Biodiversity Offsetting and Environmental Impact Assessment · Figure 6.1 The Range of Possible...
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Biodiversity Offsetting and Environmental Impact Assessment A critical analysis of the use of Environmental Impact Assessment as a vehicle for the operationalisation of Biodiversity Offsetting A thesis submitted to The University of Manchester for the degree of Doctor of Philosophy in the Faculty of Humanities 2016 RACHEL ELIZABETH MORRISON PLANNING AND ENVIRONMENTAL MANAGEMENT SCHOOL OF ENVIRONMENT, EDUCATION AND DEVELOPMENT
Transcript of Biodiversity Offsetting and Environmental Impact Assessment · Figure 6.1 The Range of Possible...
Biodiversity Offsetting and Environmental
Impact Assessment
A critical analysis of the use of Environmental Impact
Assessment as a vehicle for the operationalisation of
Biodiversity Offsetting
A thesis submitted to The University of Manchester for the degree of Doctor of
Philosophy in the Faculty of Humanities
2016
RACHEL ELIZABETH MORRISON
PLANNING AND ENVIRONMENTAL MANAGEMENT
SCHOOL OF ENVIRONMENT, EDUCATION AND DEVELOPMENT
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Contents
List of Figures ...................................................................................................................... 6
List of Graphs ...................................................................................................................... 7
List of Boxes ........................................................................................................................ 7
List of Tables ....................................................................................................................... 7
List of Maps ......................................................................................................................... 8
Abbreviations ...................................................................................................................... 9
Abstract ............................................................................................................................ 10
Copyright Statement.......................................................................................................... 11
Acknowledgements ........................................................................................................... 12
1. Introduction .................................................................................................................. 13
1.1 Conservation Controversies .............................................................................................. 13
1.2 Biodiversity in Crisis .......................................................................................................... 13
1.3 Conservation Interventions ............................................................................................... 16
1.4 Biodiversity Offsetting ....................................................................................................... 18
1.5 Evaluating Offsetting ......................................................................................................... 19
1.6 EIA and Offsetting ............................................................................................................. 20
1.7 Research Remit ................................................................................................................. 20
1.8 Thesis Structure ................................................................................................................. 21
2. Literature Review: Offsetting Origins, Controversies, and Operationalisation .................. 24
2.1 Introduction to the Literature Review .............................................................................. 24
2.2 Declining Biological Diversity: Trends, Drivers, and Consequences .................................. 24
2.2.1 Trends in Biodiversity Levels ...................................................................................... 24
2.2.2 The Importance of Biodiversity and Consequences of Decline .................................. 26
2.3 Strategies for the Conservation and Mitigation of Biodiversity Losses ............................ 28
2.4 The Rise of Biodiversity Offsetting .................................................................................... 31
2.4.1 Biodiversity Offsets as a Strategy to Halt Biodiversity Loss ....................................... 31
2.4.2 Biodiversity Offsets vs. Environmental Compensation .............................................. 34
2.4.3 Biodiversity Offsets as a Market Based Instrument ................................................... 36
2.4.4 The Promises of Biodiversity Offsetting ..................................................................... 38
2.4.5 Summary: Biodiversity Offsets as Part of the Solution to the Biodiversity Crisis ...... 40
2.5 The Contested Nature of Biodiversity Offsetting .............................................................. 41
2.5.1 Questioning the Performance of Biodiversity Offsets ............................................... 41
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2.5.2 Biodiversity Offsets and Ecological Restoration Realities .......................................... 41
2.5.3 Biodiversity Offsets and Valuation Controversies ...................................................... 43
2.5.4 Biodiversity Offsets as a Permit for Planning Permission .......................................... 45
2.5.5 Summary: Biodiversity Offsets as a Licence to Trash? ............................................... 46
2.6 Operationalising Biodiversity Offsets ................................................................................ 46
2.6.1 Evolving Offsetting Systems and Practice .................................................................. 46
2.6.2 Key Issues and Principles for Operationalising Offsetting.......................................... 48
2.6.3 Beyond Ecological Exchange Rules and Principles ..................................................... 52
2.6.4 Operationalising Offsets Through EIA ........................................................................ 53
2.7 Conclusion to the Literature Review ................................................................................. 55
3. Conceptual Framework: Integrating Biodiversity Offsets and EIA .................................... 55
3.1 Introduction to the Conceptual Framework ..................................................................... 55
3.2 Environmental Impact Assessment ................................................................................... 56
3.3 Integrating Environmental Interventions .......................................................................... 59
3.4 Assessing Integration ........................................................................................................ 61
3.5 Comparing EIA and Offsets................................................................................................ 62
3.6 Integrating EIA and Offsets ............................................................................................... 65
3.7 Research Focus .................................................................................................................. 67
4. Methodology: Investigating Integration .......................................................................... 69
4.1 Introduction to the Methodology ..................................................................................... 69
4.2 Research Domain .............................................................................................................. 69
4.3 Research Design ................................................................................................................ 69
4.4. Research Phases and Methods ........................................................................................ 72
4.4.1 Phase 1: Tracking the Emergence of Biodiversity Offsetting in the UK Context
Through Historical Analysis ................................................................................................. 72
4.4.2 Phase 2: Charting Expectations of the Integration and Interaction of EIA and Offsets
Through Expert Interviews .................................................................................................. 72
4.4.3 Phase 3: Examining the Integration and Interaction between EIA and Biodiversity
Offsetting in Practice through Case Study Analysis ............................................................ 74
4.5 Limitations to the Research Design ................................................................................... 80
4.6 Conclusion to the Methodology Chapter .......................................................................... 81
5. Tracking the Emergence of Biodiversity Offsetting in UK Planning System(s) and English
Environmental Policy ......................................................................................................... 84
5.1 Introduction to the UK Offsetting Context ........................................................................ 84
5.2 Origins, Predecessors and Early Conceptualisations ......................................................... 84
4
5.2.1 Environmental Compensation (1980s+) ..................................................................... 84
5.2.2 Hybrid Environmental Compensation-Offsetting Schemes (2000+) .......................... 87
5.2.3 Initial Interest in Offsetting the English Environmental Policy Arena (2007+)........... 89
5.2.4 Offsetting as a Tool for Corporate Social Responsibility (2007+)............................... 90
5.3 Formal Policy Proposals, Experiments and Expansion ...................................................... 91
5.3.1 Initial Offsetting Commitments in English Environmental Policy (2011+) ................. 91
5.3.2 Experimental Government Pilot Schemes (2012-2014) ............................................. 92
5.3.3 Ad-hoc Offsetting Projects (2012+) ............................................................................ 94
5.3.4 Formal Proposals: Green Paper Proposals and Consultation Responses (2013+) ..... 95
5.4 From Proposals to a Polemic (2013+) ............................................................................... 97
5.5 Current State of Play: Offsets Out of Action? ................................................................... 99
5.6 Chapter Conclusion: Emerging Offsetting Practice and Policy Polemics ........................ 100
6. Exploring Expectations surrounding the Interaction of EIA and Biodiversity Offsets ....... 104
6.1 Introduction to the Chapter ............................................................................................ 104
6.2 Practical Utility and Prospective Role(s) ......................................................................... 104
6.3 Conceptual Divisions and Barriers ................................................................................... 108
6.4. Unintended Consequences and Unexpected Opportunities ......................................... 110
6.4.1 Risks: Knock-on Effects of Weaknesses in EIA Practice ............................................ 110
6.4.2 Returns: Offsets as Catalysts for Change ................................................................. 114
6.5 Chapter Conclusions ........................................................................................................ 119
6.6 Preliminary Model of the Relationship between EIA and Offsetting .............................. 123
7. Analysing Biodiversity Offsetting and EIA in Action ....................................................... 125
7.1 Introduction to the Case Study Chapter ......................................................................... 125
7.2 Structural Connections between Offsetting and EIA ...................................................... 136
7.2.1 Structural Approaches to Offsetting and the Role of EIA ........................................ 136
7.2.2 Structural Consequences of Different Interpretations of Offsetting ....................... 139
7.2.3 Structural Connections ............................................................................................. 141
7.3 Causal Connections Between EIA and Offsetting ............................................................ 142
7.3.1 The Implications of Metric-Based Offsetting ........................................................... 142
7.3.2 The Implications of the Option to Offsets Off-site ................................................... 151
7.3.3 Causal Connections: Linking Interpretations and Implications ................................ 158
7.4 Substantive Connections for Decision-Making ............................................................... 159
7.4.1 Interactions Between Offsetting, EIA and Decision-making .................................... 159
7.4.2 The Presence and Influence of Offsetting in Decision-Making ................................ 162
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7.5 Delivery Connections Between EIA and Offsetting ......................................................... 163
7.5.1 Converting Offsets from Planning Commitments to Restoration Realities ............. 163
7.5.2 The Challenge of Delivering and Implementing Offsets........................................... 167
7.6 Connections between EIA and Biodiversity Offsetting ................................................... 167
8. Disentangling the Relationship between EIA and Biodiversity Offsetting ....................... 171
8.1 Introduction to the Discussion Chapter .......................................................................... 171
8.2 Reflecting on Integration and Key Points for Further Discussion ............................... 171
8.3 Integration Outcomes: Question for Future EIA Purpose and Practice .......................... 173
8.3.1 Shifting from Qualitative to Quantitative: How Offsetting Metrics Influenced the EIA
Process .............................................................................................................................. 173
8.3.2 Delivering Green Gains: Mitigation, Implementation, and EIA ................................ 178
8.3.3 Beyond the Site Boundary: Linking EIA and Landscape-Scale Conservation ........... 179
8.3.4 Summary: Offsetting and Future EIA Practice .......................................................... 181
8.4 Integration and Operationalisation: Questions and Challenges for Offsetting .............. 182
8.4.1 Diverging Ideas on the Value and Purpose of Biodiversity Offsetting ..................... 182
8.4.2 Operational Issues for Emerging Offsetting Practice ............................................... 184
8.4.3 Summary: Biodiversity Offsetting Conceptual and Operational Development ....... 186
8.5 Chapter Conclusions ........................................................................................................ 186
9. Conclusion: The Relationship between EIA and Biodiversity Offsetting .......................... 188
9.1 Reflecting on the Research Aim and Objectives ............................................................. 188
9.2 Research Contributions ................................................................................................... 193
9.3 Research Implications and Recommendations ............................................................... 193
9.4 Research Limitations ....................................................................................................... 196
References ...................................................................................................................... 197
Appendices ..................................................................................................................... 225
Word Count: 79567
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List of Figures
Figure 2.1 The Transgression of Planetary Boundaries 24
Figure 2.2 Total Economic Value of Ecosystem Conservation 28
Figure 2.3 Biodiversity Offsetting as Part of the Mitigation Hierarchy (Flora and
Fauna International)
34
Figure 2.4 The Source-Receptor-Pathway and the Distinction between Mitigation and Compensation
36
Figure 2.5 General Model of the Biodiversity Offsetting Credit-Debit System 37
Figure 2.6 Biodiversity Offsets as a Tool for No Net Loss 39
Figure 2.7 The Landscape Ecology Benefits of Biodiversity Offsetting 40
Figure 3.1 The EIA Process 57
Figure 3.2 Forms of Integration 61
Figure 3.3 Categorisations of Appraisal Tools 62
Figure 3.4 Integration Framework for EIA and Biodiversity Offsetting 67
Figure 4.1 An Overview of the Methodological Strategy: Linking the Research Aim, Objectives and Data Collection Phases
71
Figure 5.1a Timeline of the key Stages and Events in UK Offsetting Policy Proposals and Practice -Part A
82
Figure 5.1b Timeline of the Key Stages and Events in UK offsetting Policy Proposals and Practice - part b
83
Figure 5.2 Defra Biodiversity Offsetting Metric 93
Figure 5.3 Integrating Biodiversity Offsetting within the Planning System 96
Figure 5.4 Typology of Forms of Offsetting Taking Place across the UK 103
Figure 6.1 The Range of Possible Roles for EIA in Offsetting 108
Figure 6.2 Updated Potential roles for EIA in Offsetting Reflecting Conceptual
Disconnections
110
Figure 6.3 Updated Potential Roles for EIA in Offsetting After Consideration of Procedural and Behavioural Risk
114
Figure 6.4 Summary of Interviewees’ Expectations of the Relationship between EIA and Offsetting
121
Figure 6.5 Model of the Possible Relationships Between EIA and Biodiversity
Offsetting
120
Figure 6.6 Expectation of the Integration and Interaction of EIA and Offsetting 122
Figure 6.7 Degrees of Integration of EIA and Offsets 124
Figure 7.1 The Geographical Context of the Case Studies 126
Figure 7.2 Reactive Offsetting Using EIA as an Information Trigger 138
Figure 7.3 Proactive or Pre-Emptive Offsetting using EIA as an Analytical
Framework
138
Figure 7.4 Retrospective Offsetting Separated from the EIA Process 138
Figure 7.5 Links Between the Different Structural Approaches and
Conceptualisations of Offsetting
141
Figure 7.6 Summarising the Interaction Between EIA and the Offsetting Metric 150
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Figure 7.7 Comparison Between the Expectations and Practice 168
Figure 8.1 Conceptual Model of the Forms of Integration of EIA and Offsetting 172
List of Graphs
Graph 1.1 Living Planning Index 14
Graph 1.2 Portion of Threatened Species Affected by Each Driver of Biodiversity Decline
14
Graph 2.1 Levels of Global Biodiversity Loss since the 1970s 25
Graph 2.2 Biodiversity Offsetting Programmes Worldwide by Decade of Creation 31
List of Boxes
Box 1.1 Global Biodiversity Commitments 16
Box 2.1 Perspectives on the Intrinsic Value of Biodiversity 27
Box 2.2 Definitions of Biodiversity Offsets 33
Box 2.3 BBOP Principles for Biodiversity Offsetting Agreed by BBOP Members 49
Box 2.4 How Impact Assessment can contribute to the design and implementation of biodiversity offsets
54
Box 4.1 Main Themes Covered in the Interviews 74
Box 4.2 Key Criteria for Case Study Selection 78
Box 5.1 Hybrid Compensation-Offsetting Schemes 87
Box 7.1 Offsetting Metrics and Impact Identification in EIA 144
Box 7.2 Offsetting Metrics and EIA Impact Significance 146
Box 7.3 Offsetting Metrics and the Adherence to the Mitigation Hierarchy in EIA
148
Box 7.4 Offsets and Impacts 153
Box 7.5 Offsets and Impact Significance 154
Box 7.6 Offsets and Adherence to the Mitigation Hierarchy in EIA 157
List of Tables
Table 2.1 International Biodiversity Offsetting Schemes 38
Table 2.2 Biodiversity Offsetting Metrics and Currencies 43
Table 2.3 Common Challenges Surrounding Offset System Design and
Implementation
50
Table 3.1 Meanings of Integration in Environmental Assessment and Governance 60
Table 4.1 Breakdown of the Interviewees by Sector 74
Table 5.1 Examples of Compensation Project for Impacts on Natura 2000 Sites 86
Table 5.2 Defra Biodiversity Offsetting Pilot Schemes 94
Table 7.1 Sequence of Events Leading Up to Offsetting in the Case Studies 135
Table 7.2 Impacts that Offsets Were Used to Address in the Case Studies 151
Table 7.3 Comparing the Implications of Metric-based Offsetting and Off-site
Offsets with EIA
158
Table 7.4 Implementation and Delivery of Offsets in the Case Studies 164
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List of Maps
Map 7.1 Glenkerie Site and Local Context 128
Map 7.2 CR2 Site Map and Local Context 130
Map 7.3 The Gateway Site Map and Local Context 132
Map 7.4 Whitehouse Farm Site Map and Local Context 134
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Abbreviations
BBOP Business and Biodiversity Offset Programme
CBD Convention on Biological Diversity
CSR Corporate Social Responsibility
DEFRA Department for Environment, Food and Rural Affairs
DCLG Department for Communities and Local Government
EAC Environmental Audit Committee
EcIA Ecological Impact Assessment
EIA Environmental Impact Assessment
EIS Environmental Impact Statement or Environmental Statement
EMS Environmental Management System
EO Ecology Officer
EPS European Protected Species
EU European Union
GP Green Paper
IUCN International Union for Conservation of Nature and Natural Resources
LPA Local Planning Authority
MBI Market Based Instrument
NTYC North-Tyneside Council
NEWP Natural Environment White Paper
NPPF National Planning Policy Framework
NTS Non-Technical Summary
NGO Non-Government Organisation
NNR National Nature Reserve
PO Project Officer
SBC Scottish Borders Council
SCC Somerset County Council
SEA Strategic Environmental Assessment
SPA Special Area of Conservation
SSSI Site of Special Scientific Interest
SBI Site of Biological Importance
UK United Kingdom
UN United Nations
USA Unites States of America
WDC Warwickshire District Council
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A Critical Analysis of the Use of Environmental Impact Assessment as a vehicle for the
Operationalisation of Biodiversity Offsetting
Rachel Morrison, University of Manchester for the Degree of Doctor of Philosophy, 2016
Abstract
Biodiversity offsetting mechanisms are increasingly applied worldwide as a new solution to the current
biodiversity crisis. The offsetting approach is idealised as a means to achieve no net loss of biodiversity.
Offsetting mechanisms aim to quantify residual biodiversity losses and enable developers to account for
residual impacts off-site. Despite rising global application, the effectiveness of offsetting is by no means
assured. The question of whether and how offsetting can be operationalised to achieve no net loss has
become a key focal point in debates surrounding their effectiveness. Environmental Impact Assessment,
or EIA, has been portrayed as an obvious ‘vehicle’ for integrating offsetting into existing corporate
management systems and planning systems, and therefore a key factor over how offsetting mechanisms
operate. This research critically investigated the nature of integration and interactions between EIA and
offsetting using a three phase qualitative research design, which brought together analysis of emerging
policy, expert interviews and in-depth case studies.
The study provides insight into an emerging relationship between EIA and offsetting which is highly
differentiated. It finds that EIA has considerable use value in the operationalisation of offsetting. The EIA
process can play various roles in triggering offsets and in providing an analytical framework for offsetting
metrics. However, there are also clear conceptual disconnections between these two mechanisms which
limit the utility of EIA for operationalising offsetting and can equally place these two mechanisms in
conflict. Interviews with policy-makers and practitioners reveal disillusionment with current EIA process,
a perception that problems with EIA could have negative implications for offsetting, and a minority view
that offsetting could be a catalyst for change in EIA practice.
Case studies of the application of offsetting in four UK development planning applications give insight into
two main forms of integration. These are based on different interpretations of the value and purpose of
offsetting in relation to EIA. First, offsetting metrics have been integrated analytically into the EIA process
and used as a new methodology. Second, in instances of more consecutive integration, offsets have been
bolted-on to the EIA process to provide off-site solutions to unavoidable impacts. Through analytical
integration, offset metrics can extend impact identification, challenge the place of subjective expert
judgement and the acceptability of residual impacts, and provide a measure of mitigation
(in)effectiveness. In contrast, under consecutive forms of integration, the application of offsetting is much
more dependent on subjective conceptualisations of impact significance and subject to existing
weaknesses in the EIA process. Therefore, the form of offsetting’s integration with EIA has implications
for how it works as a tool for mitigation. This research does not suggest that EIA and offsets are
incompatible, but, that the uncritical combination of these two mechanisms should be avoided.
These and other research findings suggest that despite complaints about the validity and reductionist
nature of offsetting metrics, in relation to EIA they could have pragmatic value as a management and
negotiation tool to engender change and account for current disillusionment with EIA performance.
Furthermore, the dynamics of integration and interaction between EIA and offsetting, in the UK context,
highlight fundamental questions still surround what offsetting is trying to achieve and the particular
problems with the planning system we are trying to resolve through offsets. For future practice this
research highlights that we need to pay greater attention to the variability in offsetting practice, to
acknowledge different interpretations, formulations and outcomes.
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Declaration
I declare that no portion of the work referred to in this thesis has been submitted in support of
an application for another degree or qualification of this or any other university or other institute
of learning.
Copyright Statement
The author of this thesis (including any appendices and/or schedules to this thesis) owns certain
copyright or related rights in it (the “Copyright”) and he has given The University of Manchester
certain rights to use such Copyright, including for administrative purposes.
Copies of this thesis, either in full or in extracts and whether in hard or electronic copy, may be
made only in accordance with the Copyright, Designs and Patents Act 1988 (as amended) and
regulations issued under it or, where appropriate, in accordance with licensing agreements
which the University has from time to time. This page must form part of any such copies made.
The ownership of certain Copyright, patents, designs, trademarks and other intellectual
property (the “Intellectual Property”) and any reproductions of copyright works in the thesis, for
example graphs and tables (“Reproductions”), which may be described in this thesis, may not
be owned by the author and may be owned by third parties. Such Intellectual Property and
Reproductions cannot and must not be made available for use without the prior written
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Further information on the conditions under which disclosure, publication and
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restriction declarations deposited in the University Library, The University Library’s regulations
(see http://www.library.manchester.ac.uk/about/regulations/)and in The University’s policy on
Presentation of Theses.
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Acknowledgements
I am grateful to the Economic and Social Research Council and President’s Doctoral Scholar
Award for funding this PhD research.
Thanks to Adam Barker and Carys Jones for their encouragement and guidance as they
supervised me through the PhD process, helping me to develop as a researcher. Their experience
has helped immeasurably. Thanks also to Anna Gilchrist for her advice and enthusiasm over the
past four years.
Thanks to my family for all their support, especially my mum Kerry and my sister Jenny who
helped with proof-reading of chapters, among many other acts of kindness.
There are many colleagues and friends who have helped me along the way – my thanks go to all
of them. Evelyn Bateman, Sara Hassan, Charles Jarvis, Moozhan Shakeria, Helen Underhill and
Kelly Watson each deserve special thanks.
Thanks finally to Robbie Watt for his support and encouragement, especially in the final months
as I worked to prepare the thesis for submission.
The Author
Rachel Morrison is a PhD candidate in Planning and Environmental Management in the School
of Environment, Education and Development at the University of Manchester. Her previous
degrees are in Physical Geography (BSc) from Durham University and in Environmental Impact
Assessment and Management (MA) from the University of Manchester.
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1. Introduction
1.1 Conservation Controversies
Interventions for wildlife and nature conservation can be highly controversial. Exclusionary
conservation policies have, historically, sought to protect wildlife through ‘fortress
conservation’, the creation of national parks and game reserves, at the cost of the eviction and
exclusion of native people and the separation of nature and society (Brockington, 2002).
Contemporary conservation controversies are led by a new wave of can-we-should-we moral
and ethical dilemmas surrounding the use of technology and genetic rescue to bring back species
from the brink of extinction, such as the Northern White Rhino (Callaway, 2016), or even to
resurrect species through ‘de-extinction’ and human reengineering of species, where candidates
include the European Great Auk and the Passenger Pigeon (Revive and Restore, 2016). While a
proliferation of new conservation interventions in the form of Market Based Instruments or
MBIs, classified for their monetary connections and link to price signals (Hrabanksi, 2015;
Lapeyre et al., 2015l; Pirard, 2012), have divided the conservation community. New market
based interventions, such as biodiversity offsetting or payments for ecosystem services, are
perceived, paradoxically, as both the commodification of nature and an effective way to finance
and promote conservation (Lapeyre et al., 2015; MacDonald, 2010). For the 21st century, the
criticality of these conservation controversies is only likely to increase in the face of the currently
biodiversity crisis.
1.2 Biodiversity in Crisis
Biodiversity, shorthand for biological diversity, refers to “the sum of all organisms on Earth, their
variation and the ecosystems which they are a part” or more simply put “life on earth” (Pereria
et al., 2012:27). Our global biodiversity is the unique product of approximately 3.5 billion years
of life on earth (Katz, 1992), considered to be a cornerstone of healthy ecosystems (Hector and
Bagchi, 2007) and intimately linked to human wellbeing (MEA, 2005). However, global
biodiversity levels are widely acknowledged to be undergoing the highest rate of decline in
human history (MEA, 2005; Pereria et al., 2012). Barnosky et al. (2011) highlight that the current
rate of species extinction is estimated to be somewhere in the region of 20 to 40 times greater
than background rates of extinction. Novacek and Cleland (2001) recognise that the current rate
of extinction could fundamentally reset the future evolution of the planet’s biota. The Living
Planet Index, one of the main global metrics used to assess changes in global species abundance
of vertebrate species populations (Graph 1.1), has been used to establish that there has been a
52% decline in vertebrate species populations’ abundance levels between 1970 and 2010 (The
Living Planet Report, 2014).
The current net loss of biodiversity reported by Barnosky et al. (2011), Novacek and Cleland
(2001) and the Living Planet Index is widely attributed to a human induced acceleration of
natural rates, linked to anthropogenic causes such as habitat change and loss, pollution, over
exploitation and the introduction of invasive species and climate change (as shown in Graph 1.2
below). Habitat loss, in particular, is thought to be the primary cause of biodiversity decline
(Hambler, 2011; Young, 2000; MEA, 2005). Essentially, “as the human footprint on the planet
increases, biodiversity declines” (Periera, 2012:26). The magnitude and scale of human-driven
biodiversity loss create a crisis which is now one of the most pressing global environmental
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challenges (Pimm, et al. 2014; Barnosky et al., 2011; Novacek and Cleland, 2001; Pereria et al.,
2012; Steffen et al., 2015).
Graph 1.1 Living Planning Index (Living Planet Report, 2014)
Graph 1.2 Portion of threatened species affected by each driver of biodiversity decline, including
mammals, birds and amphibians in the critically endangered, endangered and vulnerable IUCN
Red List Categories (Pereria et al., 2012)
In response to the biodiversity crisis, numerous multi-lateral environmental agreements have
been adopted to try to address global biodiversity loss. These have generally taken the form of
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conventions, which can be understood as international agreements between two or more
countries which deal with a specific subject of common concern. Conventions are legally binding,
and once ratified the country becomes a ‘contracting party’ to the convention. There are seven
major biodiversity related multi-lateral agreements, including the Convention on Biological
Diversity; the Convention on International Trade in Endangered Species of Wild Fauna and Flora;
the Convention on the Conservation of Migratory Species of Wild Animals; the International
Treaty on Plant Genetic Resources for Food and Agriculture; the Convention on Wetlands and
the World Heritage Convention and the International Plant Protection Convention.
Most notably, the Conventional on Biological Diversity, or CBD, relates to global biodiversity loss
and seeks to ensure that:
“By 2050, biodiversity is valued, conserved, restored and wisely used, maintaining
ecosystem services, sustaining a healthy planet and delivering benefits essential for
all people” (CBD, 2010).
The CBD provides a globally unified agenda to tackle the conservation and sustainable use of
biodiversity. Biodiversity is also mentioned in the 17 United Nations (UN) sustainable
development goals, adopted as part of the 2030 Agenda for sustainable development (Goals 14
and 15 shown in Box 1.1). The CBD lies at the heart of global conservation efforts. However, the
achievement of its overall aspiration has been problematic (Chandra and Idrisova, 2011;
Butchart et al. 2010). The CBD originally committed parties to a significant reduction in the global
rate of biodiversity loss by 2010. The failure to achieve this target was linked, by Butchart et al.
(2010), to the combined effects of increased human pressures and inadequate conservation
responses. In response to this failure, the CBD put forward an ambitious new plan containing 20
new biodiversity targets (Aichi targets) to be met by 2020 (CBD, 2010) (see Box 1.1).
The future is not entirely bleak – there have been some conservation success for individual
species. Notably, 2016 saw the Giant Panda, the icon of the global conservation movement, re
categorised from critically endangered to only vulnerable by the IUCN (IUCN red list – IUCN,
2016). Deinet et al. (2013) reported that although total levels of biodiversity in Europe is
decreasing there is evidence that some larger wildlife and bird species are making a comeback.
Targeted species conservation, protection and reintroduction along with marginal farming land
abandonment is leading to some conservation successes. However, these successes are few and
far between and despite increased efforts and the expansion of protected areas, the cumulative
and expansive scale of the pressure on biodiversity means that the 2020 targets are still likely to
be missed (Tittensor et al., 2014).
In the face of seemingly continual, and accelerating, levels of biodiversity decline, the Global
Biodiversity Outlook 4 (Secretariat of the Convention on Biological Diversity, 2014) called for
urgent action to meet 2020 targets:
“The time for talk is done; it is now the time for action. The story is disruptive
change. Disrupt the current paradigm because what we’re doing is good but not
enough” (Inger Andersen, 2016, IUCN World Conservation Congress 2016)
In order to achieve aspiration to halt biodiversity loss, the CBD is pushing for the scaling up of
financing and resources to halt biodiversity loss and the degradation of ecosystems. In essence,
16
an increase in government responses and interventions to ensure they are commensurate with
the scale of biodiversity decline and the strengthening of conservation measures.
Box 1.1 Global Biodiversity Commitments
1.3 Conservation Interventions
The repeated failure to meet targets to halt biodiversity loss has driven a diversification of
conservation interventions and strategies (Rands et al., 2010). In an attempt to up the scale of
Global Biodiversity Commitments
Convention on Biological Diversity Aichi Targets:
Aichi Target 5: By 2020, the rate of loss of all natural habitats […], is at least halved and where
feasible brought close to zero, and degradation and fragmentation is significantly reduced…
Aichi Target 11: By 2020, at least 17 per cent of terrestrial and inland water, and 10 per cent
of coastal and marine areas, especially areas of particular importance for biodiversity and
ecosystem services, are conserved …
Aichi Target 12: By 2020 the extinction of known threatened species has been prevented and
their conservation status, particularly of those most in decline, has been improved and
sustained …
Aichi Target 13: By 2020, the genetic diversity of cultivated plants and farmed and
domesticated animals and of wild relatives, including other socioeconomically as well as
culturally valuable species, is maintained…
Sustainable Development Goals:
Goal 14: Conserve and sustainably use the oceans, seas and marine resources for sustainable
development…
14.5 By 2020, conserve at least 10 per cent of coastal and marine areas, consistent
with national and international law and based on the best available scientific
information…
Goal 15: Protect, restore and promote sustainable use of terrestrial ecosystems, sustainably
manage forests, combat desertification, and halt and reverse land degradation and halt
biodiversity loss…
15.1 By 2020, ensure the conservation, restoration and sustainable use of terrestrial
and inland freshwater ecosystems and their services, in particular forests, wetlands,
mountains and drylands…
15.4 By 2030, ensure the conservation of mountain ecosystems, including their
biodiversity....
15.5 Take urgent and significant action to reduce the degradation of natural habitats,
halt the loss of biodiversity and, by 2020, protect and prevent the extinction of
threatened species.
17
the response to the biodiversity crisis, a multitude of new interventions and mechanisms have
been introduced to try to tackle the various threats and pressures on biodiversity (Global
Biodiversity Outlook 4, 2015). Proposed solutions and interventions to combat the biodiversity
crisis have expanded beyond protected sites and species, to include eco-tourism, environmental
certification, payments for ecosystem services, or the use of campaigns to increase
environmental awareness and funding, agricultural subsidies for nature conservation,
biodiversity offsetting, biodiversity action plans and strategies, and construction of best practice
standards (Brown, 2002; Rands et al. 2010). There is now an extensive portfolio of possible
strategies and interventions which can be employed, in parallel, to try to reverse the trend of
biodiversity loss.
At the root of biodiversity loss is the conflict between economic growth and the conservation of
biodiversity (Young et al., 2007). Particularly, the direct loss of habitat through land use change
and built environment, with its highly altered landscapes and rapid human-caused changes to
local ecosystems, is accepted as a major driver of biodiversity change (Pereira et al., 2012; Sala
et al., 2000). There has been a considerable effort to try to shift from a position of conflict
between development and conservation, to improve conflict management and move towards
more sustainable development models (e.g. Petersson et al., 2013; Redpath et al., 2013). For
the built environment a key strategy to achieve sustainable development has been an increased
focused on mitigation as a means to minimise impacts on biodiversity caused by developments.
Within the field of biodiversity conservation, mitigation approaches have always been seen as a
more development-friendly alternative to strict environmental laws, allowing development to
occur when environmental laws might otherwise prohibit development (Wood, 2003). However,
Drayson and Thompson (2013) highlight that mitigation strategies are also an essential part of
reducing impacts on biodiversity, stressing that “the flaws in the system that allows built
development to contribute to biodiversity loss need to be identified and remedied” (Drayson and
Thompson, 2013:103) (see also Novack and Cleland, 2011).
How best to mitigate for the complex problem of biodiversity loss, and reconcile development
impacts with biodiversity objectives, has been a continual concern for biodiversity conservation
and efforts to meet global commitments to halt declining biodiversity levels under the CBD
(Adams and Redford, 2002; Brown, 2002). One of the most recent additions to the field of
mitigation, introduced as part of the push to scale up response to the biodiversity crisis, is
biodiversity offsetting which is increasingly promoted as a key piece of the puzzle to achieve
targets to halt decling biodiversity levels (ten Kate et al., 2004; IUCN, 2014; BBOPa, 2012;
Gillespie, 2012).
“The current planning system, largely without offsets, results in a significant
cumulative loss of biodiversity” […] “In the past society was prepared to accept
projects’ residual social and environmental impacts in exchange for the economic
benefits of jobs and revenue. Contemporary expectations are for net social,
environmental and economic gain – demonstrated by a more rigorous approach to
the quantification of impacts and benefits” (ten Kate, et al., 2013:17 and 22)
Biodiversity offsetting is part of the new wave of conservation approaches which aim to achieve
more for biodiversity conservation through introducing new techniques and mechanisms (OECD,
18
2013), and moving beyond the protectionist agenda towards intervention ecology and increased
ecological restoration (Suding, 2010). However, as highligted in section 1.1, biodiveristy
offsetting is also a controversial conservation intervention.
1.4 Biodiversity Offsetting
Biodiversity offsetting (*hereafter offsetting or offsets) is increasingly promoted as a win-win
strategy to help halt biodiversity loss alongside continued economic development (Madsen et
al., 2011; ten Kate et al., 2004; Pilgrim and Elkstrom, 2014). Offsetting is an environmental
compensation tool which aims to achieve overall no net loss of biodiversity levels through
quantifying biodiversity losses and providing a mechanism through which to deliver equivalent
gains off-site (ten Kate et al., 2004; Bull et al., 2013; Gardener et al., 2013). The central tenet of
offsetting mechanisms is the trading of environmental losses for restoration gains, through
permit systems and credit-debit swaps, to try to balance the competing objectives of
development and conservation to achieve overall aspirations of no net loss of biodiversity
(Maron et al., 2016; Spash, 2015; Apostolopoulou and Adams, 2015).
Offsetting is idealised as a mechanism to achieve no net loss of biodiversity (ten Kate et al.,
2004), to drive increased levels of environmental restoration and counteract flaws in the current
system and work as a ‘missing piece of the conservation puzzle’ (Gillespie, 2012). Not only is
biodiversity offsetting linked to reduced levels of biodiversity decline, but it is also connected to
a multitude of other possible benefits such as increased efficiency, the generation of markets
and new funding streams for biodiversity, landscape-scale restoration and greater benefits for
biodiversity (ten Kate et al., 2004; Kiesecker et al., 2009; Latimer and Hill, 2007).
However, the premise behind offsetting, the trading or swapping of biodiversity losses in one
location for uncertain gains in another, has divided opinions in academia, policy and practice.
“Offsets, along with biodiversity and ecosystem valuation, use economic logic to
legitimise, rather than prevent, ongoing habitat destruction” (Clive Spash,
Academic, WU Vienna University for Economics and Business, In Spash, 2015:541)
“Where there is no alternative, biodiversity offsets can be useful. But offsetting can
be abused. If governments want to use this as a window-dressing for a pro-growth
agenda, as I fear that Britain does, it can be very dangerous" (Tony Juniper, NGO
member and Former Head of Friends of the Earth, In Vidal, 2014).
“Biodiversity offsetting is controversial. People suspect developers of trying to buy
their way out of conservation requirements by compensating for biodiversity losses
somewhere else. But the framework offsetting provides has several advantages
that current wildlife legalisation does not offer, and we desperately need these if
we’re to reach our UK target of halting biodiversity loss by 2020” (Julia Baker,
Practitioner and Biodiversity Expert, Balfour Beatty, In Baker, 2016).
Offsetting is also presented as ‘greenwashing’ (Maron and Watson, 2015), ‘cash for damage’
(Brown et al., 2015), and even referred to as a ‘Trojan horse’ (King, 2014). These criticisms are
based on ideas that rather than working as tool for conservation, through exchanging
biodiversity losses for uncertain gains offsetting could instead operate as a ‘licence to trash’
19
(Walker et al. 2009; Maron et al., 2010). Therefore, the rising application of offsetting, reported
by Madsen et al. (2011), is occurring in combination with increasing levels of concerns around
its ethics, effectiveness and implications. As summarised by Peter Unwin, Director General of
the policy delivery group at the UK environmental ministry Defra, at the first international
conference on offsetting “I don’t think I have ever seen so much suspicion on either side of a
debate” (Peter Unwin, Defra Minster, in Vidal, 2014).
1.5 Evaluating Offsetting
Offsetting in many contexts is still in its infancy (Marsh, 2015). Therefore, we are still learning
and evaluating the potential of offsetting because its outcomes are by no means resolved. In
this emerging field of research, there are, arguably, three main areas of evaluation currently
being undertaken. Firstly, there is a growing body of research investigating the conceptualisation
of offsetting as a market oriented approach (Lapeyre et al., 2015; Boisvert, 2015, 2013;
Hrabanski, 2015; Coralie et al, 2015), and concerned with offsetting as the financialisation of
nature (e.g. Apostolopoulou and Adams, 2015; Büscher et al. 2012; Robertson et al., 2004, 2006;
Spash, 2015; Sullivan, 2013). Secondly, there is a longstanding body of research studying the
ecological performance of restoration sites, and the achievement of no net loss or desired
ecological targets through compensation approaches and offsetting schemes (Strange et al.,
2002; Gibbons and Lindenmayer 2007; NRC, 2001; Matthews and Endress 2008; Robertson,
2006; Quigley and Harper 2005; Mack and Micacchion 2006; Burgin, 2008; Race and Fonseca,
1996). This research broadly suggests that the effectiveness and performance of restoration is
questionable with relatively mixed reviews in terms of general instrumental effectiveness.
According to Quigley and Harper (2006) the current application of offsets are at best slowing
down, but not halting the rate of habitat loss. Thirdly, and in response to concerns around the
ecological performance of offsets, there is also a growing body of conservation literature
concerned with the technical challenge of implementing offsets. This body of research has begun
to investigate the operational conditions and ecological contingency factors that could enable
offsetting to best achieve no net loss of biodiversity (Gardner et al., 2013; Gardner and von Hase,
2012; Bull et al., 2013; Maron et al., 2016; Norton, 2008; BBOP, 2012a,b,c; IUCN, 2014; Pilgrim
et al., 2012). Essentially this research is exploring whether and how offsetting systems can be
operationalised to achieve no net loss.
The question of whether and how offsetting can be operationalised to achieve no net loss of
biodiversity has become the key focal point in debates surrounding the effectiveness of
offsetting, and a critical discussion point for the design of an increasing number of offsetting
systems worldwide (Quétier et al., 2014; Gardner et al., 2013; Treweek et al. 2009; IUCN, 2014).
As an emerging field of research, whether and how offsetting systems should operate has largely
focused on technical questions, such as the design of offsetting metrics (e.g. Gonçalves et al.,
2012; Quétier and Lavorel, 2011; Bull et al., 2014), how to determine the best spatial location
for offsets (Kiesecker et al., 2009, 2010), and the design of frameworks to determine the
‘offsetability’ of impacts (e.g. Pilgrim et al, 2012). Collectively, this body of research has built up
a wide range of challenges and issues for consideration in operationalising offsetting, as outlined
in Gardner et al. (2013), Bull et al. (2013) and Maron et al. (2016). However, these studies
generally consider offsetting, and its effectiveness, in isolation rather than embedded and
interacting within existing tools for environmental governance and regulatory frameworks.
20
Offsetting is unlikely ever to be used as a sole policy for biodiversity conservation, yet the
interaction between offsetting systems and existing regulatory frameworks and instruments is
relatively unstudied and the implications for offset effectiveness are unknown. There is a
growing appreciation of the need to study these connections, and the effects of planning,
implementation and management deficiencies on the achievement of no net loss (Gardner and
von Hase, 2012; Tisheew et al., 2010; Race and Fonesca, 1996).
1.6 EIA and Offsetting
Environmental Impact Assessment, or EIA, is a globally applied procedure for environmental
appraisal. It is an established approach for forecasting the possible environmental consequences
of development proposals and for determining appropriate measures to avoid, reduce or
compensate for impacts (Canter, 1996). EIA is applied worldwide and likely to be a key part of
the existing regulatory framework for offsetting across international practice (BBOP, 2009a;
Hayes and Morrison-Saunders, 2007; Middle and Middle, 2012; Melton, 2005; Gillespie, 2012;
Brownlie and Botha, 2009; Doswald et al., 2012; Slootweg et al., 2010). The core link between
EIA and offsetting is the mitigation hierarchy, which is fundamental to both the EIA process and
the application of offsetting. In literature and guidance related to offsetting, EIA is already
referred to as an obvious ‘vehicle’ to aid the operationalisation of offsetting (BBOP, 2009a), and
offsets have even been described as a subset of the impact assessment paradigm (Race and
Fonesca, 1996). Furthermore, Doswald et al. (2012) highlight that offsetting systems are already
closely linked to EIA regulations in South Africa, Mexico, Chile, China, and Pakistan. Therefore,
EIA is a key part of the wider context within which biodiversity offsets will be operationalised.
However, exactly how EIA and offsets will interact, and how this might shape also the
effectiveness of offsets, has received relatively little investigation (cf. BBOP, 2009a).
The integration of EIA and offsetting has generally been assumed to be positive rather than
actively investigated or critically reviewed. At present offsets are, generally, not considered part
of impact assessment (Gillespie, 2012), and exactly what the integration of offsetting and EIA
will entail is far from clear. EIA and offsetting derive from quite different origins and remits,
therefore their compatibility and degree of integration could be complex. There is also an
extensive body of existing research and criticism related to the ecological component of EIA
(Drayson and Thompson, 2013; Tinker et al., 2005; Thompson et al., 1997; Treweek and
Thompson, 1997; Slootweg et al., 2010), which brings into question whether it is even advisable
to link up these two mechanisms and to what degree offsetting could enhance the EIA process
(Jay et al, 2007). If offsets are likely to become part and parcel of impact assessment there is a
clear need to critically consider the compatibility of these two environmental management
mechanisms, the implications of their integration, and the outcomes for both offset
effectiveness and EIA practice.
1.7 Research Remit
The remit for this research was to critically investigate the relationship between EIA and
offsetting and outline the possible dynamics of their integration and interaction. Through
investigating the connections and compatibility of these two mechanisms, this research hopes
to provide a clearer basis for integration and comment on the role of EIA as a ‘vehicle’ for offsets.
Through exploring integration, this research also aims to establish another perspective for the
21
wider debate on the operationalisation and effectiveness of offsetting, and on the role of EIA as
a tool for environmental management and sustainable development.
Research aim:
To analyse whether biodiversity offsetting can stem the continual decline in
biodiversity as a compensation tool in EIA.
Research Objectives:
Objective 1: To review the theoretical basis for, and the controversies surrounding
the operationalisation of biodiversity offsetting as a new solution to the biodiversity
crisis.
Objective 2: To map out expectations around the integration of biodiversity offsets
and EIA, and the possible dynamics of their interaction.
Objective 3: To explore the connections between biodiversity offsetting and EIA in
emerging practice and identify any possible areas of interaction and evidence of
implications.
Objective 4: To critically reflect on the outcomes of integrating EIA and biodiversity
offsetting in existing planning practice and the implications for the treatment and
management of biodiversity impacts.
1.8 Thesis Structure
Following on from the introduction, Chapter 2 outlines the current knowledge and research
developments surrounding biodiversity offsetting. First, summarising the background to
offsetting, by highlighting the extent of the biodiversity crisis and the place of biodiversity
offsetting within the spectrum of different conservation strategies. This provides a clear picture
of the factors which have contributed to the promotion and proliferation of offsetting
mechanisms. The key concepts and characteristics of offsetting, as a strategy to halt the
biodiversity crisis, are discussed, focusing on offsetting as a compensation mechanism and a
market based approach. After developing a picture of the origins, conceptual characteristics and
potential role of offsetting as a conservation strategy, the review then assesses offsetting
mechanisms as a controversial conservation tool. This Chapter highlights issues of ethics and
effectiveness surrounding ecological restoration and valuation, plus more fundamental
concerns around the possible effects of the option to offset on decision-making. Finally, the
literature review explores current research surrounding the operationalisation of biodiversity
offsetting, outlining the core conceptual challenges in offset system design and the development
of universal principles for offsetting practice. Finally, the review introduces EIA as part of the
wider receiving environment for biodiversity offsetting and outlines the part it could play in
offsetting.
Chapter 3 introduces a framework for examining the integration of EIA and offsetting. This
Chapter outlines EIA as an established procedural approach to predicting environment impacts,
and as an existing framework through which to propose mitigation for the potential impacts
caused by development projects. The possible dynamics and dimensions of integration are then
22
discussed. A framework for integration is then developed through reviewing existing literature
and conceptual approaches in the field of integrated assessment. Chapter 3 then provides an
initial comparison of EIA and offsetting, based on the integration framework. The comparison
shows that the relationship between these two mechanisms is far from clear cut. EIA and
biodiversity offsetting are not necessarily incompatible but have a number of conceptual
differences and world views. The output of the Chapter is the development of a research focus
on the investigation of integration.
Chapter 4 describes the methodological approach adopted to investigate integration, outlining
a three-phased research design to explore the relationship between EIA and offsets in the UK
context. The choice of the UK context as the domain of investigation is explained, linked to
exploring an emerging offsetting system without a fixed relationship between EIA and offsets.
The first phase of the methodological strategy focuses on piecing together a genealogy of
offsetting in the UK to emphasise any prior consideration of the role or relationship between
EIA and offsetting. The second phase focuses on semi-structured interviews to build up a picture
of the expected dynamics and dimensions of the relationship between EIA and offsetting. This
leads into the final phase based on developing a snapshot of emerging practice via comparative
case study analysis. The main limitations of the study are also outlined.
Chapter 5 reports on the domain of investigation, providing a detailed picture of the history and
development of biodiversity offsetting policy and practice in the UK. This Chapter tracks the
evolution of offsets from early forms of environmental compensation to full scale consultation
on English policy proposals and evaluations of the government pilots. Through analysing the
development of offsetting in the UK, this chapter highlights policy creep and evolution of ideas
surrounding offsetting, alongside a variety of different forms of offsetting in practice based on
different institutional arrangements, actors and agendas. In relation to EIA, this Chapter
suggests that there has been little formal explicit consideration of the role in policy, but some
evidence of concern around the connections between EIA and offsets.
Chapter 6 explores the findings of 23 semi-structured interviews, investigating expert
expectations around the integration and interaction of EIA and offsetting. It highlights four
dimensions of the prospective relationship between EIA and offsetting, including use-value,
conceptual disconnections, possible procedural and behavioural risks and returns. These
different dimensions are used to build a preliminary model of the possible different degrees of
interaction and integration of EIA and offsetting.
Chapter 7 builds on the findings of Chapter 6 by providing a snapshot of the relationship
between EIA and offsetting in practice. This Chapter reviews the findings of four cases studies
by discussing different forms of connection between EIA and offsetting, including structural,
causal, substantive and delivery connections. The comparative case study analysis in Chapter 7
illustrates a range of different structural connections between EIA and offsetting, based on
different interpretations of the value and purpose of offsetting. These different structural
connections are then linked into different implications for impact identification, impact
significance and the mitigation hierarchy. Substantive and delivery connections are used to
discuss areas of disconnection.
23
Chapter 8 synthesises the empirical findings of Chapters 5, 6 and 7, thereby providing a clear
picture of the possible outcomes and degrees of integration and interaction of EIA and
offsetting. This Chapter recaps the research premise then collates the research findings to
provide an overall conceptual model of the relationship between EIA and offsetting. Based on
the research findings, a number of discussion points are outlined for both future EIA practice
and for the conceptual and practical development of biodiversity offsetting.
Finally, Chapter 9 provides a set of closing reflections for the thesis, ultimately concluding on
the integration and interaction of EIA and offsetting. It outlines the main conclusions on the
potential relationship between EIA and offsets and reflects on the research aim and objectives.
The main limitations of the study and the implications of the research are acknowledged. Areas
for future research are highlighted.
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2. Literature Review: Offsetting Origins, Controversies, and
Operationalisation
2.1 Introduction to the Literature Review
Chapter 1 provided an introduction to the research, outlining the research aim and objectives.
The remit for this Chapter is to expand the research context and background by reviewing the
origins and controversies surrounding the operationalisation of biodiversity offsetting. First, the
Literature Review outlines the biodiversity crisis by exploring current levels of biodiversity loss
alongside its drivers and consequences. The next step is to then assess the main proposed
solutions to biodiversity decline, and the place of biodiversity offsetting within the wider field of
biodiversity conservation. The conceptual foundations and main assumptions of offsetting are
then discussed, prior to outlining its many controversies. The review then explores a growing
body of research focused on the technical challenges and issues surrounding the
operationalisation of offsetting to best achieve no net loss of biodiversity. The link between
biodiversity offsetting and EIA is explored and identified as a critically under investigated
component of the operationalisation of offsetting.
2.2 Declining Biological Diversity: Trends, Drivers, and Consequences
2.2.1 Trends in Biodiversity Levels
Figure 2.1 The Transgression of Planetary Boundaries, Rockström (2009). The inner green shading represents the proposed safe operating space for nine planetary systems. The red wedges represent an estimate of the current position for each variable.
Planetary boundary studies suggest that anthropogenic pressures are pushing our planet to its
limits (Rockstöm et al., 2009; Steffen et al., 2015), resulting in a growing number of global
environmental problems, including: the generation of unsustainable levels of waste, soil
degradation, air, water and land pollution, ocean acidification, lack of safe and sufficient
25
freshwater, climate change, and the loss of biodiversity (Rockström et al., 2009; Steffen et al.,
2015). Out of all the environmental problems depicted by Rockström et al., (2009) in Figure 2.1
it is evident that the loss of biodiversity is in the most critical position, with an ever growing body
of evidence charting declining global biodiversity levels (e.g. Myers, 1990; Pimm, et al. 2014;
Pimm, 2001; Novacek and Cleland, 2001; Graph 2.1). Levels of global biodiversity loss are now
thought to be at the highest rate of decline in human history (MEA, 2005). The human induced
acceleration of species extinction is estimated to be some 20 to 500 times greater than
background rates of extinction (Wilson, 1992; Ladle, 2009; Stedman-Edwards, 1997; Woodruff,
2001). The magnitude of biodiversity loss has even been described as comparable to that of a
major prehistoric global extinction events by Novacek and Cleland (2001), whilst Whittaker et
al. (2004) refers to a biodiversity as “under assault on a global basis”.
Graph 2.1 Levels of global biodiversity loss since the 1970s (WWF Living Planet Report, 2012)
The causes behind biodiversity decline are well established and firmly attributed to
anthropogenic stresses, the ever increasing extent of socio-economic alteration of the natural
environment for anthropogenic gain (e.g. Stedman-Edwards, 1997; Ladle, 2009; Sala et al., 2000;
Novacek and Cleland, 2011, Gaston and Spicer 2004; MEA, 2005). As society converts land for
agricultural use, the diversity of ecosystems is reduced; by building roads, landscapes and
ecosystems are fragmented; and by dumping waste or applying pesticides, ecosystems and
habitats are degraded. A range of factors are catalogued as drivers of biodiversity loss, including
habitat loss and degradation, the introduction of invasive species, human overpopulation,
climate change and pollution, and overharvesting and extinction cascades (e.g. Gaston and
Spicer, 2003; Ladle, 2009).
“Primary habitat loss, disturbance, and fragmentation arguably represent the greatest immediate threats to the global persistence of biodiversity and provisioning of ecosystem” (Curran et al., 2014:617).
26
Within the range of possible drivers, habitat loss or land use change is commonly thought to be
the most critical cause of biodiversity decline (Hambler, 2011; Young, 2000; MEA, 2005).
Essentially, the more societies develop, the more we impact on biodiversity. This decline in
biodiversity levels is rarely an intended consequence of human actions, but an unintended side
effect or economic externality (Rands et al., 2010). However, capitalism, and the continued
quest for growth, are considered to be at the heart of dramatic ecological changes, linked to the
acceleration of ecosystem transformations and biodiversity decline globally over the last century
(Foster 1996; Kovel 2002). As levels of economic development continue to increase during the
21st C, the stresses and pressures on the environment and biodiversity are only predicted to
further accelerate (MEA, 2005).
2.2.2 The Importance of Biodiversity and Consequences of Decline
‘Biodiversity’ is a relatively new term, conceived in 1986 as an abbreviation of ‘biological
diversity’ by the biologist Edward Wilson (National Forum on Biodiversity, 1986; Wilson, 1988),
and formulated in response to concern about the loss of organisms, communities, and entire
ecosystems.
“The variability among living organisms from all sources, including, 'inter alia,'
terrestrial, marine, and other aquatic ecosystems; and the ecological complexes of
which they are a part: this includes, diversity within species, between species and of
ecosystems" (CBD, 1992, Article 2).
Biodiversity describes the number of species of plants, animals, and micro-organisms, the many
different ecosystems on the planet which they inhabit and the enormous diversity of genes that
they contain (MEA, 2005). Therefore, the term biodiversity is, in essence, an expression of the
‘variety of life on earth’ (Ladle, 2009). The inclusion of ecosystems, and relationships between
species, indicates that biodiversity is much more than another term for species variety, diversity
or richness, but also encompasses the complex relationships of communities, habitats, spatial
groups and temporal interactions between species.
By the 1990s, biodiversity had been incorporated into the global environmental agenda as a
mainstream policy concern, following the ratification of international agreements to conserve
biodiversity through the Convention on Biological Diversity (CBD) in 1992 (Thompson and
Starzomski, 2007).
“Biodiversity is used both as a broad political term (as shorthand for the living life
support systems of the world) and in a more scientific and technical sense” (Byron,
2000:20).
The inclusion of biodiversity in the global environmental agenda means that the term is not only
scientific but also political in nature, intrinsically linked to conservation and concerns over the
loss of the natural environment (Gaston and Spicer, 2004; Ladle, 2009). The close association
between biodiversity and nature conservation means that biodiversity is connected to concepts
such as sustainable use, ideas around limits to growth, and resource consumption (Sanders,
2012).
Biodiversity is considered a cornerstone of healthy ecosystems (Kremen, 2005, Duffy et al., 2007,
Hector and Bagchi, 2007). The loss of biodiversity, due to human actions, has the potential to
27
reduce multi-trophic-level interactions (Costanza et al., 1997 and Schneiders et al., 2012), and
cause trophic cascade repercussions (Lindberg et al., 1998, and Tylianakis et al., 2008).
Therefore, biodiversity loss is a critical scientific concern for ecologists. The value of biodiversity
is not solely scientific, and also understood differently by different people, depending on their
experiences, their background and their systems of value. The most obvious distinction between
these different kinds of value of biodiversity is between the intrinsic and instrumental
perspectives.
Box 2.1 Perspectives on the Intrinsic Value of Biodiversity
Environmental ethicists stress that biodiversity has intrinsic value:
“Species have value in themselves, a value neither conferred nor revocable, but
springing from a species’ long evolutionary heritage and potential” (Soule,
1985:731).
The intrinsic value of biodiversity is related to the idea that all life warrants respect because it is
the unique result of approximately 3.5 billion years of life on earth, independent from human
design and control (Katz 1992). By destroying biodiversity we are interfering with the un-
replicable outcomes of multi-million years of evolution. Based on this perceptive, biodiversity is
valued for what it is rather than what it can bring about, its subjective intrinsic value (Sanders,
2012; see also Box 2.1). The intrinsic value of biodiversity means that it can be considered an
ethical or moral entity, and its conservation a social goal (Gustafsson, 2013). Therefore, humans,
as a part of nature, have a moral imperative to conserve biodiversity (Leakey and Lewein, 1995;
Roughgarden, 1995), a position embodied by command and control legalisation such as the
Endangered Species Act (Armsworth et al., 2004). Under this paradigm, the prevention of
biodiversity loss is an ethical assertion (see Box 2.1), something that ought to be done (Ravan
and McNeely, 1998).
Alongside intrinsic value, biodiversity is also considered important for its instrumental value, the
value that humans attribute to an object or idea based on a perception of how that object or
idea can be of use to them (e.g. Justus et al., 2008). Under the instrumental value paradigm
biodiversity is valuable as a resource that generates provide food, profit, medicine or provides
inspiring scenery for us to enjoy. Instrumental values link the loss of biodiversity into hunger,
poverty, disaster and human suffering. These values are discovered by human valuers but are
“A thing is right when it tends to preserve the integrity, stability and beauty of the biotic community.
It is wrong when it tends otherwise” (Leopold, 1949, A Sand Country Almac - 189).
"The non-humanistic value of communities and species is the simplest of all to state: they should be
conserved because they exist and because this existence is itself but the present expression of a
continuing historical process of immense antiquity and majesty. Long standing existence in Nature is
deemed to carry with it the unimpeachable right to continued existence" (Ehrenfeld, 1972, Conserving
Life on Earth).
"99 percent of all species that ever lived are now extinct. But I think we have an obligation, now, in
our generation and in foreseeable generations, to try to protect every species, try to maintain every
species, because virtually every species that is going extinct now is going extinct due to human
activity not because of natural processes" (Noss, 1996, Conservation Biology).
28
not created by them. Both Daily (1997) and Costanza and Daly (1992) identify biodiversity as a
generator of ecosystem services and benefits for society, which often cannot be replicated by
human technology. This utilitarian perspective often aims to quantify the impact of a change in
biodiversity value on our economy or human welfare, using monetary valuation tools such as
total economic value (Figure 2.2). Economists have even expressed biodiversity as life insurance
for life itself (McNeil and Shei, 2002). This instrumental perspective highlights the value of
biodiversity as a resource for society, as well as an ethical or moral factor, a perspective
embraced by the contemporary discourses of sustainable development and ecological
modernisation (Gustafsson, 2013).
Evidently, biodiversity has multiple forms of value and different motivations and arguments can
be used to defend and emphasise the need for conservation. Although it is not a case of either-
or for these different value frames, their interaction has generated controversy. Particularly,
proponents of intrinsic value argument perceive instrumental values as undermining their
position (Norton, 2000). Fundamentally, arguments around the importance of biodiversity
stress the need for a solution to the problem of biodiversity loss, and presenting the
conservation of global biodiversity is a key challenge for the 21st century. However, there is still
considerable debate about the most appropriate response(s) to the current biodiversity crisis.
Figure 2.2 Total Economic Value of Ecosystem Conservation (Pagiola et al, 2004)
2.3 Strategies for the Conservation and Mitigation of Biodiversity Losses
“The mainstream response to the loss of biodiversity promoted by conservation
groups and adopted by governments has been the establishment of protected
areas. Today there are over 100,000 protected areas that cover approximately 12%
of the earth’s land areas” (Lele et al., 2010:94).
29
Historically, biodiversity conservation has focused on a protectionist agenda, seeking to reduce
biodiversity loss by reserving places for nature through sanctuaries, national parks, nature
reserves and concerted efforts at the preservation of a single species (Adams, 2004; Hutton et
al., 2005; Lele et al., 2010). Spatial and land use planning has been used to create protected
areas (e.g. National Parks, Sites of Special Scientific Interest), and certain species protected
through the development of laws, regulations, and lists (e.g. European Protected Species or the
IUCN Red List). This approach to countering biodiversity loss is often referred to as the
‘protectionist tradition', ‘fortress conservation’, or ‘fences and fines approach’ (Brockington et
al., 2002; Neumann, 1998), and generally, focuses on in situ preservation of existing biodiversity.
Fortress conservation is linked to the idea that society should protect a sufficient sample of each
of the world’s ecosystems to guarantee the widest possible variety of life to be enjoyed by future
generations (Jenkins and Joppa, 2009). Therefore, areas such as national parks are thought of as
reservoirs of biodiversity.
Protected areas are now estimated to cover approximately 12% of the earth’s terrestrial surface
(Lele et al. 2010). However, the rate of protected areas creation has slowed from a peak in the
1970s and 80s, while global economic development continues to rise (Ladle, 2009). In a world
of increasingly scarce resources setting aside areas for conservation is a highly contentious and
complex process (Shaffer et al., 2002), and biodiversity continues to be eroded despite a raft of
protective legislation (Burgin, 2008). Gaston and Spicer (2004) identify four major issues with
the protectionist approach: the overall conservation network is too small, land used for
conservation is often biased towards land of low economic value, the current protected area
network has been conceived along static lines rather than ecological networks, and protected
areas represent isolated populations vulnerable to environmental change. Armsworth et al.
(2004:131) condemn protected areas as:
“Islands within heavily modified and fragmented landscapes and seascapes, where
conservation is highly constrained, and reserves are typically small and isolated.”
Therefore, protected areas are a key feature of the conservation agenda; however, they are
increasingly criticised as ‘museum approaches’ rather than an adaptive long-term solution to the
biodiversity crisis.
The 1960s and 70s saw a growing social awareness of the environmental issues caused by
developments, and a move towards a precautionary as well as protectionist approach. A series
of high-profile environmental disasters and the publication of Rachel Carson’s Silent Spring
(1962) sparked a growing environmental movement in the 1970’s. The sustained concentration
of public concern around eco-centric issues resulted in the National Environmental Policy Act
(1969) in the US, a push towards greener decision-making.
“…for major Federal actions significantly affecting the quality of the human
environment, a detailed statement on: (i) environmental impact of proposed action
(ii) any adverse environmental effects which cannot be avoided (iii) alternatives to
the proposed action (iv) relationship between local short-term uses of man’s
environment and maintenance and enhancement of long-term productivity (v) any
irreversible and irretrievable commitments of resources involved in the proposed
action”.
30
NEPA led to the development of Environmental Impact Assessment, commonly referred to as
EIA, an anticipatory environmental planning, and decision-making tool. EIA is applied at the
project level to establish the potential environmental effects of major developments (Glasson
et al., 2012). From this first requirement, the EIA process has subsequently been developed as a
means of assessing environmental impacts worldwide and has been adapted into a wide variety
of different jurisdictions and institutional contexts and spawned a raft of similar instruments
such as Health Impact Assessment and Social Impact Assessment (Wood, 2003).
The global uptake of EIA widened the remit of environmental conservation and provided an
added policy tool to identify and evidence biodiversity loss. However, continued reports of
biodiversity decline, and a growing perception that protected areas are an essential and core
aspect of biodiversity conservation strategies but not sufficient to alone halt biodiversity loss,
brought about a more substantive shift in conservation thinking in the 1990s (Margules and
Pressey, 2000; McNelley, et al., 1990). This shift was driven by the rise of sustainable
development, which promoted the idea that economic, environmental and social goals are
compatible and advocates win-win-win solutions to ensure conservation and sustainable use of
biodiveristy alongside achieve social and economic development (Redford and Richer, 1999;
Robinson, 1992). In addition, the focus on ecological modernisation which challenged regulation
as the primary response to environmental issues, and the protectionist agenda, instead
suggesting that environmental issues can be alleviated through technology, environmental
restoration, managerial ingenuity and market forces (MacDonald, 2010). Over the past few
decades, these two concepts have shaped what Brown (2002:403) refers to as a “major
paradigm shift in conservation, resulting in what some researchers refer to as ‘new
conservation’”.
This shift is characterised by Hulme and Murplee (1999) as a change in perspective on three core
issues. Firstly, conservation and ecology have moved from the position that conservation should
exclude people, to community-led conservation schemes and a focus on socio-ecological
connections (e.g. Ghimire and Pimbert, 1997). Secondly, conservation strategies are increasingly
adopting a contemporary understanding of ecology and landscape ecology, and incorporating
ideas around ecological networks, ecosystem functions, and relationships (e.g. Margules and
Pressey, 2000; Redford et al., 2003). Through this perspective, there is now a much greater
appreciation of common biodiversity, rather than just charsmatic or endangered biodiversity
and ecosystems. Furthermore, that biodiversity loss is being driven not just by large scale
individual impacts but by the cumulative effects of individually innocuous impacts (Laurence,
2010; Treweek et al., 1998; Wilding and Raemaker, 2000). A move which was mainstreamed by
the uptake of the ecosystems approaches as the primary framework for action under the
Convention on Biological Diversity (COP fifth meeting Decision V/6). Thirdly, there is a new
alliance between conservation and capitalism after decades of their separation, a
reconfiguration of their relationship from incompatible into win-win scenarios (MacDonald,
2010; Igoe, 2010).
“In the context of implementing these biodiversity-related conventions, the use of
economic instruments has expanded significantly over the last years. This reflects a
growing understanding that economic instruments can increase the efficiency and
31
cost-effectiveness of environmental management, create incentives for investment
and generate financial resources for preserving biodiversity” (UNEP, 2004:1).
This shift in perspective resulted in a drive towards market-based solutions to biodiversity
issues.
This bringing together of business and biodiversity, often referred to as the neoliberalisation of
conservation, has promoted the concept of green developments, and market solutions to
biodiversity loss. Although ‘fortress conservation’ is heavily criticised, new conservation is
equally controversial (Igoe et al., 2010; MacDonald, 2010; Busher and Whande, 2007;
Brockington and Duffy, 2010). This paradigm shift in conservation has resulted in a variety of
new conservation strategies. Conservation is now pursued through taxes, education, farming,
and rural stewardship schemes, debt-for-nature swaps, eco-tourism, certificating and marketing
(Gaston and Spicer, 2003). Among these new approaches, the new alliance between business
and biodiversity has led to the promotion of biodiversity offsetting as a mechanism to help
achieve the aspiration of no net loss of biodiversity. Since its adoption into the international
sphere of biodiversity conservation in 2004, the term ‘biodiversity offsetting’ has seen a huge
increase in popularity over the last decade (Madsen et al., 2010, 2011) and become a widely
used label (Lapeyre et al., 2014; Coralie et al., 2015). Coralie et al. (2015) suggest that the term
has become a buzzword and finds that 283 papers have been written on the topic between
2007-2014, while Madsen et al. (2011) highlights that there are some 39 schemes classified as
‘biodiversity offsetting’ and there are another 25 in various stages of development.
Graph 2.2 Biodiversity offsetting programmes worldwide by decade of creation (Ferreira, 2014)
2.4 The Rise of Biodiversity Offsetting
2.4.1 Biodiversity Offsets as a Strategy to Halt Biodiversity Loss
The term biodiversity offsetting has multiple definitions (see Box. 2.2). This section provides a
broad sense of what undertaking offsetting entails, its theoretical foundations, adjoining
32
concepts and origins. Biodiversity offsetting, also referred to as mitigation banking, conservation
banking, environmental compensation, compensation pools, conservation credits, was
predominantly born out of practice rather than scientific enhancement. One of the most widely
used definitions of biodiversity offsets is by the Business and Biodiversity Offset Program’s
(BBOP), a coalition of organisations who have promoted offsets as part of the international
conservation agenda.
“Measurable conservation outcomes resulting from actions designed to
compensate for significant residual adverse biodiversity impacts arising from
project development after appropriate prevention and mitigation measures have
been taken. The goal of biodiversity offsets is to achieve no net loss and preferably
a net gain of biodiversity on the ground with respect to species composition, habitat
structure and ecosystem function and people’s use and cultural values associated
with biodiversity” (BBOP, 2012c:5)
BBOP are an offshoot of the Forest Trends, a not for profit organisation who promote market-
based approaches to forest conservation. In the context of declining biodiversity levels,
worldwide, biodiversity offsets are conceptualised as a mechanism to try to balance
development and conservation by creating restored habitat in one place to compensate for
losses in another. The central tenant of offsetting is the aspiration to achieve no net loss of
biodiversity (hereafter no net loss). The inclusion of no net loss is based on the premises that
further loss of biodiversity is unacceptable (CBD, 2010), and therefore, biodiversity must be
conserved at its current level. By placing no net loss as the cornerstone of biodiversity offsetting,
any new development that disrupts biodiversity must be offset by conservation action[s] which
provide equivalent gains in biodiversity (ten Kate, 2004). Therefore, a core aspect of offsets is
about swaps or trade-offs, exchanging environmental losses for restoration gains to achieve an
overall aspiration of no net loss of biodiversity.
In order to ensure comparability or equivalence between losses and gains in biodiversity, the
production of measurable biodiversity gains is a key component of definitions of biodiversity
offsets (Box 2.2). Consequently, the process of offsetting is often associated with the
quantification of biodiversity value to ensure measurability. Quantification of the value of
biodiversity lost and gained is achieved through calculative devices which are referred to as
offsetting metrics, or biodiversity proxies, which provide an estimate or surrogate of the value
of biodiversity at a site (ten Kate et al., 2004; BBOP, 2012a). A key component of offsetting is,
therefore, the valuation of biodiveristy through the use of calculative technologies. Finally, there
is also a sense in the definitions outlined in Box 2.2, that offsets are designed to go beyond the
current status quo and account for ‘residual adverse impacts’ which would otherwise be
considered inevitable impacts (Hayes and Morrison-Saunders, 2007). Offsets are, therefore,
often referred to as an additional positive or beneficial aspect. This feature of biodiversity offsets
also mean that offsets are extra step in relation to the mitigation hierarchy, an established
framework of best practice for tackling biodiversity impacts (see Figure 2.3 on page 24).
Therefore, biodiversity offsets are a type of compensation activity which aims to achieve no net
loss and preferably a net biodiversity gain on the ground, by quantifying biodiversity losses and
gains, and provides a mechanism through which compensation for environmental losses can be
achieved off-site.
33
Box 2.2 Definitions of Biodiversity Offsets
Definitions of biodiversity offsets from literature and guidance
Business and Biodiversity Offsets Program (2012b:5):
“Measurable conservation outcomes resulting from actions designed to
compensate for significant residual adverse biodiversity impacts arising from
project development after appropriate prevention and mitigation measures
have been taken. The goal of biodiversity offsets is to achieve no net loss and
preferably a net gain of biodiversity on the ground with respect to species
composition, habitat structure and ecosystem function and people’s use and
cultural values associated with biodiversity”.
Curran et al. (2014:617)
“Biodiversity offsets are seen as a policy mechanism to balance development
and conservation goals. Many offset schemes employ habitat restoration in one
area to recreate biodiversity value that is destroyed elsewhere”.
Ten Kate et al. (2004:13)
“Conservation actions intended to compensate for the residual, unavoidable harm to biodiversity caused by development projects, so as to ensure no net loss of biodiversity”.
Bull et al. (2013:370)
“Offsets are commonly viewed as actions to create additional and/or
comparable biodiversity gains to compensate for losses caused by
development”.
Treweek and ten Kate (2014:1)
“Offsets mitigate for residual impacts that would otherwise be accepted as an
inevitable consequence”.
Gardner et al. (2013:1255)
“Biodiversity offset go beyond traditional environment-impact mitigation
measures and help relieve tension between conservation and development by
enabling economic gains to be achieved without concomitant biodiversity
losses”.
Hill (2013:10)
“Essentially biodiversity offsets are conservation activities design to deliver
biodiversity benefits in one place to compensate for losses in another in a
measurable way”.
34
Figure 2.3 Biodiversity Offsetting as Part of the Mitigation Hierarchy (Flora and Fauna
International)
2.4.2 Biodiversity Offsets vs. Environmental Compensation
The origins of the concept of offsetting are largely attributed to the US wetland mitigation
banking schemes developed in the 1970s. Mitigation banking schemes, also referred to as
compensation pools or conservation banking, are a collective form of offsetting where offsets
are developed prior to developer demand, in the form of mitigation banks or large parcels of
restored habitats, and can be purchased ‘off the shelf’ by developers as and when they are
required. From these US origins offsetting is considered to have subsequently spread worldwide,
uploaded into the international conservation sphere from the US model (Maron et al., 2016;
Madsen et al. 2011; Marsh et al., 1996). Offsets have been promoted by organisations such as
the Business and Biodiversity Offset Partnership who developed a series of voluntary offsets
with industry partners and wider national uptake of offsetting schemes (ten Kate et al, 2004;
BBOP 2009b). Other early variations of offsetting include the German Impact Mitigation
Regulation after Nature Conservation Act in 1976, which is the major landscape conservation
instrument to address mitigation and compensation for impacts from developments and
projects in Germany (Wende et al. 2005). Offsets are often closely connected to the concept of
environmental compensation which again has much origins in the US, in early attempts at
environmental restoration of forests and prairies in the 1930s (Cowell, 1997; Rundcrantz and
Skärbäck, 2003).
Broadly the concept of compensation is based on the notion that an individual is willing to trade-
off different amounts of goods without it affecting his/her overall sense of wellbeing (Johnasson,
1991). The idea of compensation has traditionally been interpreted as monetary. Environmental
compensation is, specifically, linked to ideas about environmental liabilities, and the polluter
pays principle (Cowell, 1996). Compensation would require action to be taken where the
environment runs the risk of being degraded environmental, to ensure that the accountable
35
person bears the costs of restoring the damage (Gillespie, 2012). Both Anderson (1995) and
Wyant et al. (1995) highlight that the term environmental compensation is not fundamentally
different from either ecological restoration or habitat creation, except that it is specifically
employed to counterbalance individual adverse impacts on the environment due to
development. Environmental compensation is also linked to the economic paradigm of
sustainable development which focuses on the maintenance of overall levels of natural, social
and economic capital stocks (Cowell, 1997). Therefore, ecological compensation is strongly
associated with sustainable development, ecological restoration and the re-assembling of
ecosystems.
However, the exact relationship between compensation, mitigation and offsets is often unclear,
as theses terms are used interchangeably:
“The international literature on environmental compensation uses near-synonymous
terms, including ‘offset', ‘compensatory mitigation’ and ‘remedy.' The number of
definitions of the concept almost equals the number of authors discussing the
subject” (Persson, 2013:611-612).
In North America biodiversity offsets are usually referred to as ‘mitigation’ while in Europe and
Australia the same process commonly referred to as ‘compensation’ (Marsh et al., 1996; Darbi
et al., 2009; Treweek et al., 2009). In France ‘compensation’ and ‘biodiversity offsetting’ are
considered to be one and the same. This indicates considerable confusion surrounding which
measure has been applied, mitigation, compensation or offsetting, and disconnection across
international practice. It is, therefore, useful to make some clear distinction between the terms
mitigation, compensation, and offsets.
Environmental compensation is generally introduced as a strategy to:
“Provide positive environmental measures to correct, balance or otherwise atone
for the loss of environmental resources” (Cowell, 2000:690).
Although, mitigation and compensation both attempt to neutralize environmental impacts, the
term mitigation is more specifically undersood as a measure used to reduce or ameliorate an
impact (Glasson et al., 2012; Marshall 2001; Cowell, 1996). Whereas, compensation implies the
possibility of creating equivalent environments to counterbalance or atone for an impact that
cannot be mitigated (Glasson et al., 2012; Cowell, 2000). The relationship between
compensation, mitigation and the source-receptor pathway is used to emphasise this distinction
in Figure 2.4. Moving on to look at the distinction between compensation and offsets, BBOP
(2012b) and Dickie et al. (2012) highlight that compensation is a much less specific term than
offsets, as compensation can involve recompense that falls short of achieving no net loss. The
no net loss feature of biodiversity offsetting denotes the quantification of impacts and requires
offset in accordance to a series of rules and standards to achieve no net loss of biodiversity
(Gillespie, 2012). Therefore, BBOP argues that biodiversity offsets relate more directly to the
biodiversity value affected, while environmental compensation represents a more general
compensatory benefit. Compensation can be achieved through a range of different measures
but does not necessarily seek to achieve no net loss (ten Kate et al., 2004). Arguably through
biodiversity offsetting, environmental compensation moves from a broad approach into a more
36
formalised tool, as offsetting specifies the exact dimension through which environmental
compensation should be applied to the impacts of a development proposal.
Figure 2.4 The Source-Receptor-Pathway and the Distinction between Mitigation and
Compensation
2.4.3 Biodiversity Offsets as a Market Based Instrument
Biodiversity offsetting is referred to as a ‘policy tool’ or ‘policy innovation’, but most widely
classified in the literature as a ‘market-based instrument or MBI’ or innovative financial
mechanism to fund biodiversity conservation through private sector incentives (e.g. ten Kate et
al., 2004; Bräuer et al., 2006, Fischer et al, 2012; cf. Coralie et al. 2015, Boisvert et al., 2013).
Before the rise of biodiversity offsetting, Hrabankski (2015) highlights that ecological
compensation mechanisms were not conceptualised as economic instruments and that the
market label is very much associated with biodiversity offsetting. Offsets are considered an MBI
as they broadly operate through a credit-debit system, swapping biodiversity losses or debits for
biodiversity gains or credits (eftec et al., 2010; Parker and Cranford, 2010; See Figure 2.5).
Biodiversity credits represent property rights to gains from conservation actions, and therefore
biodiversity conservation efforts effectively become a commodity which can be bought and sold
(ten Kate and Crowe, 2010). This approach is also referred to as a tradable permit approach, as
developers wishing to develop land may do so only if they obtain a permit from the statutory
agency or authority showing that they have generated equivalent gains (credits) elsewhere
(Wissel and Wätzold, 2010).
Offsetting systems require a metric to quantify biodiversity and enable a single transferable
value to be placed on losses and gains of biodiversity in different locations, thereby ensuring
Impact
Source
Impact
Receptor Pathway
Impact
Source
Impact
Receptor Pathway
Mitigation
Impact
Source
Impact
Receptor Pathway
Compensation
+ Replace-
ment
Receptor
37
equivalence (or commensurability) can be established and enable biodiversity swaps (Salzman
and Ruhl 2000; Walker et al., 2009). Through tradable offset permits, Wizzel and Wätzold (2010)
highlight that the developer does not need to carry out the restoration work, but can instead
purchase credits from a third party restorer or land owner which enables market dynamics to
emerge. Therefore, the idea behind offsets is the use of market incentives to maintain overall
levels of ‘natural’ capital stocks. In addition, by quantifying biodiversity, offsetting metrics are
also linked to arguments that through assigning a value to nature this will highlight its economic
value for decision-makers and business, and arguably further incentivise conservation (Costanza
et al, 1997).
Figure 2.5 General Model of the Biodiversity Offsetting Credit-Debit System (Rajvanshi and
Mathur, 2008)
The market potential of offsetting has, in some offsetting systems (i.e. the US and Australia), led
to the development of habitat banking or compensation pools, where land owners or offset
bankers pre-emptively produce a credit supply which developers can then purchase ‘off-the-
shelf’. However, under the umbrella term ‘biodiversity offsetting’ there are a variety of different
‘types’ of offsets with different governance arrangements, and different levels of state
involvement, some mandatory other voluntary, some heavily state-influenced, some part of
habitat pools or banks and some one-off (see Box 2.3). Consequently, the classification and
grouping of these wide range schemes as market-based instruments has recently come under
scrutiny:
“Far from confirming the existence of a single unified category of so-called Market
Based Instruments grouped under the umbrella label of ‘biodiversity compensation’
articles presented in this special issue rather display heterogeneity in practical
institutional arrangements designed to govern and implement biodiversity offsets”
(Lapeyre et al., 2015:130).
Both Vassiere and Leverel (2015), and Lapeyre et al. (2015) emphasise that schemes labelled as
biodiversity offsetting encompass a range of different contexts, drivers, economic realities,
ecosystems, scales, and are promoted by different actors and individuals. The two publications
suggest that variability in the institutional arrangements to govern and implement offsets is “the
rule rather than the exception” (Lapeyre et al., 2015). Not only is there an increasing appreciation
Approval
Local
Planning
Authority
Development E.g. Residual
impacts result in 30
acre of damage
woodland
Biodiversity
Offset E.g. 50 acres
restored Credit
£
Permit
38
of the divergence between biodiversity offsetting schemes, but also suggestion that offsetting
schemes often do not share features of economic mechanisms and classic market-based
instruments (Hackett, 2015; Boisvert et al., 2013; Coralie et al., 2015). Hackett (2015) suggests
that this disconnection means that there has been an overt focus on a few elements of ideal
offsetting typologies. While Lapeyre et al. (2015) find that there is a need to understand the
heterogeneity within each offsetting scheme, to try and disentangle its institutional and
economic characteristics as well as relations to market mechanisms.
Table 2.1 International Biodiversity Offsetting Schemes (OECD, 2014)
2.4.4 The Promises of Biodiversity Offsetting
In promoting biodiversity offsetting a wide range of potential benefits have been identified for
industry, government, and conservation groups alike (ten Kate et al., 2004). For the conservation
agenda, offsetting promises to allay the acceleration of biodiversity loss by attempting to
maintain a position of no net loss of biodiversity, and therefore improve biodiversity outcomes
compared to business-as-usual (Fox and Nino-Murcia 2005) (Figure 2.6). By linking conservation
into the private sector, biodiversity offsetting is thought to be a means to foster new sources of
funding and incentives for conservation (Boisvert et al., 2015; ten Kate et al., 2004; Calvert et
al., 2015). Furthermore, by moving off-site, and, therefore, away from piecemeal in situ
39
biodiversity conservation, Latimer and Hill (2007) suggest that offsetting can generate smarter
mitigation by linking offsets into landscape scale conservation aspiration and restoration of
ecological networks (Figure 2.7). Particularly, the pooling of offsets together to create larger
compensation sites, through mitigation/compensation banking, is thought to be a means to
provide more stable nature reserves for biodiversity which are less vulnerable to disturbance
effects and fragmentation, and an opportunity to link site based mitigation with large-scale
landscape restoration aspirations (Kiescker et al., 2009). Furthermore, by incorporating
biodiversity accounting within the development planning process, offsetting also promises to
better balance the competing demands of development and compensation (Bull et al., 2013;
Bekessey et al., 2010). The potential of offsets to reconcile the agendas of conservation and
development means that offsetting mechanisms are highly conceptual attractive approaches
(Bekessey et al, 2010).
Figure 2.6 Biodiversity Offsets as a Tool for No Net Loss (Bull et al., 2013)
Many of the perceived benefits of adopting biodiversity offsetting are also wrapped up in its
conceptualisation as a market-based instrument:
“Over the last two decades, environmental policies have increasingly used economic
incentives for biodiversity conservation as more efficient ways of achieving
conservation outcomes than traditional approaches. Seen as a way to provide
40
economic incentives, the concept of biodiversity offsetting has recently enjoyed
renewed political interest, and is endorsed in many political agendas” (Calvert et al.
2015:7358).
Biodiversity offsetting is lauded as potentially more economically efficient than existing
approaches used by developers (ten Kate et al., 2004; Marsh, 1996; Bayon et al, 2012). The
option to use a third party provides an opportunity for the developer to shed responsibility for
delivering compensation. Moreover, through habitat banking, the economies of scale achieved
through offsetting could result in reduced management costs (ten Kate et al., 2004; Bayon et al.,
2012). Furthermore, the use of a measured approach is thought to be a means to provide clarity
around compensation requirements and reduce the need for negotiation, leading to a clearer
path to implementation and more precision on the possible costs for financial planning.
Effectively offsetting is seen as a means to streamline current compensation practice, so that it
is more cost effective and efficient for developers (Apostolopolou and Adams, 2015). Offsetting
also presents a route for rural diversification and new funding streams for land managers.
Finally, offsets provide government regulators with the opportunity to encourage companies to
make significant contributions to conservation, particularly when legislation does not require
mandatory offsets. Sukhdev (2011) also highlights that valuing and quantify biodiversity should
help to raise the profile of biodiversity, providing an opportunity for businesses to better
understand, and therefore manage, the costs and benefits of biodiversity loss.
Figure 2.7 The Landscape Ecology Benefits of Biodiversity Offsetting (Environment Bank, 2016)
2.4.5 Summary: Biodiversity Offsets as Part of the Solution to the Biodiversity Crisis
The wide range of prospective benefits means that offsetting is considered by many to be:
“One of the pieces of the puzzle in which the environmental crisis and economic
growth can be reconciled, to the benefit of both” (Gillespie, 2012:2).
41
As discussed in section 2.3, offsets are increasingly being employed on an international scale,
and a wide range of governments, organisations, corporations and academics, worldwide, are
exploring the possibility of implementing a system of biodiversity offsetting. Broadly, offsets are
lauded for their potential to help account for the cumulative and incremental loss of biodiversity,
enable landscape scale conservation and smarter mitigation, provide new funding streams for
conservation and work as a more efficient means to account for biodiversity damage for
developers. However:
“Although offsets may sound like a win for conservation, views on biodiversity
offsetting as a conservation approach range widely, from outright rejection (Walker
et al. 2009, Spash and Aslaksen 2015) to qualified acceptance (Gardner et al. 2013),
with scepticism and resistance also prominent in civil society discourse (FOEE 2014)”
(Maron et al. 2016:1).
Despite growing interest in the application of offsetting, the concept and approach also raises a
range of scientific, social, political, legal and economic questions, to which there are no easy
answers (Rajvanshi and Mathur, 2009). Frequently, recognition of the potential for offsets is
stated alongside acknowledgment that there is also widespread concern about the conceptual
aspirations and potential effectiveness of biodiversity offsets.
2.5 The Contested Nature of Biodiversity Offsetting
2.5.1 Questioning the Performance of Biodiversity Offsets
Studies of the performance of offsets for biodiversity have also produced relatively mixed
reviews in terms of general instrumental effectiveness (Strange et al., 2002; Gibbons and
Lindenmayer 2007; NRC 2001; Matthews and Endress 2008; Robertson, 2006; Quigley and
Harper 2005; Mack and Micacchion 2006; Burgin, 2008; Race and Fonseca, 1996). Although
there are also some positives reviews of offsetting systems (e.g., Atkinson et al., 2002), according
to Quigley and Harper (2006) the current application of offsets are at best slowing down not
halting the rate of habitat loss. Therefore, biodiversity offsets, and more broadly, environmental
compensation, have been linked to a historic failure to achieve their objectives. For some
researchers, this raises concerns around offset design and implementation and the technical
effectiveness of biodiversity offsets ability to achieve no net loss. However, other studies make
more fundamental objections to the conceptual foundations and ethics of offsetting (e.g. Walker
et al., 2009; Robertson, 2004, 2006; Maron et al., 2012; 2015). Criticisms of ethical
appropriateness and technical effectiveness of offsets are concentrated around two key
features of offsetting, its links to ecological restoration and ecological valuation. These
conceptual and instrumental criticisms of offsetting are further added to by concerns around
how offsetting, and the aspiration of no net loss, will influence decision-making around
biodiversity impact and damage (Walker et al., 2009).
2.5.2 Biodiversity Offsets and Ecological Restoration Realities
“Restoration is rudimentary as best, criminally inept, at worst” (Race and Fonesca,
1996:5)
The central aspiration of biodiversity offsetting, the achievement of no net loss of biodiversity,
is based on the premise that environmental restoraton specialists are able to restore or recreate
42
ecosystems to the point that they contain equivalent biodiversity values to those which are lost
(Maron et al., 2012; Cowell, 1997; Robertson, 2004, 2006).
“In a sense, environmental compensation is on the fulcrum between present
patterns of economic growth [weak sustainability] and environmental limits [strong
sustainability], and the extent to which environmental functions can be adequately
replaced or compensated for is, therefore, a pivotal concern” (Cowell, 1996:13).
No net loss places substantial confidence in the ability of restoration to recover lost biodiversity.
This confidence is based on the assumption that capital is abundant and substitutable in
neoclassical economics and therefore can be run down as long as human capital is used to
replicate lost natural capital (Cowell, 1996). The evidence that this will actually occur is,
however, sparse:
“A survey of 87 restoration projects showed that 17 were unsuccessful, 53 were
partially successful and only 17 were successful” (Lockwood and Pimm, 1999:373).
The success of many restoration schemes remains up for debate. For some researchers’ issues
with restoration are due to issues with the three main technical factors (1) complexity of
ecosystems, (2) our inability to fully measure biodiversity on site, and (3) the timescales for
ecological restoration. These three factors mean that the success of ecological restoration is by
no means assured (Hildebrand et al. 2005; Zedler et al., 2007; Lockwood and Pimm, 1999; Pickett
et al. 2013, Maron et al., 2012). A lack of monitoring and follow-up studies on environmental
restoration projects also means that a clear picture of the success of environmental restoration
is unavailable. There is a clear concern about whether we can produce structurally or
functionally equivalent sites to account for losses (Lockwood and Pimm, 1999, Maron et al.,
2010; Hildebrand et al., 2005). Consequently, through offsets, we could be exchanging certain
losses for uncertain restoration gains (Maron et al., 2012; Walker et al., 2009), and we may need
to re-evaluate the aspiration to achieve no net loss to reflect the realities of what restoration
can achieve (Hildebrand et al., 2005).
These criticisms of environmental restoration have led some to a perception that biodiversity
offsetting mechanisms could simply act to facilitate environmental degradation (Quigley and
Harper, 2005; Walker et al., 2009). More seriously, Maron et al. (2012) stress that the idea that
we can restore complex natural systems is technological arrogance. Whilst on an ethical basis,
Katz (1992) highlights that rather than enshrining nature and environment protection, through
restoration we are instead portraying nature as replicable and interchangeable and thereby
depleting its intrinsic value. Moreover, the fundamental idea behind swapping losses for gains
is often considered to be flawed, based on the idea that we cannot simply cancel out harm by
doing good. These complaints have led to criticisms of no net loss of biodiversity as illusionary
goal, a hollow promise or symbolic policy (Robertson, 2002; Walker et al., 2009).
However, it must also be acknowledged that Zedler and Callway (1999) point out that success
or failure is hardly ever a black and white concept. Furthermore, restorers accept that
restoration often does not go as well as planned, and are increasingly identifying some causes
of restoration failures: such as ad hoc approaches, lack of criteria, lack of understanding of socio-
economic and political constraints (Choi et al., 2001). The ecological community has long
recognised that recreating or restoring ecosystems to some specified former state is often
43
unlikely to be feasible (Hobbs et al., 2011). A more positive opinion of environmental restoration
is given by Middle and Middle (2010) who stressed that despite these deficiencies the
opportunities of environmental restoration are potentially significant, and do not detract from
its potential as a useful management approach. A perspective supported by Young (2000) who
similarly notes that even though restoration can be misused this does not detract from its
significant potential. A review of the North American Wetland Mitigation Banking system by the
Natural Research Council in 2001 (NRC, 2001) found that although offsetting projects have not
always satisfied the basic goal of restoring and maintaining the quality and quantity of the
country’s wetlands, the adoption of no net loss has reversed the post-war trend of continued
wetland loss in the US. However, environmental restoration is not the only aspect of offsetting
which suffers from complaints about technical effectiveness and questionable ethics.
2.5.3 Biodiversity Offsets and Valuation Controversies
The substitution of development impacts and offset restoration gains requires the measurement
of biodiversity values to establish an overall transferable biodiversity value or currency (ten Kate
et al., 2004; BBOP, 2012b). However, the inherent complexity of biodiversity, as a
heterogeneous resource, means that measurement is a longstanding challenge in biodiversity
offsetting.
“Biodiversity is a hierarchy with levels of organisation from genes to ecosystems and
has an extraordinary number of elements at each level which vary in time and space,
and diverse interactions both within and between levels” (Walker et al., 2009:150).
The measurement of biodiversity is not a simple task of counting but also requires an
appreciation of ecological functions, relationships, and interactions. Consequently, biodiversity
in its entirety is generally considered nigh impossible to measure and, therefore, offsetting
schemes have adopted various metrics to provide proxy measures or estimates of overall
biodiversity value lost and gained, dominated by habitats-based or species based approaches
(see Table 2.2). The use of offsetting metrics is thought to enable robust and transparent
accounting of losses and gains, and therefore demonstrate ecological equivalence and the
achievement of no net loss (BBOP, 2012b). In adopting a metric, offsetting systems are therefore
attempting to convert dynamic relationships and networks into a static body
Table 2.2 Biodiversity Offsetting Metrics and Currencies (summarised from Bull et al., 2014 and
Quentier and Lavorel, 2011)
Name Country Method
Wetland Mitigation Banking USA Area based approach (area * score)
Canadian Fish Habitat Canada Area*Functionality
Australian vegetation offsets Australia Area*Condition vs benchmark pristine
state
US Conservation Banking USA Area necessary to support a given
species population
Habitat Hectares Australia Native vegetation (43rea *score)
44
Ausgleich Germany Protected species and habitats (area
*habitat type)
Biotopwertverfahren Germany Undeveloped land (area* score)
Offset ratios France Protected species and habitats (area
*habitat type)
Defra Biodiversity offsetting
metric
UK Area*distinctiveness*condition
The valuation of biodiversity through offsetting metrics is one of the most important aspects of
offsetting systems, but also one of the most problematic (e.g. Rundcrantz and Skärbäck, 2003;
Bull et al., 2013; Quèntier and Lavorel, 2011; Gardner et al., 2013; Gonçalves et al., 2015).
Offsetting metrics have been discussed widely as a technical challenge in the academic literature
and emerging offsetting practice (Bull et al., 2014; Quèntier and Lavorel, 2011; ten Kate, 2004;
Parkes et al., 2003; Gardener et al., 2013; Gibbons and Lindenmayer, 2007; Kiesecker et al.,
2009). A whole host of different assessment methods, metrics and currency have been
developed to try to quantify biodiversity value and address policy requirements over the last 40
years (Bull et al., 2014; BBOP, 2012a; Table 2.2). Metrics range from measures of area or size to
particular ecological functions or structures, some include the presence of threatened species
populations, vegetation cover or habitat type (Maron et al., 2012; Temple et al., 2010). These
metrics can be best understood as pseudo-quantitative approaches as they often include scoring
or judgement based measures of condition or quality of habitat. The outputs of these metrics
are generally expressed as single figures and referred to as units of measures such as
‘biodiversity units’ or ‘conservation credits’. Fundamentally, the amount of different metrics
highlights the persistent problem of quantifying biodiversity, particularly that:
“There is no single, best way to measure losses or gains in biodiversity” (BBOP,
2012a:25).
The lack of consensus around metrics is attributed by Maron et al. (2012) as a result of the poor
definition and measurability of the values to be offset, whilst Salzman and Ruhl (2000:623)
acknowledge that there is simply no currency that adequately “captures what we care about”.
The valuation of biodiversity is not only technically very difficult but also ethically controversial.
O’Neill (1993) highlights that maintaining natural capital is a particularly problematic objective
because environments are repositories of plural and incommensurable values. Some of these
values are irreplaceable, for instance, cultural values where the meaning is derived from the
uninterrupted influence of natural and human creativities shaping landscapes over long periods
of time, or ‘naturalness’ itself (O’Neil, 1993):
“No net loss, cannot by definition, recognise or preserve the value of specific
relationships between human individuals and communities, their local landscapes
and their non-human neighbours” (Hannis and Sullivan, 2012:15).
Therefore, engaging with metrics almost always implies responding to only a certain set of
values but not others. Therefore, biodiversity offsetting metrics are placing a highly reductionist
approach on biodiversity value, considering only the biophysical rather than the socio-ecological
45
relationships and assuming that the most important yardstick of a resource is quantity
(Gasparatos, 2010).
Furthermore, researchers such as Robertson (2000) emphasise that converting multiple
biodiversity values into a single figure is effectively a form of commodification of nature. As a
calculative device, offsetting metrics are reconceptualising nature from something which has an
in situ intrinsic, embedded and unique value, into something which is mobile and transferable
(Robertson, 2000). Placing a single quantitative value on biodiversity, which can easily be linked
to a price, encourages the perception of nature as abstract from other socio-ecological
connections, a transferable resource for human use or investment. Therefore, metrics can
convert biodiversity into a fungible or liquid natural capital asset (Robertson, 2000, 2002, 2004,
2006; see also: Apostolopoulou and Adams, 2015; Sullivan, 2013; Walker, et al., 2009; Büscher
et al., 2014). The quantification of biodiversity may enable biodiversity to be integrated into
planning and business decision-making, however, Cowell (1997) indicates that in promoting a
calculative approach this reframes environmental issues as managerial and technical concerns
for the capitalist economic system, rather than moral or societal goals (Büscher et al., 2012). The
subject of environmental valuation is clearly a critical one. The current proliferation of valuation
and quantification schemes in conservation agendas suggests that quantification and
instrumental value is prevailing over intrinsic value.
2.5.4 Biodiversity Offsets as a Permit for Planning Permission
Issues with both environmental restoration and environmental valuation bring into question the
ethics and effectiveness of offsets, presenting offsets as a potential licence to trash biodiversity
rather than tools to achieve no net loss. In addition, the licence to trash label derives from the
potential of offsetting to produce perverse incentives around planning permission. In a study of
biodiversity offsetting, Walker et al. (2009) use political choice theory to predict that the
incorporation of biodiversity offsetting into decision-making is likely to result in offsets being
used as a permit for permission.
“Given the option of saying to developers “yes, with conditions” rather than “no,”
officials will prefer “yes, with conditions” […] particularly when compliance with
conditions cannot be credibly measured and officials can avoid accountability for
outcomes” (Walker et al., 2009:155).
Furthermore, Walker et al. (2009) argued that, rather than acting to reinforce existing
biodiversity protection, the option to trade losses for gains could instead provide an opportunity
to resist or relax existing safeguards. Effectively the presence of offsets in planning and decision-
making could generate increased environmental damage. In particular, issues of conflicting
incentives are linked to the relationship between biodiversity offsetting and the mitigation
hierarchy. Prevailing best practice for the treatment of biodiversity impacts suggests that
developers must focus first on avoiding impacts, before proceeding to considered mitigation and
finally compensation or offsets. There is concern that offsets, and the increased emphasis on
the end of the mitigation hierarchy, will increase incentives for regulators to ‘skip past
avoidance’ and proceed straight to compensation, as an easier option (Clare et al., 2011; Walker
et al., 2009).
46
Furthermore, politicians can appear to take action through the no net loss aspiration while
continuing to serve development interests, and ignoring or perhaps exacerbating biodiversity
loss (Walker et al., 2009).
“Such symbolic policies promise much but guarantee little, and allow the motivated
few to reap most of a policy’s benefits whilst leaving the disorganised many
unaware, or lulled into a political quiescence” (Walker et al., 2009:154).
No net loss is therefore described by Robertson (2000) as giving the rhetoric to the ecologists
and environmentalist, but the decisions to the developer, and thus diffusing potential opposition
by engaging ecologist collaboration in a symbolic but illusory goal.
2.5.5 Summary: Biodiversity Offsets as a Licence to Trash?
Biodiversity offsets have evolved from the aspiration to reconcile the incremental erosion of
biodiversity levels with continued growth and development. The literature surrounding
offsetting and no net loss clearly indicates that offsetting is extremely contested conservation
strategy, and there is uncertainty around whether offsetting is an appropriate mechanism for
biodiversity conservation and no net loss an appropriate policy aspiration. The aspiration of no
net loss, to achieve the management of natural capital stocks, should be understood essentially
as an anthropocentric, technocratic and a rational neoliberal approach, which recognises
biodiversity as a resource to be maintained. Issues of ethics and effectiveness surrounding
environmental valuation and environmental restoration have resulted in concern that
biodiversity offsetting has to date “facilitated development while perpetuating biodiversity loss”
(Walker et al., 2009:14). Rather than working to halt biodiversity loss, offsets could instead be
used as a ‘licence to trash or destroy biodiversity’ in exchange for uncertain environmental gains
(Walker et al., 2009; Robertson, 2004; 2006; Hannis and Sullivan, 2010). There are clearly two
sides to compensation. There is an identifiable need for compensation to raise the minimum
requirements for developers and prevent the depletion of biodiversity. Also, compensation can
be used by developers to open a window of opportunity to gain planning permission in exchange
for restoration promises. Given the promises and criticisms of offsetting it is difficult to ascertain
whether the situation would be better or worse with offsets.
2.6 Operationalising Biodiversity Offsets
2.6.1 Evolving Offsetting Systems and Practice
Systems of biodiversity offsetting are now found worldwide (as highlighted earlier in Table 2.1),
sometimes as a result of government legislation and in other cases as a consequence of the
efforts of organisations or corporate policies (Darbi et al., 2009). The diversity of different
proponents and jurisdictions means that offsetting has been implemented into a range of
conservation agendas and socio-economic contexts. Consequently, offsetting systems and
mitigation banks come in a huge variety of shapes, sizes and institutional arrangements (Marsh
et al., 1996). Two broad ‘types’ of offsets are recognised in the literature: restoration offsets and
averted loss offsets (Bekessy et al., 2010). A restoration offset is essentially where an immediate
loss of existing habitat is traded for the promise of the future habitat creation or regeneration,
examples include the Simandou Project in the Republic of Guinea (Koman et al., 2014). In
contrast, an averted loss offset, also referred to as a protection offset, is where an existing
47
habitat is secured or protect in perpetuity in exchange for loss (Bekessy et al., 2010). Restoration
offsets are by far the most common type.
Offsetting literature also makes a distinction between voluntary and mandatory offsetting (ten
Kate et al., 2004; OECD, 2014). Offsets can operate as part of wider schemes, made mandatory
using compliance regimes, e.g. the US, German and Australian offsetting schemes. Alternatively,
offsets are also being undertaken voluntarily by businesses, such as Rio Tinto or Network Rail,
in a wide range of different countries, and often in partnership with organisations such as BBOP
(Doswald et al., 2012; ten Kate and Crowe, 2014). Offsets can also operate under banking
systems using private conservation banks, such as CDC Biodiversité (Bouches-du-Rhône, France);
the Environment Bank (UK) and Thames River Conservation Credits Bank, or alternatively
through ad-hoc or one-off offsets developed specifically for a project. Some offsets are part of
generalist schemes e.g. the German Impact Mitigation Regulation, whereas others target certain
species or habitats (e.g. Australian Bush Broker Scheme, US Wetland Mitigation Banking, and
Brazilian Forest Offsets).
The rising application and proliferation of offsetting clearly jars with concerns surrounding the
ethical implications and practical effectiveness of offsetting. Although, offsets may have
negative qualities, and could be misused, a number of researchers and organisations have also
argued that this may not detract from their significant potential to generate gains for
biodiversity (Bull, 2015; Baker, 2014; Newey, 2014; Middle and Middle, 2012). For instance, Race
and Fonesca (1996) suggest that many resources managers still see compensation as “better
than doing nothing”. Equally, Middle and Middle (2012) stress that the opportunities to use
offsets as a useful management approach are potentially significant. Madsen et al. (2011)
highlights that despite the undercurrent of doubt around how offsetting will operate for
biodiversity conservation there has still been a proliferation in practice. Finally, Maron et al.
(2012) point out that biodiversity offsetting is likely to increase in line with on-going global
development. The effectiveness and implications of biodiversity offsetting are evidently central
research concerns for the field of biodiversity conservation.
There are beginning to be standards, strategies and guidance surrounding offsetting e.g. BBOP
(2009a,b; 2012a,b,c), ten Kate and Crowe (2014), Bayon et al. (2012) and a range of technical
study papers (e.g. IUCN, 2014; ten Kate and Pilgrim, 2014; Treweek et al., 2009). However, there
appears to be no single universal model of best practice, no how-to-kit which states how
offsetting system should operate. In designing offsetting systems, the approach taken is
effectively ‘open for interpretation’ with a variety of approaches currently operating in parallel.
However, variation in offsetting practice could result in considerable variation in outcomes for
biodiversity (Gordon et al., 2011). Therefore, McKenny and Kiesecker (2010:168) highlight that
there are a number of challenges to adopting and developing an offsetting system, questions
such as “what counts as an offset? How much does it count? Where should the offset be located?
When does it need to be operational and for how long? How should risks be managed and what
if the offset fails?” Consequently, there has been a proliferation of literature, debate and
discussion, focusing on how offsets can best operate to achieve no net loss (e.g. Norton, 2009;
McKenney and Kiesecker, 2010; Brownlie et al., 2012; Clare et al., 2011; Hayes and Morrison-
Saunders, 2007; Rundcrantz and Skärbäck, 2002; Wildling and Raemaeker, 2002; Bull et al.,
2013; Maron et al., 2016; Gardner, 2013; Gardener and von Hase, 2012). For these authors the
48
specific elements and choices made in the design of the offsetting systems, such as ecological
contingency and exchange factors between losses and gains, are key in whether offsets achieve
no net loss of biodiversity (Rajvanshi and Mathur, 2009).
2.6.2 Key Issues and Principles for Operationalising Offsetting
The key issues for operationalising offsetting, its system design and implementation, are
conceptualised quite differently in the literature. Gardner et al. (2013) refer to general
challenges for offsetting practice and key ingredients for no net loss (Gardener and von Hase,
2012). Bull et al. (2013) differentiate between conceptual and practical challenges, whilst others
such as Maron et al. (2016) refer to conceptual, governance and technical challenges. Whereas
multi-lateral environmental organisations such as BBOP (2012b) or the IUCN (2014) refer to rules
and principles for offsetting, shown in Box 2.3.
Within the myriad of different terms and conceptualisations it is apparent that this body of
literature is generally referring to a similar set of challenges and core issues (Maron et al., 2016;
BBOP, 2012b; ten Kate et al., 2004; Bull et al., 2013; Gardner et al., 2013; Gardner and von Hase,
2012; Norton, 2008, see Appendix 1 for details). Key issues include the use of appropriate
currencies, biodiversity surrogates and offsetting metrics, to calculate and value biodiversity;
the question of offsettability and the limits to what can be offsets (including replicability and
reversibility of impacts); ensuring equivalence between offset losses and gains (like-for-like or
like-for-better offsets); the application of offsets in line with the mitigation hierarchy, as a last
resort; consideration of the spatial location and landscape context of offsets; the achievement
of additionality and the use of offsets as a new contribution to conservation; and compliance,
long-term management and securing offsets in-perpetuity. There is a raft of other issues (e.g.
uncertainty, time-lags), however, those mentioned above represent the core areas of concern
around offsetting system design. For a comprehensive outline of each issue please see Table 2.3.
These issues for offsetting implementation and design cover a broad range of aspects around
‘when and how’ offsets should be applied. Therefore, these factors are often described as
exchange restrictions, ecological contingency factors or protocols for offsetting (Walker et al.,
2009), which try to ensure offsets are not used as a licence to trash. There are also some issues
which represent more managerial and governance concerns, such as compliance and long-term
management. For the achievement of no net loss, managerial issue such as ensuring compliance
are equally as important as ecological contingency factors. A similar list of implementation
concerns is found in Marsh et al.’s (1996) early text on the theory and practice of mitigation
banking. Therefore, these issues are also not particularly new for biodiversity offsetting but
represent a longstanding preoccupation. Each issue has been analysed in dedicated papers and
is part of more general reviews of offsets practice (for examples see Bull et al., 2013). Although
there is a clear appreciation that these issues are important their resolution has proved hard
achieve (Maron et al. 2016). For example, how offsets will work with the mitigation hierarchy,
appropriate metrics and currencies, and like-for-like, is still the subject of considerable
deliberation and debate (See Table 2.3), and Maron et al. (2016) refers to them as ‘wicked
problems’. Therefore, these critical issues still very much dominate the research and guidance
surrounding the implementation of biodiversity offsetting.
49
Box 2.3 BBOP Principles for Biodiversity Offsetting Agreed by BBOP Members (BBOP, 2012b)
1. Adherence to the mitigation hierarchy: A biodiversity offset is a commitment to
compensate for significant residual adverse impacts on biodiversity identified after
appropriate avoidance, minimization and on-site rehabilitation measures have been
taken according to the mitigation hierarchy.
2. Limits to what can be offset: There are situations where residual impacts cannot be
fully compensated for by a biodiversity offset because of the irreplaceability or
vulnerability of the biodiversity affected.
3. Landscape Context: A biodiversity offset should be designed and implemented in a
landscape context to achieve the expected measurable conservation outcomes
taking into account available information on the full range of biological, social and
cultural values of biodiversity and supporting an ecosystem approach.
4. No net loss: A biodiversity offset should be designed and implemented to achieve in
situ, measurable conservation outcomes that can reasonably be expected to result in
no net loss and preferably a net gain of biodiversity.
5. Additional conservation outcomes: A biodiversity offset should achieve
conservation outcomes above and beyond results that would have occurred if the
offset had not taken place. Offset design and implementation should avoid
displacing activities harmful to biodiversity to other locations.
6. Stakeholder participation: In areas affected by the project and by the biodiversity
offset, the effective participation of stakeholders should be ensured in decision-
making about biodiversity offsets, including their evaluation, selection, design,
implementation and monitoring.
7. Equity: A biodiversity offset should be designed and implemented in an equitable
manner, which means the sharing among stakeholders of the rights and
responsibilities, risks and rewards associated with a project, and offset in a fair and
balanced way, respecting legal and customary arrangements. Special consideration
should be given to respecting both internationally and nationally recognised rights of
indigenous peoples and local communities.
8. Long-term outcomes: The design and implementation of a biodiversity offset should
be based on an adaptive management approach, incorporating monitoring and
evaluation, with the objective of securing outcomes that last at least as long as the
project’s impacts and preferably in perpetuity.
9. Transparency: The design and implementation of a biodiversity offset, and
communication of its results to the public, should be undertaken in a transparent
and timely manner.
10. Science and traditional knowledge: The design and implementation of a biodiversity
offset should be a documented process informed by sound science, including an
appropriate consideration of traditional knowledge.
50
Table 2.3 Common Challenges Surrounding Offset System Design and Implementation
Challenge Key aspects and areas of debate
Offsetting
Metrics and
Currencies
Biodiversity offsetting metrics and currencies are used to quantify losses, gains
and residual impacts on biodiversity, to enable the measurement of no net
loss (BBOP, 2009a, 2012b). Gardner and von Hase (2012:10) highlight that “no
single currency can adequately account for all concerns about biodiversity”.
There are a range of different choices about what is a representative proxy for
biodiversity and the integrity of offsetting metrics. One of the most common
debates is between taking a habitat or species based approach, however,
additional factors such as baselines, counterfactual scenarios, choice of
multipliers for restoration risk, uncertainty, time-lags and location are also key
areas of concern in developing and applying metrics (Bull et al., 2013; Bull et
al., 2014; Quèntier and Lavorel, 2011; Gonçalves et al., 2015). There are also
user relates choices between simple easy to understand approaches and more
complex but ecologically meaningful metrics, with different data
requirements and issues (Gardner and von Hase, 2012). At present there are
a wide variety of different metrics tailored to different contexts, but some
suggestions that we should move towards harmonised metrics (Gonçalves et
al., 2015).
Equivalence,
like-for-like
or like-for-
better
“Biodiversity offsetting deals with exchanges in types, time and space”
(Brownlie et al., 2012). Concepts such as like-for-like, in-kind and out-of-kind
are described as replacement policies to guide the priorities for offsets and
equivalence in these exchanges. Traditionally, offsets have been based on a
strict like-for-like approach (e.g. Kiesecker et al., 2011; Race and Fonesca,
1996; Treweek et al., 2009), linked to replication of environmental values.
However, exactly what like-for-like entails is often unclear and how ‘like’ an
offset has to be remains undefined (Hayes and Morrison-Saunders, 2007).
There is also increasing recognition that our ability to realise like-for-like
compensations is limited, with Hayes and Morrison-Saunder (2007) siting
reasons such as the lack of available land and difficulties in describing and
comparing like-for-like values. Furthermore, ten Kate et al. (2004) highlight
that it is “often better to aim for conservation of complex systems rather than
direct equivalence”. Increasing flexibility around the application of the like-for-
like principle (Cuperus, 2004) is apparent, and there is a clear trend towards a
greater acceptance of out-of-kind (McKenney and Kiesecker, 2010) and the
most environmentally preferable option, instead of direct equivalence to deal
with the realities of the limits of the science of restoration ecology.
Offsetability
It is widely acknowledged that there are limits to the impacts which can and
should be offset (ten Kate et al., 2004; Gardner et al., 2013; Pilgrim et al.,
2012), exactly which impacts should not be offset is, however, debatable due
to a lack of guidance and consensus. Generally, offsetability is thought to
decrease with increased vulnerability and irreplaceability of biodiversity.
Pilgrim et al. (2013) developed a burden of proof framework for offsetability
linked to the appropriateness and achievability of offsetting, determined
51
through level of conservation concern, magnitude of the significant residual
effect, opportunity for suitable offsets and feasibility of offset
implementation.
Adherence
to the
mitigation
hierarchy
One of the most frequently highlighted principles of offsetting is that it should
be conducted in line with the mitigation hierarchy, as a last resort. The
sequencing of mitigation measures, with a preference for avoidance and
minimisation, is based on the principle of prevention rather than a cure, and
therefore that the protection of biodiversity is best achieved in situ (Treweek
et al., 2009). There are, however, complaints around a lack of guidelines to
determine when to move from one stage of the mitigation hierarchy to
another (Maron et al., 2016). The embeddedness of the mitigation hierarchy
in current practice has also been questioned (Clare et al., 2011). Particularly,
Kiesecker et al. (2011), Clare et al. (2001) and Norton (2009) all propose that
the mitigation hierarchy should be applied with a broader context of some
kind, such as a landscape conservation plan or a watershed plan, to provide a
foundation to identify the most appropriate step in the mitigation hierarchy.
Site
selection
and
Landscape
context
“It is essential that the design and implementation of project-level offsets
account for wider landscape context” (Gardner et al., 2013:8). The location of
the offset influences the spatial relationship between the impacted and
compensatory sites. Consequently, “one of the central questions in offset
design is how offsets should be located in relation to the impacted site”
(Kiesecker et al., 2009). Offsets are also linked into landscape-scale
conservation aspirations in order to make offsets meaningful for biodiversity
conservation (Kiesekecker et al., 2009). Therefore, location may be important,
but the degree of relationship to the impacted site vs. landscape scale
aspiration is far from resolved.
Additionality ‘Additionality’ refers to “the requirement that an offset benefits consist only of
gains that would not otherwise have occurred and that are fully additional to
the expected scenario without the offsets” (Maron et al., 2016:490).
Additionality is particularly connected to issues around in-lieu or averted risk
offsets, and ensuring that areas which would already be preserved are not
used as offsets (McKenney and Kiesecker, 2010). Consequently, guidance for
offset design and implementation often includes the requirement that offsets
should not be located on sites which already have a designation and that
preservation can only be used to offset an impact if the area would be
threatened in the future (BBOP, 2012b).
In-
perpetuity
Bull et al. (2013) highlight that there are questions around how long offsets
are expected to last, and what in-perpetuity means. Should in-perpetuity refer
to ‘as long as the development lasts’ or ‘some measure of ecological
timescales’, and how can offsets be managed for longevity. The timescales of
offsets are linked into the reversibility of impacts and the long term integrity
of offsets (Gardner et al., 2013).
As previously highlighted, these key debates around how and when offsets should be designed
and implemented are generally reflected in a series of principles (e.g. Box 2.3; BBOP, 2012a,b)
52
for considerations for offsetting systems. The BBOP principles have been well accepted in
offsetting practice, for instance, Hayes and Morrison-Saunders (2007) report that in Australia
many practitioners do not consider an offset valid unless they are like-for-like (or in-kind).
Furthermore, the concentration around a series of principles, rather than a specific process,
provides the opportunity to tailor offsets to specific locations or situations rather than simply
adopting models applied in alternative contexts. Together the principles or challenges for the
implementation and design of offsets draw attention to the wide range of issues, which will be
vital for the achievement of no net loss through offsets.
Accounting for all of these different issues may be important to ensure equivalence, however,
it is also extremely difficult (Salzman and Ruhl, 2000; Walker et al., 2009; Quigely and Harper,
2005). In reviews of offset design and implementation one of the most recurrent comments is
the lack of workability of a number of the principles. For instance, Hayes and Morrison-Saunders
(2007) also reported that some practitioners did not believe that the like-for-like principle is
workable in practice. In some contexts, there have been attempts to move away from strict rules
around offsetting towards a more flexible approach, but this led to concern about the validity of
offsets. However, Brownlie et al. (2012) highlighted that these attempts to improve offsetting
practice may not always be engaging with all of the issues which are preventing the achievement
of no net loss.
2.6.3 Beyond Ecological Exchange Rules and Principles
The focus for improving offsetting practice has coalesced around a number of key factors and
considerable effort has been put into designing a series of principles of best practice. Research
attempting to resolve and explore these conceptual debates and challenges (e.g. Maron et al.,
2016; ten Kate et al., 2004; McKenney and Kiesecker, 2010) dominates discussions around how
offsetting schemes should operate and whether or not offsets will achieve no net loss. However,
the singular focus on procedural and enforcement failures, and the development of the best
operational frameworks, has come under criticism (Walker et al., 2009).
“Revision of compensation efforts through technical or scientific details are not
likely to make compensatory mitigation more effective because we need to
acknowledge the extent to which non-scientific or real world complications plague
current policies and practice” (Race and Fonesca, 1996:94).
These critical ecological exchange factors are increasingly acknowledged as only likely to go so
far towards achieving no net loss of biodiversity, and there is a growing perception that they
cannot solely be relied upon to combat issues with the ineffectiveness of biodiversity offsetting
(Gardner and von Hase, 2012).
Tischeew et al. (2010), Gardner and von Hase (2012) and Fitzsimons et al. (2012) have begun to
explore the governance as well as the technical challenges of implementing offsetting within
planning systems. While, Treweek and ten Kate (2014:1) also recognised that: “in addition to
‘technical challenges’ the literature highlights a number of ‘governance’ or political realities that
can hamper appropriate use of offsets in practice” (also see, Maron et al., 2016; Gardner et al.,
2013; Fitzsimons et al., 2014). Increasingly, there are suggestions of the need to acknowledge
the “practical realities” (Gardner and von Hase, 2012:12), the “physical, institutional and
political arrangements governing the receiving environment” (Cowell, 2003:347), and the “non-
53
scientific and real word complication [which] plague current policies and practice” (Race and
Fonesca, 1996:94). In essence, these researchers are beginning to examine additional drivers of
(in)effectiveness for offsetting, and existing features of governance, which could influence the
success and implementation of exchange factors.
As an emerging policy instrument, the majority of research surrounding biodiversity has
explored offsets as an isolated policy phenomenon, rather than as a tool within a wider existing
system of planning and environmental impact assessment. Rather than looking at offsets as an
isolated policy innovation, research around offsetting is beginning to highlight the need to also
explore how offsets are being embedded into existing institutions, and whether offsets will
function as promised when applied in different cultural, institutional and political contexts, and
under different circumstances (Mann et al., 2013). Effectively how offsets will work within the
wider landscape of environmental governance approaches and tools.
2.6.4 Operationalising Offsets Through EIA
Tischeew et al. (2010) places particular emphasis on the need to determine the effect of
planning implementation and management deficiencies on goal achievement for offsetting and
identifies that the point at which offsets are integrated into the planning system as potentially
critical. Although the receiving environment for offsetting will vary between schemes, in terms
of the political, social, economic and ecological make-up, there are also some more consistent
elements. Environmental Impact Assessment, or EIA, is a globally applied framework for
environmental appraisal, used to forecast the possible environmental consequences of
development proposals. For offsetting schemes, EIA is a key part of the existing regulatory
framework for assessing environmental standards. EIA is referred to both in academic research
and guidance on biodiversity offsetting as part of the wider context within which biodiversity
offsets will be operationalised (BBOP, 2009a,b; Hayes and Morrison-Saunders, 2007; Middle and
Middle, 2012; Melton, 2005; Gillespie, 2012; Brownlie and Botha, 2009; Doswald et al., 2012;
Slootweg et al., 2010). However, the exact way that EIA and offsets will work together is far from
clear.
Doswald et al. (2012) highlights that there are:
“Three main legislative frameworks can lead to offsets (1) species and habitat
legislation (2) EIA regs, (3) offsets or compensation regulation. North America,
Europe, Australia use habitats and species legislation. EIA or specific offset or
compensation regulation are either current mechanisms or potential drivers for
offsets in Latin America and Asia” (Doswald et al., 2012:7).
Most often EIA is referred to as a possible ‘vehicle’ for operationalising biodiversity offsetting,
through integrating offsetting into this existing appraisal procedure (BBOP, 2009a), EIA could
work as a legal mechanism or framework to operationalise offsets (e.g. Doswald et al., 2012;
Slootweg et al., 2010). EIA is considered, by some, as one of the strongest tools for getting
environmental consideration into different projects, and therefore Rundcrantz and Skärbäck
(2003) suggest that if environmental compensation is proposed, described and analysed through
EIA procedure this will probably make it easier for offsets to be implemented in the project.
Equally, BBOP (2009a:5) echoes this perspective, highlighting that EIA is an “obvious vehicle” for
integrating biodiversity offsets into existing corporate procedures and management systems,
54
and offsets have been portrayed as a subset of the paradigm of impact assessment.
Furthermore, academics have also suggested that offsets are designed to complement or
supplement EIA (Race and Fonesca, 1996). For Gillespie (2012) the prospective connection
between EIA and offsets is, in fact, a core justification for the ease of uptake of offsets. BBOP
(2009a) highlights a whole host of possible different ways that the EIA framework can contribute
to the design and implementation of biodiversity offsets (Box 2.4). Frequently, the EIA process
appears to be acknowledged as the main method through which to generate the requirement
to implement biodiversity offsets (e.g. BBOP, 2009a; ten Kate et al., 2004; Treweek et al., 2009).
Effectively, this means that EIA could play a fundamental part in triggering the requirement for
offsets. There are also suggestions that EIA could contribute by informing offsets, as a
prospective data source (Box 2.4; BBOP, 2009a).
Although EIA is often mentioned in relation to offsets, and the connection between offsets and
EIA has been promoted in guidance, e.g. BBOP (2009), as potentially having multiple benefits.
BBOP (2009a) highlight a prospective relationship based on EIAs utility for operationalising
offsetting (see Box 2.4). Independent academic studies of the connections and links between
EIA and offsets are relatively sparse or limited to the consideration of specific aspects (Hayes
and Morrison-Saunders, 2007; Middle and Middle, 2012 Brownlie and Botha, 2009). Hayes and
Morrison-Saunders (2007) have begun to explore the perception of offsetting by EIA
practitioners or consultants, identifying issues with the workability of offsets principles for EIA
practitioners. While, Brownlie and Botha (2009) bring up questions about trade-offs in EIA
through the inclusion of offsetting. Through EIA, offset metrics will join a wider range of existing
environmental analysis aids and tools for assessing sustainability decisions. Overall, there is an
assumption that the offsetting and EIA processes will work effectively together, with a
considerable range of possible roles for EIA in the operationalising offsetting.
Box 2.4 How Impact Assessment Could Contribute to the Design and Implementation of
Biodiversity Offsets (BBOP, 2009a)
55
As a potentially key part of the environmental governance landscape of offsetting, how
offsetting interventions and EIA procedures will work together, the question of their integration
and the outcomes for biodiversity conservation, is a crucial research question when exploring
the physical, institutional and political arrangements of offsetting. Although a clear link between
EIA and offsets has been established the exact nature of the relationship between these two
mechanisms has not been critically investigated, and consideration of the notion of integrating
has been largely uncritical. Therefore, the question of what is meant by the use of EIA and offsets
together, and what EIA working as a vehicle for offsets might entail, remain open for fuller
investigation. Looking at how these two approaches to environmental management and
biodiversity conservation will work together can provide insight into the governance context and
wider range of factors that will effect when, whether and how offsets achieve no net loss of
biodiversity.
2.7 Conclusion to the Literature Review
The literature review outlines the background and context of biodiversity offsetting within the
wider landscape of conservation strategies. Exploring existing research indicates that
biodiversity offsetting is a formalisation of current compensation mechanisms which promises
to achieve no net loss, develop new finance streams for biodiversity and even enable smarter
mitigation to take place by moving off-site. However, offsetting is also a controversial
conservation strategy and there are questions surrounding its ethics, effectiveness, and possible
implications for environmental decision-making. Complaints and issues with effectiveness of
offsetting mechanisms have generated a proliferation of research surrounding the
operationalisation of biodiversity offsetting, centralised on a number of key conceptual and
practical challenges. Issues for offsetting practice were found to be wide ranging from ensuring
the adherence to the mitigation hierarchy to developing correct currencies to measure
biodiversity losses and gains and investigating the offsettability of different impacts. However,
the effectiveness of offsetting mechanisms has generally been considered in isolation rather
than in relation to wider context and receiving environment. The degree to which existing of
tools for environmental governance could set the parameters for biodiversity offsetting success
or failure is relatively unknown. Therefore, rather than looking at offsets as an isolated policy
innovation, this suggests that research around offsetting also needs to explore how offsets are
being embedded in existing institutions and whether offsets will function as promised in
different contexts, and under different circumstance. Globally, offsetting systems are likely to
be operationalised in a context which is currently dominated by EIA, as the main pre-existing
framework for assessing and managing development impacts. However, there has been little
critical investigation of the integration and interaction of EIA and biodiversity offsetting.
3. Conceptual Framework: Integrating Biodiversity Offsets and EIA
3.1 Introduction to the Conceptual Framework
Chapter 2 provided a review of the context, nature and parameters of debates surrounding
biodiversity offsetting mechanisms, emphasising criticisms related to the ethics and
effectiveness of offsetting and highlighting a multitude of challenges related to the
operationalisation of offsetting systems. The focus of this Chapter is to build on the literature
review and explore one element of the receiving environment for offsetting - Environmental
56
Impact Assessment (*hereafter EIA). EIA, as an existing procedural framework for analysing
environmental impacts, has been connected to the operationalisation of offsetting in guidance
and early literature (e.g. BBOP, 2009a; Doswald et al., 2012; ten Kate et al, 2004), and in some
states, EIA already forms part of offsetting systems. However, the exact relationship between
EIA and offsetting is far from clear, and the notion of integrating offsetting and EIA has only been
subject to limited academic investigation (Hayes and Morrison-Saunders, 2007; Wende et al,
2005; Middle and Middle, 2010). The remit for this section is to first elaborate on the nature,
parameters and conceptual foundations of EIA, as a procedural framework for forecasting
environmental impacts. Then to explore the notion of integration of EIA and offsetting in the
context of different strategies for environmental management, linking to the wider literature on
integrative assessment and the combined analysis of environmental assessment tools. An
integration framework is then developed to provide a preliminary outline of the theoretical
compatibility of EIA as an existing procedural framework, and offsetting as a new tool for
biodiversity intervention. This initial framework will then provide a basis from which to further
explore the integration of EIA and offsetting, and the possible outcomes for biodiversity impacts.
The Chapter concludes with an overview of the research focus and presentation of the research
aims and objectives.
3.2 Environmental Impact Assessment
Environmental Impact Assessment, or EIA, is generally understood as:
“A process of identifying, predicting, evaluating and mitigating the biophysical,
social and other effects of proposed projects and physical activities prior to major
decisions and commitments being made” (Sadler, 1996:13).
The EIA process provides a systematic approach for the consideration of the possible significant
impacts and environment consequences of a project proposal (Jay et al., 2007). EIA is essentially
a ‘framework’ or ‘procedure’ containing a number prescribed stages (Gaspartos, 2010; Glasson
et al., 2012), such as impact identification, prediction, and evaluation. The main stages of the
process are shown in Figure 3.1. Rather than dictating a specific analytical approach various
analytical tools can be used within the EIA framework. EIA is often characterised, through its
process, as a series of iterative steps leading to a statement of environmental impact (or EIS)
(Glasson et al., 2012).
Through the identification and evaluation of the possible environmental outcomes of projects,
the immediate aim of EIA is, most commonly, described as a process to facilitate informed
decision-making and sound environmental management (Sadler, 1996; Jay et al, 2007; Glasson
et al, 2012). Therefore, EIA is anticipatory in nature and based on a precautionary approach to
project authorisation (Jay et al., 2007). Undertaking the EIA process is based on providing an
opportunity to identify inappropriate developments, reduce negative effects and improve
projects (Sadler, 1996; Glasson et al., 2012). Essentially, as Kolhoff et al. (2010:125) describe
“[EIA] directs decision-makers to ‘look before they leap’”.
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Figure 3.1 The EIA Process (UNEP, 2002)
EIA was first developed in the US in the 1970s (Glasson et al, 2012) and is now a well-established
approach backed by legal and procedural requirements in more than 120 countries (IAIA, 2016).
Despite the uptake of EIA worldwide, the basic concept and components of the EIA process have
remained remarkably consistent (Glasson et al., 2012). Furthermore, EIA has become an
environmental governance norm:
“It seems inconceivable, nowadays, to decide about major projects and policies
without an analysis of the positive and negative impacts on the environment”
(Gasparatos, 2010:1613)
58
Therefore, the EIA process has developed into a key part of the regulatory framework for
assessing environmental standards, firmly embedded in the institutional context of decision-
making (Glasson et al., 2012). EIA has also been part of what Scrase and Sheate (2002) describe
as a wider ‘audit explosion’ since the 1970s-80s, which saw the development of not only EIA but
a whole raft of assessment tools including Cost Benefit Analysis, Life Cycle Assessment, Social
Impact Assessment, Health Impact Assessment, Risk Assessment and Strategic Environmental
Assessment, to try to guide sound decision-making.
The decision-informing or aiding aspiration of EIA, and many other decision-aiding tools, is often
attributed to the dominance of rational planning theory in the 1960s/70s (Petts, 1999;
Lawrence, 2000; Elling, 2009; Jay et al., 2007).
“A rational decision is defined as one in which the option that most satisfactorily
achieves the stated objective(s) is selected, based on a complete understanding of
the consequences of all relevant alternatives and consensus about the goals that
govern the decision” (Cashmore et al., 2004:298).
Rational planning theory is based on the idea that planning should be a systematic and value-
free consideration of alternatives by experts (Leknes, 2001). Under rationalist thinking the EIA
process should be a systematic and technical evaluation of impacts to enable objective decision-
making through the provision of comprehensive information (Lawrence, 2000; Weston, 2000;
Elling, 2009). Under the rationalist paradigm, the best possible process will result in the optimum
information and decision-making. The dominance of rationalism during the emergence of EIA
practice means that research surrounding EIA has tended to focus on refining instrumental
effectiveness through technical enhancement and improved communication (Cashmore, et al,
2004). Furthermore, the prevalence of the techno-rational model means that the main output
of the EIA process has focused on the publication of an Environmental Impact Statement (EIS),
to supply decision-makers with the best possible information of the environmental
consequences of a project proposal (Jay et al., 2007; Glasson et al., 2012).
The rational model, and ideas that the production of EIA and decision-making is value-free,
objective, or impartial, has now largely been refuted as unrepresentative of the value-full nature
of decision-making and EIA is an intricate weaving of fact and fiction (Jay et al., 2007; Owens et
al., 2004; Lawrence, 2000; Cashmore et al., 2008). Therefore, there has been an increasing
appreciation that there are limits to the neutrality of the production of EISs, and a move to
acknowledge that EIA has more of a mixed character as both a science and an art (Jay et al,
2007). Appreciation of the disconnection between the rationalist model, the reality of EIA
production and the political nature of decision-making has been linked to dissatisfaction with
the performance and achievements of EIA in influencing decision authorisation (Cashmore et
al., 2004; Jay et al., 2007). Most notably, this shift in thinking has brought into question the idea
that better information will lead to better decisions, and therefore the immediate aim of EIA as
a decision-informing tool. Consequently, over the last ten years there been a move towards
reconsidering the theoretical or substantive basis of EIA, and attempts to generate a
fundamental re-think of what EIA is, how it should progress and the role of EIA in relation to
decision-making (Cashmore et al., 2004, 2008; Lawrence, 2000; Jay et al., 2007). Furthermore,
there have been increasing attempts to recognise the more indirect means through which EIA
can contribute to the overarching goal of sustainable development, such as a symbolic
59
deterrent, through environmental education or changing values over longer timescales (Jay et
al., 2006; Bartlett and Kurian, 1999).
EIA is embedded in international practice and an accepted regulatory norm for the development
planning process. Therefore, the EIA process is key part of the current landscape of
environmental governance for the built environment and a central component of the regulatory
framework for offsetting. However, increasing disquiet with the status quo in EIA has developed
over the last decade, and questions are now being asked about the validity of the early
foundations and formulations of EIA, which have the potential to alter or extend the scope and
character of EIA. Therefore, EIA can also be seen as at a critical point in terms of its development,
with fundamental questions being asked about its future direction and effectiveness,
substantive purpose and relationship to decision-making.
3.3 Integrating Environmental Interventions
There is an underlying perception, in both literature and guidance on offsetting, that EIA will
play a role in aiding the operationalisation of biodiversity offsetting (e.g. BBOP, 2009a; ten Kate
et al., 2004; Doswald et al., 2012). At present, research on offsetting is an emerging research
field and thus far any consideration of the integration of EIA, as a procedural framework, and
offsetting, as a new intervention for no net loss, has been largely uncritical. The integration of
various environmental management and appraisal mechanisms is often linked to ideas of
environmental pragmatism which advocates streamlining, harmonisation and procedural
integration. Scrase and Sheate (2002) highlight that integration, in relation to environmental
assessment and management, has been on the research agenda since the late 1990s, driven by
a proliferation of policies promoting the integration of assessment tools as a model of best
practice. Researchers have investigated the logic of combining different strategies for
environmental management and appraisal frameworks, including EIA, cost benefit analysis,
health impact assessment, life cycle assessment and many others (e.g. Eales et al., 2005; Scrase
and Sheate, 2002; Ness et al., 2007; Owens and Cowell, 2002; Baumann and Cowell, 1999; Milner
et al., 2005; Kirkpatrick and Lee, 1999; Finnveden and Moberg, 2005; Gasparatos, 2010). This
body of research has explored the notion of integration and emphasises a range of key factors
for consideration in investigating the relationship between EIA and offsetting.
Scrase and Sheate (2002) highlight that the term integration has a range of different meanings
in relation to environmental management (Table 3.1). Integration, in the context of bring
together EIA and offsetting, refers to ‘integration among assessment tools’ with different
disciplinary and practical origins (Table 3.1). In analysing the integration among assessment
tools, Baumann and Cowell (1999) highlight that different tools can be used in combination,
side-by-side, consecutively, or even as a subset of other tools. The connections between
different tools can be complementary or duplicating, competing or incompatible (Baumann and
Cowell, 1999; Figure 3.2). Hacking and Guthrie (2008) also highlight that the integration of
different assessment tools can result in the addition of techniques and analytical features, and,
therefore, cause the expansion of the thematic coverage of appraisal frameworks. A classic
example of this analytical integration is the combination of Health Impact Assessment and EIA.
Such full methodological or analytical integration is considered a very strong level of integration
by Lee and Kirkpatrick (1999). Alternative integration can be more consecutive or in-parallel,
such as using the results of EIA as the evidence base for Environmental Management Systems.
60
Table 3.1 Meanings of Integration (Scrase and Sheate, 2002)
Scrase and Sheate (2002) emphasise that integration is often assumed to be a positive
sharpening or expansion of tools rather than actively investigated or questioned, however, the
“headlong rush to integrate can raise philosophical challenges for policy and decision-makers”
(Scrase and Sheate, 2002:291). For Kirkpatrick and Lee (1999) the uncritical integration of
different assessment tools is linked to approaches which are too unwieldy to handle effectively
or credibly, and can even result in the stretching of tools beyond their capacity (see also Hacking
and Guthrie, 2008). The potential for duplication, competing and incompatible tools, and
prospective difficulties in coordinating approaches, highlights that compatibility is a critical issue
in undertaking integration (Baumann and Cowell, 1999; Eales et al., 2005). In addition, there can
also be what Scrase and Sheate (2002) describe as disciplinary protectionism or ‘turf wars’
between different tool users, and Gasparatos (2010) highlights that there can be instances of
‘institutional protectionism’ where different institutions strive to establish a brand distinction
between quite similar tools. The right kind of integration is clearly important rather than simply
combining process through ‘flow diagrams’ or conducting assessments in isolation and stapling
assessment reports together (Abaza et al., 2004).
Exploring integration can enable a better understanding of the relationship between different
environmental appraisal tools, provide an opportunity to reflect on the limitations and framings
of different tools, and highlight the appropriateness of using certain tools together (Hacking and
Gurthrie, 2008; Gaspartos, 2010; Scrase and Sheate, 2002). The variety of forms and degrees of
integration, along with possible repercussions emphasised by existing research, suggest that
integration should not be undertaken lightly but based on an understanding of:
61
“Who is being asked to integrate what, with whom and how, and what conceptions
of sustainable development are different parties being invited to share?” (Owens
and Cowell, 2002:65).
Therefore, there is a need to establish the advisability of integrating EIA and offsetting,
essentially to determine whether the integration of EIA and offsetting will be competing or
incompatible. Investigating compatibility can help to establish what integration between EIA and
offsetting means: what degree of integration might be appropriate, what integration might
entail and what possible implications might result from integration. Pre-existing research
investigating integration not only emphasises that the choice to integrate EIA and offsets should
not be a trivial one but also provides a number of frameworks through which to begin investigate
integration and the compatibility of EIA and offsetting.
Figure 3.2 Forms of Integration (Baumann and Cowell, 1999)
3.4 Assessing Integration
To establish whether the integration of different analytical tools is appropriate, a variety of
conceptual frameworks have been developed in the literature, including Baumann and Cowell
(1999), Eales et al. (2005), Scrase and Sheate (2002) Ness et al. (2007), Gasparatos (2010) and
Finnveden and Moberg (2005). These studies suggest that approaches can be categorised and
compared based on a range of different factors, using different terms and frameworks. This
section draws on a number of common themes within this literature to guide the initial analysis
of the integration of EIA and offsets.
Firstly, Eales et al. (2005), Hacking and Guthrie (2008), Baumann and Cowell (1999) and
Gasparatos (2010) all emphasise that in comparing tools there is a need to explore the focus of
different approaches, i.e. their overall purpose and intentions, the object of the analysis, goals
and main assumptions. In addition to exploring the focus of different assessment tools, another
common aspect of analysis was the type of intervention that tools were aiming to achieve. This
includes questions such as whether they are working as an overarching procedural framework
or an analytical tool, advocating or informing a certain intervention, coming from a change-
oriented or descriptive point of view (Finnveden and Moberg, 2005). Bauman and Cowell (1999),
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Eales et al. (2005), Finnveden and Moberg (2005) also consider that the way that different
approaches process and present information is an important factor for integration. Therefore,
there is also a need to understand what benchmarks, rationales or approaches are used to
evaluate or score in different assessment approaches. The task here is often to distinguish
between the degree of aggregation of information, whether approaches are seeking to inform
deliberation, i.e. more participatory approaches, or are more technical or reductionist in nature
and suggest a preferred option (Hacking and Guthrie, 2010; Gasparatos, 2010). Finally,
examining the compatibility, scope and system boundaries of different mechanisms can further
establish their compatibility and whether they are investigating similar dimensions. This can
include temporal and spatial remits, target audiences or sectors (Baumann and Cowell, 1999).
Essentially this literature highlights that in exploring integration there is a need to examine the
different world-views evident in the varied approaches to environmental assessment and
intervention, and the rules of the game they play by, as illustrated in Figure 3.3.
Figure 3.3 Categorisations of Appraisal Tools (Eales et al., 2005)
3.5 Comparing EIA and Offsets
The literature on integrative assessment highlights a number of key factors which commonly
require consideration in integrating different environmental management approaches and
appraisal tools. These factors include (1) the focus or substantive aspirations of different
environmental management mechanisms, (2) the type of intervention or approach taken to
achieve this aspiration, (3) the approach taken to processing and presenting information, and
(4) the scope and remit of different mechanisms. Through exploring these factors it is possible
to establish, at least to some degree, an initial picture of the positions of different approaches,
i.e. who they are seeking to influence, what is considered relevant data, and what the objective
of analysis is, and thereby to gain insight into what form of integration might be possible and
appropriate (Gasparatos et al., 2010). This framework can then be used as a starting point to
consider the compatibility of EIA and offsets.
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Substantive Purpose or Focus
BBOP (2009a, b; 2012a) suggest that offsets can be considered, in theory, as a potential subset
of the paradigm of impact assessment, and, therefore, countries familiar with EIA should be able
to utilise the same legal machinery to implement offsets. As highlighted in 3.1, the broad aim of
the EIA process in the UK has traditionally been conceptualised as to contribute towards
sustainable development and sound decision-making by providing comprehensive information
on the environmental consequences of project proposals. Benson (2003) emphasises that this
makes EIA unusually weak as an environmental management tool, as it does not impose any
particular targets on decision-makers. While Cashmore (2004) emphasises that this substantive
purpose is difficult to translate into definable outcomes “how do you determine whether a
development is ‘sustainable’ when there are no objective standards by which to do so”
(Cashmore, 2004:420). Therefore, EIA, as an approach to environmental management, has
historically not been particularly outcome-orientated, lacking a clear frame of reference to
measure progress towards sustainable development (Hayes and Morrison-Saunders, 2007). In
comparison, biodiversity offsetting is highly outcome-orientated with a clear substantive aim to
achieve no net loss of biodiversity. Offsetting is clearly much more actively decision-making and
goal orientated than EIA. Consequently, ten Kate et al. (2004) suggest that the EIA process may
not synchronise well with the application of biodiversity offsets. Whether EIA can be used to
facilitate the aspiration of no net loss of biodiversity is seen as questionable by Hayes and
Morrison-Saunders (2007).
However, as highlighted in section 3.2 the immediate focus on EIA primarily as a decision-
informing tool has come under increasing scrutiny. Researchers have advocated for the need to
refocus the substantive aim of EIA, and redefine it as a more purposeful tool for sustainable
development (Dalkmann et al., 2004; Jay et al., 2007; Cashmore, 2004; Cashmore et al., 2008).
In reflection of this fact, Villaroya and Puig (2010) highlight that the adoption of the no net loss
aspiration could take EIA beyond its conventional decision-informing role and towards a more
decision-making position of whether, or not, a development is sustainable and which way a
choice should be made. Equally, Gilllespie (2012) highlights that the integration of EIA and
offsets could, for the first time, establish boundaries or standards around impact acceptability,
which should not be transgressed. The integration of a stronger substantive aim in the form of
no net environmental degradation has actually been previously suggested by Jay et al. (2007) as
a means to take EIA beyond its conventional decision informing role. Therefore, there is some
suggestion that offsetting could change EIA’s standing in decision-making from a passive
decision-informing tool to a more active decision-making tool.
Type of intervention
EIA is a decision-orientated framework for appraisal and, therefore, can be thought of as largely
descriptive, reporting the consequences of projects rather than focusing on instigating change
or interventions. However, mitigation proposals have always played a central role in EIA, a key
part of determining the environmental consequences of projects is based on whether or not
impacts can be avoided or mitigated (Glasson et al., 2012). Mitigation has even been portrayed
by some researchers as a critical component of the EIA process, described as both “the heart”
and “ultimate aim” of EIA by Wood (2003:258) and Jones et al. (1998:316). Furthermore, the
mitigation hierarchy is embedded in EIA guidance (e.g. Glasson et al., 2012; UNEP 2002; CIEEM,
64
2006). However, Gillespie (2012:11) emphasises that the mitigation step in EIA does not
generally involve a ‘swap’ of biodiversity, and typically focuses on on-site and in-situ mitigation.
“Conversely the core of offsets is about swapping and this unusually occurs at a
different site to where the development occurs” (Gillespie, 2012:11).
Furthermore, Treweek and Thompson (1997) found that generally mitigation measures
proposed in EISs did not to relate to any specific ecological impact but were simply aesthetic in
function. Therefore, mitigation in EIA may not always focus on ecological damage, while offsets
specifically focus on ecological restoration and achieving equivalence for direct habitat loss
(BBOP, 2012b). These divisions between the type of intervention employed by EIA and offsetting
could mean that the use of offsets presents a shift in thinking for EIA, and could even overload
the EIA framework (Treweek et al., 2009).
Approach to processing and presenting information
EIA looks at multiple dimensions of the environment and is inherently multi-criteria in nature
(Glasson et al., 2012; Gasparatos, 2010), employing a range of analytical tools rather than taking
a reductionist approach and using a single common denominator. In taking a non-reductionist
approach, the EIA process is generally based on giving equal weights to the various dimensions
of analysis which are treated separately in different impact silos or Chapters of the EIS (Glasson
et al., 2012). Although EIA does not use a common currency or monetary approach, it does
employ a qualitative common denominator and conceptualises each different impact silo
around the common concept of impact significance (Glasson et al., 2012). There is no general
definition of impact significance (Lawrence, 2007a; 2007b), instead, its determination within the
EIA framework is generally a process of expert judgement, normally bounded within strict
parameters (Lawrence, 2007a; 2007b; Briggs and Hudson, 2008). However, Wood (2008)
highlights that the attribution of impact significance remains:
“One of the most complex, contentious, and least-understood aspects of EIA
systems across the globe” (Wood, 2008:23).
Subjectivity is an inherent characteristic of determining impact significance (Briggs and Hudson,
2008; Wilkins, 2003), this also means the determination of significance in practice tends to be
highly variable (Lawrence, 2007b). Eales et al. (2005) also highlight that EIA traditionally attaches
considerable importance to consultation with parties affected by the options or proposal.
In comparison, as set out in Chapter 2 (2.5.3), offsetting take a much more quantitative approach
using biodiversity offsetting metrics to estimate biodiversity losses and gains. Offsetting metrics
are highly technical reductionist approaches, designed to commensurate the value of
biodiversity in different locations in order to establish an overall figure for biodiversity losses
and gains using a common denominator or currency (generally expressed as biodiversity units
or conservation credits). Moreover, offsetting metrics all measure success around the
benchmark of no net loss.
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Scope and Scale
The remit of analysis for both EIA and offsets is superficially quite similar, as both are linked to
development footprints and impacts. However, the resolutions at which EIA and offsets study
these impacts, their scope and scale, are quite different.
“Biodiversity offsets are generally intended to deal with significant residual effects
on biodiversity that remain after other appropriate actions have been taken to avoid
them or reduce them to an acceptable level” (Treweek et al., 2009:X).
Offsets focus on residual impacts (Burgin, 2008), whilst EIA traditionally focuses on only the
significant or major impacts which arise from development. Therefore, EIA may not focus on the
right resolution of biodiversity impacts (e.g. Latimer and Hill, 2007; ten Kate et al., 2004). How
residual impacts are currently identified and treated within EIA will be a key consideration in
how offsets and EIA interact. More fundamentally, Slootweg et al. (2010) highlights that
biodiversity is often considered only implicitly in EIA, and even neglected or badly represented.
Therefore, EIA may not just miss residual impacts but may fail to capture impacts on biodiversity
at all. Another potential point of discord is the timescale of EIA. The position of EIA as a decision-
aiding tool means that the EIA process may not synchronise well with the application of offsets
(ten Kate et al., 2004; BBOP, 2009a; Hayes and Morrison-Saunders, 2007). Thus offsetting could
challenge both the scope and scale of the EIA framework.
3.6 Integrating EIA and Offsets
EIA is a key part of the institutional and regulatory context within which offsetting will be
operationalised (BBOP, 2009a, b; 2012a; Doswald et al., 2012). EIA is envisaged as playing a
central role in operationalising offsetting, portrayed as a ‘vehicle’, trigger or legal machinery for
implementing offsetting (BBOP, 2009a; ten Kate et al., 2004). Furthermore, BBOP (2009) even
warns that:
“If biodiversity offsets are not planned within the EIA process there will be no
trigger or motivation for developers to consider them at all” (BBOP, 2009a:7).
The interaction of EIA and offsetting appears inevitable. However, Scrase and Sheate (2002)
emphasise that the rhetoric around integration is often simply assumed to be a positive
expansion or sharpening of tools rather than critically investigated. Furthermore, the headlong
rush to integrate can result in unwieldy approaches or the combination of tools and frameworks
with different worldviews (Eales et al., 2005; Hacking and Guthrie, 2010). Different forms and
degrees of integration could occur between these two mechanisms, including methodological
or consecutive approaches, or alternatively, tools can be incompatible or even compete.
Although offsets are thought of as a subset of the paradigm of impact assessment, to date
consideration of the integration of EIA and offsets has been largely uncritical (Race and Fonesca
1996) and exactly what the integration of offsetting and EIA will entail appears to be largely
unexplored, except by those promoting offsetting (BBOP, 2009a). Furthermore, how integration
might affect the outcomes of the EIA process, particularly its remit as a decision-informing tool,
and offsets quest to achieve no net loss of biodiversity, remains to be seen.
Exploring the notion of integration more critically by comparing the characteristics of offsetting
and EIA through the integration framework (summarised in Figure 3.4) indicates that they have
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some quite considerable differences. On a superficial level, both EIA and offsetting are applied
to achieve sustainable development. However, the discrete substantive purposes of EIA and
offsets are distinctly different; offsets take a specific perspective on sustianable development
through the notion of no net loss whereas how EIA contributes to sustainable development
remains open to interpretation. Although this does not mean that EIA and offsets are entirely
incompatible, and in fact several researchers have suggested that incorporating a more
definitive definition of sustainable development could improve EIA’s effectiveness, it is,
however, a considerable shift in thinking, and the necessity of a distinct aim for EIA is by no
means universally agreed upon. In terms of the type of intervention adopted, mitigation is
already a key part of EIA, yet, the EIA framework has traditionally focused on on-site and in-situ
mitigation and not on specific approaches to maintaining environmental capacity in comparison
with offsets. Furthermore, the way that EIA and offsetting process information is quite different,
with EIA using a multi-criteria approach and offsets aggregating information through offsetting
metrics. Finally, the scope and scale of EIA and offsets are potentially quite distinctly different.
EIA focuses narrowly on ‘significant’ or major impacts whereas offsets look at low-level or
residual impacts. Therefore, there are questions as to whether EIA would engage at the right
level to work as a framework or trigger for offsets.
The integrative framework does not suggest that EIA and offsets are completely incompatible
but indicates that there could be limitations or issues with the connections between EIA and
offsets. Despite indications of the need to link EIA and offsets, this preliminary exploration of
their integration suggests that EIA is certainly not the perfect framework for the application of
biodiversity offsetting and that the EIA process may need to be adapted to be used as a vehicle
for offsetting. Furthermore, alongside questions about the compatibility of EIA and offsets, there
were also some suggestions of the possibility for performance-based concerns around the use
of the EIA and offsetting process together, based on the idea that:
“The quality of the measures proposed is highly dependent on the quality of the
impact assessment and therefore the service providers commissioned by the project
developer” (Morandeau and Vilaysack, 2012:90).
Middle and Middle (2012) describe this as ‘procedural risk’ in the use of EIA to facilitate offsets,
which relates to the potential flaws and corrupting influence in the process of deciding and
implementing offsets through EIA. However, the exact dimensions of how EIA performance
could influence the practice of offsetting has been little explored. Moreover, the contemporary
literature on EIA stresses that it cannot simply be viewed as an inert tool (Cashmore, 2004;
Cashmore et al., 2008), and EIA consultants and developers could effectively set the playing field
for offsets. Finally, Middle and Middle (2012) even suggest that there could be some unexpected
results, or transformations, from using EIA and offsets together. Therefore, it is not only the
theoretical compatibility of these tools which needs to be taken into consideration but also how
the existing nuances in the performance and practice of EIA could influence the effectiveness of
offsets, and in the behaviour of EIA practitioners.
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Figure 3.4 Integration Framework for EIA and Biodiversity Offsetting
3.7 Research Focus
The techniques and strategies employed to achieve biodiversity conservation will influence
current rates of biodiversity loss. Debates surrounding the ethics and effectiveness of offsetting
as a new solution to the biodiversity crisis have divided opinions in academia, policy and practice
(e.g. Brownlie and Botha, 2009; Bull et al., 2013; Walker et al., 2009; Maron, et al., 2010, 2016).
Despite rising concerns around the implications and effectiveness of offsetting there has been a
considerable rise in schemes employed globally, resulting in a raft of new research which
explores ‘when and how’ offsets should be applied to best achieve no net loss of biodiversity
(Bull et al., 2013; Maron et al., 2016; Gardner et al., 2013; Gardner and von Hase, 2012).
The achievement of no net loss through offsetting has been linked to a wide range of issues and
ecological contingency factors, from the use of the right offsetting metrics to calculate
biodiversity losses, to ensuring offsetting takes place in adherence to the mitigation hierarchy
and gains to enforcing compliance. This research looks to explore a wider perspective by
investigating how the receiving environment, or governance landscape, might also shape the
outcomes of offsetting (following Tischeew et al., 2010; Gardner et al., 2013; Fitzsimons et al.,
2012). As a globally employed environmental appraisal procedure, EIA is likely to be a key part
of the regulatory framework for biodiversity offsetting, on an international scale. There is a clear
perception in literature and guidance that offsets and EIA will work effectively together, and EIA
is portrayed as a vehicle, trigger, legal machinery and even a data source for offsets. Moreover,
offsets are even presented a subset of the paradigm of impact assessment and designed to
complement EIA (Race and Fonesca, 1996).
Despite the potential for EIA to play a key role in the operationalisation of offsetting there has
been little in the way of critical investigation of the integration and interaction of these two
mechanisms. Past research in the field of integrated assessment questions the uncritical
combination of different environmental management tools, and highlights that the uncritical
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combination of assessments tools can result in unwieldy approaches, competing frameworks,
and the combination of tools with quite different worldviews (Scrase and Sheate, 2002;
Baumann and Cowell, 1999; Gasparatos, 2010). Initial exploration of integration already
suggests that EIA is not the perfect framework for offsetting, as these two mechanism have
some striking conceptual differences. This does not mean that these two approaches are
incompatible but that there could be limitation, risks and issues surrounding their connection.
Exploring integration can enable a better understanding for the relationship between these two
mechanism, the degree of integration which is appropriate and the implications accompanying
their connection.
Therefore, this study seeks to understand what is meant by the use of EIA as a vehicle for offsets,
and what integration of these two mechanisms might entail. Through tracing the interaction of
EIA and offsets this research looks to explore whether biodiversity offsetting can be an effective
tool for biodiversity conservation if it is applied through EIA. To understand how the wider
receiving environment, regulatory frameworks for environmental standards and planning set-
up could affect whether offsets achieve the aspiration of no net loss of biodiversity.
Research Aim:
To analyse whether biodiversity offsetting can stem the continual decline in
biodiversity as a compensation tool in EIA.
Research Objectives:
Objective 1: To review the theoretical basis for, and the controversies surrounding
the operationalisation of biodiversity offsetting as a new solution to the biodiversity
crisis.
Objective 2: To map out expectations around the integration of biodiversity offsets
and EIA, and the possible dynamics of their interaction
Objective 3: To explore the connections between biodiversity offsetting and EIA in
emerging practice and identify any possible areas of interaction and evidence of
implications.
Objective 4: To critically reflect on the outcomes of integrating EIA and biodiversity
offsetting in existing planning practice and the implications for the treatment and
management of biodiversity impacts.
Integration is, therefore, the key line of inquiry undertaken in this research, to understand more
fully the links, disconnections and implications of bringing together EIA and offsetting. The
methodological approach taken to investigate the integration of EIA and offsets is outlined in
the subsequent Chapter.
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4. Methodology: Investigating Integration
4.1 Introduction to the Methodology
Following on from the conceptual framework this Chapter details the research methodology
used to investigate the integration and interaction of EIA and biodiversity offsetting. The
methodology outlined here builds on the conclusions of Chapters 2 and 3, which identified that
EIA could potentially play a key role as a ‘vehicle’ for offsetting however, the relationship
between EIA and offsetting has been largely been assumed to be positive rather than critically
investigated. This Chapter sets out the domain of investigation and provides an overview of the
research design adopted to investigate integration, outlining a three-phase qualitative inductive
approach. Following on from the research design the main research methods used in each phase
are discussed, and the context of their application. The analytical approach taken is described
along with the anticipated limitations of the research strategy.
4.2 Research Domain
Biodiversity offsetting mechanisms are applied in a number of different states and systems
worldwide (Madsen et al., 2011). Studies of the relationship between EIA and offsetting could,
therefore, be undertaken in a range of different domains. Doswald et al. (2012) highlight that
offsetting is connected to the EIA regulations in South Africa, Mexico, Chile, China, and Pakistan.
There have been early studies of elements of the relationship between EIA and offsets, such as
practitioner perspectives, in the Australian context (e.g. Hayes and Morrison-Saunders, 2007).,
To fully explore the integration and interaction of EIA and offsetting, ideally, a comparative study
approach would have been undertaken, to contrast different relationships between offsetting
and EIA globally. However, the scope of this research was limited by time and resource
constraints.
In order to fulfil the aim of the research, within a limited research domain, the approach taken
was to instead look at an emerging, rather than established, state offsetting scheme. Through
exploring an emerging offsetting scheme, where the parameters for the engagement between
EIA and offsets have not yet been defined, the aim was to capture any range of different possible
relationships and ideas around the interaction of offsets and EIA. Offsetting schemes are
currently under consideration in a wide range of countries including Sweden, Spain, England,
Indonesia, Egypt, India, and France, to name a few (Doswald et al., 2012; Madsen et al., 2011).
For this study, the UK context was chosen. Proposals to develop a national English offsetting
schemes have been highly contentious (e.g. Vidal, 2013; Sullivan and Hannis, 2014) resulting in
considerable debate around whether and how a prospective offsetting scheme should operate.
Therefore, the UK also provides a useful microcosm of the wider debate around the introduction
of biodiversity offsetting, in the context of an already well-established EIA system.
4.3 Research Design
Rather than examining offsetting based solely on its merits as an individual environmental policy
innovation, this research sought to explore offsetting within the wider context of existing
environmental governance arrangements and planning tools, and particularly as a
subcomponent of EIA. The integration and interaction between offsetting and EIA was the
central relationship under investigation. To investigate integration this research was concerned
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with questions such as how offsets are working as a form of compensation within EIA, to what
degree and what forms of integration are occurring, how the presence of offsets could be
affecting the treatment of biodiversity impacts within EIA, and what role EIA is playing in
operationalising offsetting within the UK context.
The research design, shown in Figure 4.1, is based on a three phase qualitative inductive
approach. This design was driven by the research domain, research aim and objectives (Section
3.7). The first phase is based on investigating the research domain to clarify the background and
context of the research. The second and third phases are then linked to the empirical research
objectives (objectives 2 and 3). The second phase is based on mapping out the range of
theoretical expectations surrounding the integration and interaction of EIA and offsetting, to
develop a comprehensive picture of the possible dynamics of their relationship. The third phase
then explores the interaction of EIA and offsetting in practice, to see how ideas about integration
are materialising on the ground. To bring together theory and practice, the fourth objective was
to then critically reflecting on outcomes for future practice. These different phases of the data
collection are clearly mapped on to the different objectives of the research in Figure 4.1
Therefore, the research design was inductive in nature and based on building a comprehensive
picture of the relationship between EIA and offsetting, including both theoretical expectations
and interaction in practice. An inductive approach was also a key to the research objective and
the exploration of emergent phenomenon and testing ideas around how these two mechanisms
are being used together. The focus on practice also means that the research design was as highly
applied in nature, linked to the exploration of real world application of offsetting in conjunction
with EIA. Finally, the three–phased research design is also characterised by its qualitative
nature. Denzin and Lincoln (2011) emphasises that a qualitative approach is taken to gain an
understanding of and ask questions about relationships and interaction.
“The main features of qualitative research are that it is naturalistic, descriptive
rather than numerical, concerned with process rather than simple outcomes,
inductive rather than deductive, and subjective due to the researcher/informant
relationship” (Bogdan and Biklen, 2007:274).
Specifically, a range of qualitative research methods were undertaken (as show in Figure 4.1).
Distinctly different methods were employed to fulfil the different research objectives of the
study and each phase of the data collection. Together these methods helped to build a picture
of the field of inquiry and enable an in-depth understanding of the integration of EIA and offsets.
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Figure 4.1 An overview of the methodological strategy: linking the research aim, objectives and data collection phases
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4.4. Research Phases and Methods
4.4.1 Phase 1: Tracking the Emergence of Biodiversity Offsetting in the UK Context Through
Historical Analysis
The first phase of the methodological strategy was based on tracking the origins and emergence
of offsetting in the UK context. This initial phase served two purposes, firstly, to develop the
background and context of offsetting in the UK, and secondly to generate some initial insight
into the consideration given to EIA in introducing and designing offsetting schemes.
“For every qualitative study, data on the background and historical context are
gathered. This may not be a major part of data collection but at least, in proposing
a particular setting, the researcher gathers demographic data and describes
geographic and historical particulars” (Marshall, 2006:107).
To provide the structure for this first phase, broadly, what can be described as an historical
analysis approach was undertaken. Historical analysis can be simply described as an account of
an event, and understood as a method for discovering what has happened often prior to further
research (Marshall, 2006). Historical analysis is often used to supplement qualitative research
by developing knowledge of the history and context around a specific setting. Qualitative studies
often use historical analysis to establish the baseline or background of the research subject prior
to investigating the primary research objectives (Thies, 2002). In this study, historical analysis
was used to piece together the evolution of biodiversity offsetting in the UK context. Effectively,
this first phase enabled the origins of offsetting to be traced in practice and policy, in parallel,
from the initial use of the term biodiversity offsetting and hybrid offset-compensation schemes
through to draft national policy proposals and formal pilot evaluations. A similar approach was
used by Bonneuil (2015) to develop a genealogy of biodiversity offsetting mechanisms in the
international arena.
In this study, the historical analysis was based on piecing together a chronology of key events in
the evolution of offsetting in the UK context. The primary sources of data were documents,
including grey literature (e.g. Hannis and Sullivan, 2013; Policy Exchange, 2012), policy proposals
(e.g. Defra, 2011; NEWP, 2011; Defra, 2013) and recommendations (Treweek et al., 2009),
academic studies (e.g. Sullivan and Hannis, 2015), and media (e.g. Vidal, 2014; Newey, 2015)
around offsetting proposals in the UK. These documents were also supplemented with insights
gathered from interviewing experts in the field, along with the researcher’s own attendance of
both the CIEEM biodiversity offsetting one-day conference in 2014, and the BBOP: No Net Loss
and Beyond conference in 2014. These various sources were triangulated to establish the origins
and evolution of offsetting in the UK context. The main output for this phase was a clearer
picture of the domain of analysis, the main stages of development of offsets in the UK context,
major players and actors, and understanding of currently consideration of the place of EIA in an
emerging offsetting system.
4.4.2 Phase 2: Charting Expectations of the Integration and Interaction of EIA and Offsets
Through Expert Interviews
Having explored the emergence of offsetting in the UK context, and established any initial ideas
about the relationship between EIA and offsets, the second phase of the research was too much
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more comprehensively map out experts’ expectations around the integration and interaction of
EIA and offsetting using interviews. The integration framework, in Chapter 3.4, provided some
initial indication of the conceptual disconnections between EIA and offsets from the researcher’s
perspective, interviewing experts presented an opportunity to critically assess and expand these
ideas. Therefore, the aim of phase two was to gather wider views on the interaction of EIA and
offsetting and establish a range of possible perspectives on the interaction of these two
mechanism. To establish perspectives on how these two tools could relate, how could offsets
operate within EIA, and what might be the consequences in theory for the achievement of no
net loss of biodiversity (*hereafter referred to as no net loss). In essence, to explore the
development of the thesis topic from the interviewee's point of view, and add the emic
perspective (participants’ views) to the etic perspective (researchers’ views) (Brinkmann and
Kvale, 2014; Marshall, 2006).
To generate wider insight into expectations around the relationship of EIA and offsetting a series
of qualitative semi-structured interviews were employed, with expert practitioners, policy
makers, and environmental NGOs. Newing (2011) argues that as a qualitative research method
the strength of interviews is in:
“Providing background information, generating ideas, context and in-depth
information on participant’s views, perspectives, and motivations” (Newing,
2011:98).
Qualitative interviews are described as deliberative knowledge-producing activities, based on
the idea that through conversations we get insight into other people experiences, views and
feelings (Sliverman, 2005, Brinkmann and Kvale, 2014). Interviews are one of the most widely
applied of social research methods they provide a rich source of detailed qualitative data
relatively easily and are particularly appropriate for the explorative and inductive nature of this
research, (Bryman, 2012; Newing, 2011). By providing access to the wider views and
perspectives of a range actors with experience in EIA and opinions around how offsetting might
operate interviews were considered an ideal methodology to develop a comprehensive picture
of the relationship between EIA and offsetting.
The interviews were conducted between December 2013 and December 2014, a period of peak
interest in the development of an English national offsetting scheme. A number of different
actors and stakeholders were interviewed, including policy makers, practitioners, consultant,
activists, and NGOs, in order to gather as wide as possible range of perspectives. The selection
criteria were specifically designed to focus on ‘experts’, involved in both biodiversity
conservation sector and EIA, rather than solely interviewing a specific group. The interview invite
is shown in Appendix 2. In total 22 interviews were conducted, a breakdown of interviewees by
sector is provided in Table 4.1. The format for the interviews was a flexible semi-structured
design. Semi-structured interviews are outlined by Hewing (2011) as appropriate in situations
where the discussion topics are established but the responses are unknown. While Descombe
(2010) highlights that by adopting a semi-structured approach there is considerable scope to ask
about a range of issues or focus in-depth. Given the often polarized perspectives on offsetting,
having a flexible approach was critical to enable participants to focus on their particular concerns
around the prospective relationship between EIA and offsetting.
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Robson and McCartan (2016) highlight that the most common division of interview questions
include: finding out what people know and finding out what they think or feel. For this research,
the subject of the interviews focuses on what people think, their opinion on the application of
biodiversity offsetting and EIA. The main components or themes of the interviews are shown in
Box 4.1. Broadly, the interview questions focused on the possible utility of the EIA process in
helping to operationalise offsets, any limitations, strengths and weakness around the
connection between EIA and offsetting, and finally any possible implications of using these two
mechanisms together.
The interviews were all conducted over the phone. All interviewees were asked to sign a consent
form (shown in Appendix 3) to agree to the interview being audio recorded. The interview
recordings were then transcribed by the researcher, prior to analysis, and coded using Nvivo
software. A rapid preliminary assessment of the interview transcripts was undertaken prior to
the initiation of Phase 3, while more in-depth analysis took place after all phases of the data
collection were completed. Within the analysis the differences between the types of respondent
were acknowledged. The interview responses were treated as predictions based on previous
experience of EIA and expectations around offsetting and, therefore, were considered
constructed narratives rather than direct experiences (Silverman, 2005). The analysis of the
interview data is provided in Chapter 6. Within the text, the interviewees are anonymised and
referred to solely by number 1-22 in combination with their broad role or position as a policy-
maker(pc), non-government organisation, nature conservation group or environmental interest
groups (ngo), practitioner or expert consultant (pc).
Table 4.1 Breakdown of the Interviewees by Sector
Interview Distribution by Profession
Interviewee Code
Interview Number Number of interviewees
%
NGO Member (ngo) I.1; I.8; I.10; I.11; I.13; I.15; I.16; I.17; I.20; I.22
10 43
Practitioner or Consultant (pc) I.2; I.3; I.4; I.5; I.9; I.19; I.21; I.23 8 35
Offset Broker (ob) I.6 1 4
Policy Maker (pm) I.7; 1.12; I.18; 3 13
Academic (a) I.14; 1 4
Box 4.1 Main Themes Covered in the Interviews
4.4.3 Phase 3: Examining the Integration and Interaction between EIA and Biodiversity
Offsetting in Practice through Case Study Analysis
The third phase of the methodological strategy was to shift away from theoretical expectations,
predictions and policy narratives, and instead to explore how offsetting and EIA are beginning
to work together in a series of case studies. Looking at practice was seen as a means to provide
Role and experience of offsetting
Broad position on biodiversity offsetting
Key challenges for operationalising offsetting and designing offsetting systems
Role for EIA in aiding the operationalisation of offsetting
Advisability and appropriateness of linking EIA and offsetting
Concerns around the incorporation of EIA and offsetting
Opportunities and transformation through integrating EIA and offsetting
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a clearer perspective on the possible implications of connecting EIA and offsetting for the
treatment of biodiversity impacts within planning systems. The remit for this phase of the
methodological strategy was to provide in-depth analysis on the dynamics of the interaction
between EIA and offsetting in practice. An opportunity to test out some of the expectations
around the integration of EIA and offsets outlined in Chapter 3 (3.4) and identified through Phase
2. This phase of the methodology was by far the most extensive, employing multiple research
methods within a broader comparative case study strategy. The outline of this phase has,
therefore, been divided into a series of subsections to provide a more comprehensive picture of
the case study approach taken.
4.4.3.1 Case Study Research
A case study approach was adopted in order to yield in-depth insight into the integration and
interaction of EIA and offsetting. Hartley (2004:323) highlights that case study approaches
should not be described as a single methodology but understood as a distinct “research
strategy”.
“The case study gives the story behind the result, by capturing what happened to
bring it about and can be a good opportunity to highlights a project’s success or to
bring attention to a particular challenge or difficulty a project faced” (Hartley,
2004:323).
According to Hartley (2004) adopting a case study approach will enable the researcher to
undertake a detailed investigation and develop a holistic understanding of complex phenomena,
within its context. Through case studies it is possible to not only see the end result of the
presence of offsetting but also appreciate the story behind the outcome, and the influential
factors and outcomes which produced a certain result.
By employing a case study approach the aim was to develop a comprehensive understanding of
the operation of offsetting in conjunction with EIA, within the context of the UK planning
system(s). Essentially, case studies can be used in this context to yield in-depth insight into the
nature of the connections between EIA and offsetting by exploring ‘live’ examples. Case studies
are also particularly suited to the research context as they are often linked to new research areas
or to extending research in areas where current theory is deemed inadequate (Yin, 2009).
“When the investigator has little control over events and when the focus is on a
contemporary phenomenon within some real-life context” (Yin, 1981:59)
Furthermore, Yin (2009) specifically, links case study research to ‘how’ and ‘why’ research
questions, and therefore, case studies are considered a suitable approach to help establish the
degree and form integration currently occurring between EIA and offsetting in UK practice.
4.4.3.2 Unit of Analysis
One of the fundamental factors in case study research is defining the unit of analysis, the ‘case’.
Ragin and Becker (1992) highlight that the unit of analysis can be anything from individuals to
institutions, events or decision. Therefore, defining the unit of analysis can be particularly
problematic aspect of case study research. Yin (2009) recommends that the unit of analysis
should be related to the way you have defined your initial research question. In the context of
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this research, the research questions are oriented around the investigation of the degree of
integration and type of interaction between EIA and offsets. Both the EIA process and the
application of biodiversity offsetting are associated with the environmental impacts of
development proposals. Individual development proposals are the arena through which the
interaction and integration of biodiversity offsetting and EIA is likely to occur, and were
therefore considered an appropriate unit of analysis. Specifically, both the EIA process and
offsetting will form part of the planning application and analysis process for a development
proposal.
4.4.3.3 Multiple Case Study Approach
In undertaking a case study research strategy there is the option to focus on a single case or
alternatively undertake multiple cases to provide a comparative approach. Yin (2009:60)
highlights that:
“When you have a choice, multiple case designs may be preferable over single cases
designs”.
The benefits of undertaking multiple case study approaches are linked the issue of
generalisability. The replications of the case studies through a multiple case study approach can
build confidence in the findings of the research and increase the external validity of the findings
(Yin, 2009). For this research, the aim and objectives are focused on understanding how the
integration and interaction of EIA and offsetting is taking place, whether and how biodiversity
offsetting being operationalised through EIA. ‘How’ questions, such as these, can only be
answered to a limited degree through a single case study, whereas a multiple case study
approach can be used to try to capture any differences in how EIA and offsetting are operating
together. Therefore, by adopting a multiple case study approach the aim was to look for
difference and cover the diversity of approaches being undertaken. Due to time constraints and
resource availability during the course of the research, it was impractical to include more than
four case studies.
4.4.3.4 Case Study Selection
It is not possible, nor practical, to investigate every case where biodiversity offsetting and EIA
were undertaken together in the UK. Yin (2009) highlights that the chosen case studies can
determine the validity and relevance of the data collected, and consequently the overall success
of the analysis. In adopting a multiple case study approach a robust approach is needed for case
study selection (Yin, 2009). The emerging nature of offsetting in the UK context presented a
particular challenge for cases study selection. Whilst undertaking the data collection, between
December 2013-2014, offsetting was very much a new phenomenon in the UK context and
therefore many the development projects trying to apply offsets were only in the very
preliminary stages. There is also no national register of development projects which have
applied offsets which made the identification of offsetting projects, outside of formal
government pilots, difficult. This problem was compounded by the fact that offsetting proposals,
in the UK, were quite controversial and consequently developers were not always advertising
when they had included offsets in project proposals.
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In order to develop a pool of offsetting projects from which to select case studies, instances of
offsetting were identified through web searches, media coverage, and also through attending
conferences (a full list of all cases is provided in Appendix 4). Additional examples were also
collated through the interviews with experts in Phase 2, and through contacting existing
offsetting scheme operators in the UK. From the pool of possible offset projects, the case study
selection was then based on a number of practical and research factors. A key priority for case
study selection was to first identify developments proposals where the interaction of offsetting
and EIA had occurred. EIA is generally applied only for development with the potential for
significant impact on developments, therefore cases such as the Southmoor offset in
Oxfordshire were excluded.
Practical factors also had to be taken into consideration in the case study selection. Within the
available case studies only those where the development decision and assessment process had
been largely concluded, and ideally where any requirement to offset had been put in place, were
considered appropriate for inclusion in the research. Furthermore, the time limitations of the
research also meant that there was an attempt to select cases which were relatively manageable
in scale. Due to the emerging nature of offsetting in the UK, these were quite restrictive criteria
but necessary to enable a complete picture of the outcomes and implications to be developed.
Furthermore, the research aim is linked to whether and how offsetting can work as a tool for
compensation through EIA. Therefore, as far as possible, the case study selection also needed
to be based on trying to capture any difference in approaches to offsetting, and incidentally any
prospective difference in the way that EIA and offsets were working together. Through Phase 1
of the research a typology of different approaches to offsetting was identified in the UK. This
typology was developed by collecting together a range of information on the key stages of the
development of offsetting in to the UK, their common characteristics, various different drivers,
institutional arrangements in the UK voluntary offsetting context. This typology is shown in
Figure 5.4 and fully explored Chapter 5. The case study selection was also linked to this typology
to try to ensure the research investigated the range of different type of offsetting occurring in
the UK, and therefore the range of possible relationships between EIA and offsetting. As far as
possible cases were selected to represent different types of offsetting being undertaken in the
UK, but this was limited by practical factors and therefore only 3 out of the 4 types of offsetting
occuring in the UK were included in the research.
The final case studies selected included:
Glenkerie Windfarm in the Scottish Borders, a pre-policy biodiversity offsetting scheme
developed and led by a Local Planning Authority (LPA) EO;
Cheddar Reservoir Two in Somerset, a pre-policy biodiversity offsetting scheme
developed and led by a Local Planning Authority (LPA) EO;
The Warwickshire and Coventry Gateway in Coventry, a Redevelopment Master Plan
and part of Warwickshire, Coventry, and Solihull Defra pilot offsetting scheme; and,
Whitehouse Farm a Housing Development in North Tyneside, an ad hoc offsetting
project outside a formal LPA led policy or scheme.
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Box 4.2 Key Criteria for Case Study Selection
4.4.3.5 Case Study Methods
Gillham (2000:20) highlights that the use of multiple sources of evidence is a key characteristic
of case study research as "all evidence is of some use to the case study researcher: nothing is
turned away". Furthermore, Yin (2009) emphasises that by adopting a mixed methods approach
case study approach the researcher can collect a richer array of evidence.
“Mixed methods research forces the methods to share the same research questions,
to collect complementary data and to conduct counterpart analysis” (Yin, 2009:63).
For this research, two main qualitative methods were employed: semi-structured interviews and
document reviews. These two methods were employed in a phased fashion with documents
reviews used first, to build up an evidence base and establish the parameter of offsetting and
EIA in each case. The findings of the documents review were then interrogated through
gathering accounts of the application of offsetting and the EIA process from key actors engaged
in each case via semi-structured interviews.
Document reviews are commonly used in case studies to augment evidence from other sources
(Yin, 2009). The need to extract a systematic account, of the way that offsetting had been
applied and its relationship with the EIA, meant that content analysis was the most appropriate
mechanisms. Holsti (1969:14) offers a broad definition of content analysis as:
“Any technique for making inferences by objectively and systematically identifying
specified characteristics of messages".
The review of documents via content analysis can also be used to portray the “values and beliefs
of participants in the setting” (Marshall, 2006:107). Therefore, in undertaking document reviews
the primary objective of was to build an evidence for the case studies (Yin, 2009), to gather key
information on the degree of integration between EIA and offsetting along with any insight into
the different positions of actors involved.
The term ‘documents’ covers a wide range of different forms: official policy statements,
autobiographies, letters, reports, newspaper articles and company press releases have all been
used in document analysis (Bryman, 2012). For this research, the documents used were those
which contained accounts of how both the EIA and biodiversity offsetting processes had been
undertaken. Broadly, the main documents reviewed in each case included: the Environment
Impact Statement (EIS), particularly the Non-Technical Summary (NTS), Ecology Chapter and any
supplementary action or habitat plans associated with the EIS; the Local Planning Authority
reports on the case were also reviewed this generally including the Ecology Officers report, the
Planning Officers report; any consultation material on the EIS particularly that containing the
views of the Ecology Officers (Eos), statutory bodies, environmental NGOs, and local resident
1. Identifying situations where offsetting and EIA had taken place for the same development project.
2. Identifying case which could encompass prospective difference in approaches taken to operationalising offsetting.
3. Identifying situations where the development decision and assessment process had been concluded, to some degree.
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groups; the decision report and any appeal documents; and finally any individual reports or
material on the offsetting proposal such as metric calculations, site selection or search reports.
A full list for each case study is provided in Appendix 5.
Reviewing the content of a wide range of documents enabled the researcher to build a clear
narrative around how the EIA and offsetting processes occurred in each case and gather insight
into the perspectives on their interaction from EIA consultants, developers, LPAs, and other
stakeholders. Documents provided a key source of information to look at the formal points of
interaction between EIA and offsetting. The content of each document was systematically
reviewed. The approach was not to score or rank documents but to record the content, to
identify part of the story of how offsetting and EIA had worked together, provide evidence of
interactions and outcomes of the inclusion of biodiversity offsetting in the planning application
process, and the opinions on the use of offsetting and EIA together. Essentially, in undertaking
the document reviews in each case the approach adopted was to follow the paper trail which
was left behind by both the EIA and offsetting process (see Appendix 6). However, documents
can be misleading, particularly when used in a stand-alone fashion, and may not show the full
picture of the engagement and outcomes of the interaction of EIA and offsetting. Consequently,
the document reviews were used as the starting point for further investigation through
interviews.
The second method applied in the case studies was qualitative interviews, the advantages of
interviews as a qualitative research method have already been discussed in 4.4.2. In the context
of the case studies, the interviews were conducted with the ‘key’ actors (detailed in Appendix
7) in order to gain a range of different perspectives on the application of offsetting and its
relationship to EIA in each case. The document reviews were often used to identify the key
actors for interviews. Generally, the interviewees for each case included the Local Planning
Authority Ecology Officer (LPA EO), the EIA consultant, the offset provider or broker, a
stakeholder from a local environmental NGO or statutory authority. The interviewees are
generally referred to by their position in the text, e.g. Glenkerie Ecology Officer and an identifier
composed of the case study (Glenkerie – G, Cheddar Reservoir 2 - C, The Gateway – GA and
Whitehouse Farm – W) alongside their interview numbers, as shown in Appendix 7.
The themes discussed in each interview varied depending on the key points identified through
the document reviews for each case. In general, the interviews were based the interviewee
recounting the key events of the case which led to biodiversity offsetting, alongside specific
question were then asked about the point of interaction with the EIA process and how offsetting
linked in with key aspects such as the impacts identified in the EIA, impact significance and the
adherence to the mitigation hierarchy (see Appendix 8). To fully understand the outcomes and
implication of offsetting in each case, and pull together a complete picture of any changes that
had occurred through the presence of offsetting, the influence of offsetting on decision-making
and the final output were also key areas for investigation in the interviews. The case study
interviews were all audio recorded and transcribed.
4.4.3.6 Triangulation of the Case Study Data and Comparative Analysis
In order to triangulate the two different sources of case study data, the primary approach was
to first organise the data into a case study narrative or chronology. Using a chronological
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approach enabled the cross-correlation of the application of offsetting and EIA around key
stages of the planning application process in each case. A sequential approach was developed
to follow the progression of the development proposal in each case, from pre-existing policy
through to the identification of environmental impacts, consultation, decision-making, and
offset delivery (See Appendix 9. for examples). This allowed the cases to be cross compared to
see how and when offsets were initiated, and where interaction with EIA occurred. A summary
of this is provided in Chapter 7.2. However, to undertake the case study analysis a more thematic
approach was adopted.
Hartley (2004) highlights that it is essential to use certain topics, key themes, or central
questions to organise the material thematically rather than simply reporting each case
descriptively, and furthermore to examine the degree to which the data fits into expected
categories. To enable cross-case synthesis and analyse, the approach taken as a framework for
analysis was to explore different forms of connections between EIA and offsets. Connection
were used to build up a picture of different degrees and forms of their interaction and
integration. Firstly, to establish the structural connections one of the basic questions was to
determine when and how offsets and EIA were used together or worked separately in each of
the cases. Specifically, to determine how these two mechanisms interacted, to what degree and
when in the planning application process, and therefore to contrast the different structural
arrangements between EIA and offsets in each case study. After establishing the structural
parameters, the next task was to explore the implications of the interaction between the EIA
and offsets processes the causal connections. Exploring the causal connections was a means to
look at any feedback or knock-on effects of the use of the EIA and offsetting processes together.
More substantive connections were also explored through looking at how both EIA and offsets
engaged with the decision-making process. Finally, delivery connections were also covered in
order to explore how offsets were then implemented and delivered on the ground. Through
exploring these different forms of connection it was possible to build up a cross-case synthesis,
a clear picture of the degree of integration of EIA and offsets and therefore to establish a sense
of the dynamics of their interaction and the implications.
4.5 Limitations to the Research Design
There are limitations to any methodological approach taken, however, it is particularly
important to consider the validity and reliability of the research methods, and the extent to
which the research methods are generalisable. Firstly, in terms of validity and reliability,
Maxwell (1996) highlights that a key concern is the accuracy and the completeness of the data.
In this study, the research design relies heavily on qualitative data methods, on interviews and
document reviews. However, Yin (2009:103) points out that: “documents must be carefully used
and should not be accepted as a literal recording of events that have taken place”, and therefore
cannot be taken as containing the unmitigated truth. Equally interviews must, of course, be
regard as a refraction of reality based on the perspectives and position of the interviewees.
Therefore, both interviews and documents are effectively ‘prisms’ through which it is possible
to get some sense of what may have occurred. Documents are often produced with agendas in
mind, for example, some academics have found that the actors producing Environmental Impact
Statements are producing them to achieve planning permission for their clients (e.g. Cashmore
et al., 2008). Therefore, the agenda behind the production of documents, and also the various
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interviewees need to borne in mind when analysing the data and a critical viewpoint must be
maintained (Yin, 2009).
The preconceptions of the researcher are equally liable to influence the interpretation of the
data, possible bias must be acknowledged, and a systematic approach applied in order to try to
minimize the effect of research bias (Robson, 2016). Hartley (2004) highlights that case studies,
in particular, are often claimed to suffer from issues with bias, lack rigor, and reliability.
Therefore, efforts must also be made on the behalf of the researcher to ensure to ensure that
the evidence is reported fairly (Robson, 2016; Yin, 2009). A systematic approach has been
adopted to the collection of information, as outlined in section 4.4.3, to try to ensure a
transparent and reliable approach has been taken.
Another common criticism of case studies is that of generalisability (Yin, 2009). A multiple case
study approach has been taken in order to combat some of the issues around generalisability.
Flyvbjerg, (2006:12) also recognises that: “formal generalization is overvalued as a source of
scientific development, whereas the force of the example is underestimated”. As an exploratory
study, the focus of this research is trying to expand and acknowledge the interaction and
integration of EIA and offsets rather than develop universal theory.
Case studies are acknowledged to be extremely challenging endeavors, and a particularly time-
consuming methodology (Yin, 2009). The abundance of materials produced for planning
applications and the multiple actors involved means that a key limitation was the restricted time
and resources available in the research timeframe. It is possible to get lost in reviewing too much
material, therefore effort was made to focus on only the key actors involved and the key
documents for review, in order to collect the most relevant information to answer the research
objectives.
4.6 Conclusion to the Methodology Chapter
This Chapter has presented a three phased approach to the research design, outlining a
qualitative mixed methods approach to examining the integration and interaction of EIA and
offsetting in the UK context. The research design relies heavily on two main methods:
documents review and qualitative semi-structured interviews. The results of the three-phased
research design are presented subsequently in Chapters 5, 6 and 7.
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5. Tracking the Emergence of Biodiversity Offsetting in UK Planning
System(s) and English Environmental Policy
5.1 Introduction to the UK Offsetting Context
In Brazil, Chile, China, Mexico, Pakistan and South Africa, offsetting schemes are formulated
around existing EIA regulations (Doswald et al., 2012). Alternatively, in countries such as Canada
and Australia, offsetting is linked into existing habitats legislation, or new offsetting and
compensation related legislation in Colombia and Mexico (Doswald et al., 2012). This research
is being undertaken in the UK context where offsetting is currently voluntary and very much an
emerging phenomenon, without a set or defined relationship to EIA (see Chapter 4.3). The remit
for this Chapter was to trace the development and evolution of biodiversity offsetting in the
context of UK environmental policy and planning. In order to outline how offsetting has been
interpreted in the UK context, and determine the extent to which EIA has been connected, both
implicitly and explicitly, with offsetting policy proposals and emerging practice. Therefore, this
Chapter summarises the background and context of offsetting in the UK and highlights any
consideration of the relationship between EIA and offsets in an emerging offsetting policy
context.
The approach taken to develop an understanding of the background and context of offsetting
for this research can be broadly described as an historical analysis approach, as outlined in
Chapter 4.4.1. Through developing a timeline of key events the intent was to track the
emergence of biodiversity offsetting in the UK, from early origins through the emergence of
formal policy discussion to the present context for the research (see Figure 5.1a and 5.1b).
Exploring what has happened prior to the research provides a means to establish the key driving
forces, actors, challenges and areas of contestation around offsetting, and enables an
appreciation that a number of different ‘types’ of offsetting are currently operating in the UK.
This Chapter is divided into two main sections, first looking at key events in the early origins of
offsetting, and secondly, recent policy proposal and formal government experiments with
offsetting schemes. The contents of this Chapter has primarily been sourced from articles,
media, and reports, complemented by insight from conferences, workshops, and supplemented
with some primary data collected from interviewing key actors in the burgeoning UK offsetting
arena between 2013-2014 (for details see Chapter 4.4.1).
5.2 Origins, Predecessors and Early Conceptualisations
5.2.1 Environmental Compensation (1980s+)
The term ‘biodiversity offset’ was described, in Chapter 2, as a planning tool which seeks to
account for the remaining residual impacts of developments, by quantifying biodiversity losses
and providing a mechanism through which losses can be compensated off-site to achieve no net
loss of biodiversity (Chapter 2.4.1). ‘Biodiversity offsetting’ is generally thought of as a new term
promoted by the Business and Biodiversity Offset Programme (BBOP) since 2004 (ten Kate et al.,
2004; BBOP, 2012a), based on uploading ideas from US wetland mitigation banking for the
international agenda (Maron et al., 2016). Offsetting is also often closely related to the term
‘environmental compensation’, a European term which is defined similarly to offsets as the
provision of positive environmental measures to offset, balance, or otherwise atone for the
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adverse environmental impacts of some action (Chapter 2.4.2; Cowell, 2000; Rajvanshi, 2008).
Although offsets are perceived as related to compensation, even conflated in some instances
(e.g. Persson, 2013), pains have been made to outline the distinction between offsetting and
compensation. Distinction between these two terms can be made based on the idea that
environmental compensation lacks many of the specificities of offsetting, such as taking a
measured approach and the aspiration of no net loss (e.g. Dickie et al., 2013). Chapter 2.4.2
highlighted that offsetting can be thought of as an extension of traditional forms of
environmental compensation, bringing in a specific, stronger form, or subset of the broader
concept of environmental compensation. For the origins of offsetting this connection to
compensation highlights that rather than being an entirely new aspect of English environmental
policy and practice, downloaded from international policy, offsetting can also be considered to
have some pre-existing origins or predecessors in the UK context.
The foundations of conservation and biodiversity policy in the EU environmental policy are
widely acknowledged as the Directive 79/409 on the conservation of wild birds, adopted in 1979
(hereafter ‘Birds Directive’) Directive 92/43 on the conservation of natural habitats and of wild
fauna and flora, adopted in 1992 (hereafter ‘Habitats Directive’). The development of these
Directives was influenced by the factors such as the Bern Convention on the Conservation of
European Wildlife and Natural Habitats, and the European Commission’s obligations arising
from the 1992 Convention on Biological Diversity (CBD). Together these Directives instigated the
establishment of the EU-wide Natura 2000 ecological network of protected areas by member
states, this site-based approach was based on safeguarding against potentially damaging
developments and maintaining or re-establishing a sufficient diversity and area of habitats. Both
Cowell (1996) and Cuperus (1999) emphasise that environmental compensation was largely
introduced in the UK through these directives and in relation to the Natura 2000 network,
specifically via the EU Habitats Directive.
Rather than adopting a strict, absolutist, position to protected areas the Habitat Directive,
included the clause:
“In the absence of alternative solutions, a plan or project must nevertheless be
carried out for imperative reasons of overriding public interest, including those of a
social or economic nature, but the Member State shall take all compensatory
measures necessary to ensure that the overall coherence of Natura 2000 is
protected” (EC Directive 92/43/EEC, 1992, Article 6(4)).
The inclusion of the concept of compensation in the Article 6 (4) of the Habitats Directive was
effectively intended to work as means through which development on protected areas could
still be permitted in conditions of ‘overriding national interest’, as long as the overall coherence
of the network could be maintained through compensation. The inclusion of environmental
compensation in the Habitats Directive reflects the rise of sustainable development which
advocated the creation of win-win situations for economic development, society and the
environment and an attempt to move away from the perception of development and
conservation as in conflict (MacDonald, 2010). Table 5.1 shows examples of the early uptake of
the compensation clause in the UK. However, the shift from an absolute protectionist position
was also negatively perceived as a loophole by the environmentalists (Cowell, 1997, 1996), a
means for developers to circumvent the Directive.
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Table 5.1. Examples of Compensation Project for Impacts on Natura 2000 Sites (Cowell, 1997)
The concept of maintaining overall environmental coherence is clearly very similar to the
aspiration of achieving overall no net loss of biodiversity through biodiversity offsetting (see
Chapter 2.4). Table 5.1 also indicates that central principles and concepts of offsetting such as
equivalence and like-for-like exchanges of habitat losses and gains were already in use through
compensation (Chapter 2.6). Therefore, the presence of compensation in the Habitats Directive
shows that very similar concepts to offsetting where being used in UK planning practice in the
1990s. However, the EU Habitats Directive was not the sole origin of compensation in the UK.
The concept of environmental compensation also has origins in the EU EIA Directive
(2011/92/EU). Article 5 of the EU EIA Directive (85/337/EEC) included an early formulation of
the mitigation hierarchy, and states that “a description of the measures envisaged in order to
avoid, reduce and, if possible, remedy significant adverse effects” should be included in the EIS.
The option to remedy impacts effectively enabled the inclusion of compensation approaches in
the EIA process as a means to ameliorate impacts. However, exactly what ‘‘remedy’ refers to in
the EIA Directive was unclear and therefore compensation approaches could have a much
broader remit than under the Habitats Directive. Unlike the Habitats Directive, compensation
has simply been interpreted as a ‘positive environmental measure’ to remedy environmental
impacts (Cowell, 1996; 1997). Consequently, Cowell (1996) identified at least three different
interpretations of compensation: (1) maintaining on-site nature conservation values; (2)
contributions to strategic environmental enhancements; and, (3) community compensation.
Therefore, the inclusion of compensation in the mitigation hierarchy, through the option to
remedy impacts, effectively expanded the concept of compensation beyond the physical
maintenance remit set out in the Habitats Directive. The effect of this alternative
conceptualisation can be seen through studies such as Boucher and Whatmore (1993), Ennis et
al. (1993) and Thompson et al. (1997) who suggest that in contrast to the examples given in
Table 5.1 compensation has largely been associated with securing public open space,
maintaining landscape value and aesthetic issues. Compensation through the EIA directive is not
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based on what is lost but what is easy to put in place. Furthermore, a recent review of EIA
practice in the UK highlighted that:
“Whilst practitioners are clearly capable of identifying opportunities for
environmental improvements that could be generated as a result of development,
specified actions to enhance the environment are rarely seen in UK EIA practice. The
reasons behind this are that developers often see environmental enhancements as
additional costs to the development without necessarily seeing direct benefits”
(IEMA, 2013:68)
Compensation, in relation to the EIA Directive, appears to be perceived as an additional cost or
burden for developers in relation to EIA, and its uptake has remained limited, often restricted
to large industrial developments, or associated with impacts on Natura 2000 sites.
Environmental compensation is a clear precursor to offsetting. Through option to remedy and
compensate for impacts, some of the broad principles and aspirations of offsetting are already
used in conjunction with the EIA practice in the UK. Compensation has been at the forefront of
policy to tackle ecological impacts, included in the EU Environmental Liability Directive
(2004/35/EC) and the Natural Environment and Rural Communities Act (NERC, 2006). Despite
the existence of compensation, since the 1990s, policy attempts to promote environmental
compensation have reportedly remained largely unsuccessful, and low uptake from developers
means that compensation remains relatively rare in UK practice (IEMA, 2011). Furthermore,
compensation is used quite differently under different EU environmental policy Directives and
hence appears to be quite a nebulous term, linked to quite different interpretations. Therefore,
compensation, as a precursor to offsetting, already has a quite convoluted legacy in the EIA
context. The existing context contains multiple perspectives and interpretations of
compensation, occurring in parallel, and split perspectives around whether compensation is a
loophole or burden for developers. Nevertheless, the pre-existing use of compensation provided
a launch-pad for the first offsetting ‘type’ schemes in the UK.
5.2.2 Hybrid Environmental Compensation-Offsetting Schemes (2000+)
In the UK, early practice of offsetting-like schemes emerged in the late 2000s, prior to interest
in developing a national offsetting scheme, in the form of two independent schemes developed
by Local Planning Authority (LPA) Ecology Officers (EO or EOs), one in the Scottish Borders and
another in Somerset (Box 5.1). The creation of both schemes were reportedly motivated by an
inability to account for pressure on a specific aspect of biodiversity within the current planning
system and EIA format (Tharme and Aikman, 2012; Somerset County Council, 2014). The
Somerset County Council (SCC) scheme was reportedly inspired by US wetland mitigation
banking, focused on accounting for landscape connectivity impacts on European Protected
Species (EPS) by developing a quantitative measure of impact (SCC, 2014). In comparison at the
Scottish Borders:
“We had a situation where there was no effective way of putting in habitat
management on-site, due to the biodiversity risk to black grouse caused by wind
turbines, so this posed a bit of a problem but it wasn't grounds for a refusal. What
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we really wanted to do was to achieve the habitat outside the development site.”
(Scottish Borders Council Ecology Officer pers comm).
Whilst the Scottish Borders scheme was developed as a ‘grass roots’ solution to the pressure of
a plethora of renewable energy proposal impacting upland habitats, linking un-mitigatable
upland impacts into funding for landscape-scale restoration projects (Tharme and Aikman, 2012;
Davies, 2013).
Neither of these schemes initially employed the term biodiversity offsetting, however, both have
subsequently been acknowledged as offsetting approaches (SCC, 2016; Davies, 2013). These two
early offsetting schemes directly reflect the split perspectives surrounding the nature of
environmental compensation. In some cases, a highly specific form of direct physical
compensation, Somerset, and in others a looser interpretation of compensation for landscape
benefits and financial contribution to general conservation, Scottish Borders. In Somerset, the
focus on high value, protected biodiversity, and the maintenance of environmental coherence,
reflects pre-existing ideas around compensation under the Habitats Directive. Whilst the
Scottish Borders focus on using offsets to develop financial contributions to landscape scale
restoration schemes, is much more reflective of more flexible conception of compensation as a
‘positive environmental measure’.
Box 5.1 Hybrid Compensation-Offsetting Schemes
These two schemes show that the development of offsetting in the UK context was not entirely
policy initiated but also had independent grassroots origins in innovative Local Planning
Authority (LPA) led schemes. The development of these early compensation-offsetting schemes
appears to have been driven by pressure on a specific element of biodiversity, and an inability
to account for these issues under the pre-existing parameters of planning systems and EIA. Early
offsetting schemes in the UK can be linked application of offsetting as a ‘fix’ or new solution to
deal with a specific impact on biodiversity through the planning system, rather than a desire to
develop new markets for biodiversity. Both of these early schemes generated offsetting as an
innovative solution, and clearly perceive offsets as a bottom-up, positive and proactive means
to make a difference for biodiversity, through improving of EIA and the planning system.
These two schemes illustrate the offsetting has not just been downloaded into the UK context
from international practice, but also effectively evolved from grass roots innovations and
pressure on biodiversity. However, these schemes also present quite different pictures of the
possible formulation and value of offsetting. This echoes the influence and split nature of early
forms of compensation which was used as a tool both for physical compensation or more
generally to facilitate financial contributions. In turn, this results in offsetting schemes with very
Scottish Borders Council’s Renewable Energy and Biodiversity Offsetting Initiative: “The initiative was developed
to compensate for impacts on biodiversity arising from major renewables developments to derive additional
multiple benefits and to help ensure no net loss of biodiversity through development” (Scottish Borders Council
Ecology Officer pers comm).
The Somerset County Council Habitat Evaluation Procedure: “The Habitat Evaluation Procedure can be an
important process for ensuring no net loss of important ecological resources as a result of development. To
demonstrate ‘no net loss’ the value of the habitat needs to be clearly defined, through a calculative approach, and
the methodology transparent and measurable” (SCC, 2014:7).
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different functions and purposes in relation to EIA and the planning system and tailored to very
different ecological concerns and outcomes for biodiversity.
5.2.3 Initial Interest in Offsetting the English Environmental Policy Arena (2007+)
Parallel to the development of early offsetting like schemes, a number of English institutions,
including the European Commission (EC), English Political Parties, the English Department for
Environment Food and Environmental Affairs (Defra), statutory environmental agencies such as
Natural England, Industry and environmental NGOs, began to take interest in the idea of
developing an English national offsetting scheme (I.8(ngo)). In 2007 Defra expressed intentions
“to explore new policy options including market creation in biodiversity, developing incentives
for biodiversity such as biodiversity offsets” (DEFRA, 2007:13). A move likely to have been
inspired by a wider international developments and mainstreaming of environmental valuation,
ecosystem services and market-based approaches, through the Millennium Ecosystems
Assessment (2005) and the establishment of The Economics of Ecosystem and Biodiversity
(TEEB) initiative in 2007 by the G8+5 countries. Interest in offsetting mechanisms was also
connected to lobbying by newly created offset brokers, the Environment Bank (Latimer and Hill,
2008; Briggs et al, 2008), along with international mainstreaming, and promotion of the
biodiversity offsetting mechanisms by the Business and Biodiversity Offsetting Partnership (ten
Kate et al., 2004; BBOP, 2012a).
In promoting offsetting the early policy interest and narrative was very much based on the
conceptualisation of offsetting as a Market Based Instrument (MBI) (Defra, 2007). Offsetting also
appeared in the Lawton Review (2010), an independent assessment of the state UK wildlife sites,
which recommended the development of offsetting as a means to finance landscape-scale
conservation. For actors such as the Environment Bank the drive to promote offsetting was not
just motivated by the use of offsetting as an MBI but also linked to a disillusionment with what
the existing English planning system, and EIA, delivers for biodiversity, much like the schemes
outlined in 5.2.2 (e.g. Latimer and Hill, 2007; Environment Bank Chairman pers comm).
Therefore, with the advent of government interest, ideas around ecological motivations for
offsets and the use of offsets to fix the planning system began to be joined by more economic
rationales, particularly the perceived benefits of pricing nature. However, within these early
statements of interest there is also recognition that offsetting can be a risky approach, which, if
applied incorrectly, has the potential to also be used as a licence to trash biodiversity (Defra,
2007; Lawton Review, 2010).
Proactive investigation into a possible national offsetting scheme was heralded by Defra
commissioning a scoping study into the design and use of offsetting in the English context. The
study, by Treweek et al. (2009), catalogued the growing range of rationales around offsetting:
to arrest biodiversity decline, to create economic incentives for conservation, to streamline the
planning system, and to provide clarity on compensation for developers. Treweek et al. (2009)
also outlined the main parameters of introducing offsetting, such as the need for operating
principles to ensure offsetting would not work as a licence to trash, and systems to enable
payments for offsets. The scoping study concluded that the English context was favourable for
the development of offsets, based on ideas that there are existing structures from which
offsetting could easily be developed. Furthermore, the study acknowledged that there are
several possible mechanisms for operationalising, including the biodiversity duty, the
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incorporation of offsets into agri-environment schemes, or simply requiring no net loss to be
demonstrated by all planning applications.
Among the options outlined by Treweek et al. (2009) was the possibility of adding an explicit
requirement to offset for unavoidable residual impacts into the EIA directive. Treweek et al.
(2009) suggested that through identifying residual impacts the EIA process could work to help
trigger offsets, but there could also be a number of potential points of tensions between these
two mechanisms. Specifically, Treweek et al. (2009) highlighted that the offsetting process could
potentially conflict with the existing EIA process as it does not currently use a consistent and
quantified approach to impact assessment and mitigation.
“Although it is straightforward in theory to add the requirement for EIA to the
standard EIA mitigation hierarchy, there is little guarantee under the current system
that offsets would be delivered in practice” (Treweek et al., 2009:83).
Furthermore, there was also concern that EIA may negatively affect offsetting due to existing
issues with practice. However, the narrative around the interaction of EIA and offsetting was not
entirely negative. There were also suggestions that the presence of offsetting could bring
greater scrutiny to existing mitigation practice within EIA (Treweek et al., 2009). On the whole,
this initial exploration of an offsetting scheme for the UK suggested that there was considerable
uncertainty around the possible role for EIA in the operationalisation of offsetting.
In general, English policy and practice were considered favourable for the development of
offsetting by Treweek et al. (2009). However, in concluding Treweek et al. (2009) placed
considerable emphasis on the need for substantial work to understand ‘when and how’
offsetting would work within the planning system. Therefore, offsetting remained very much in
its infancy, an idea rather than a concrete policy proposal. Both Treweek et al. (2009) and Lawton
et al. (2010) concluded that to fully understand the potential of offsetting they required more
data through piloting.
5.2.4 Offsetting as a Tool for Corporate Social Responsibility (2007+)
The emergence of policy interest in offsetting in the late 2000s and early 2010s was
accompanied by two voluntary demonstration projects, orchestrated by proactive developers-
consultant partnerships: Thameslink developed by Network Rail and Parsons Brinkerhoff and
Bardon Hill Quarry developed by Aggregate Industries UK Ltd and SLR Consulting. In these
projects, offsetting was not legally required as part of planning permission but adopted as a
voluntary initiative after planning approval and the completion of the Environmental Impact
Statement (EIS). For the Thameslink project, Network Rail adopted a voluntary net gain target
(Baker, 2014a; Baker and Woodley, 2013), applying the draft Defra offsetting metric set out by
Treweek et al. (2009) as a means to quantify net biodiversity losses and demonstrate the
achievement of net gain. The application of the metric was guided by Natural England and
resulted in a voluntary offset (Baker, 2014a, 2014b). At Bardon Hill quarry site, the application
of the draft Defra offsetting metric was completed voluntarily by Temple et al. (2010) as a
retrospective means to evidence the effectiveness of their mitigation scheme. In essence, the
use of offsetting was to demonstrate that the developer-consultant partnership had gone
beyond and above practice.
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In these early cases, the application of offsetting, appeared to be as a means to demonstrate or
improve sustainability credentials, a form of corporate social responsibility (CSR) for developers.
Using offsetting for this purpose is certainly not unprecedented. BBOP, the multi-national
organisation which has been promoting the adoption of offsetting (ten Kate et al., 2004),
regularly leverages offset commitments through voluntary net gain agreements with large
multinational mining corporations (BBOP, 2009b). Additional benefits of offsetting were also
reported by actors involved in these voluntary offsets. By putting a tangible figure on
biodiversity the draft Defra offsetting metric was also used as a point of communication with
colleagues, to demonstrate achievement and leverage commitments from executive boards
(Baker, 2014, 2014b; Baker and Woodley, 2014). Effectively, the Defra offsetting metric was
reported to also work as an engagement, communication, and management tool. Despite the
largely positive reflections, these trial applications of the Defra metric also highlighted
weaknesses with the technical aspects or the metrics, particularly surrounding habitat classes
and codes, area factors (Baker and Woodley, 2014).
5.3 Formal Policy Proposals, Experiments and Expansion
5.3.1 Initial Offsetting Commitments in English Environmental Policy (2011+)
The Natural Environment White Paper (*hereafter NEWP, 2011) provided a platform to formally
launch offsetting in English environmental policy, committing to piloting offsetting to investigate
the parameters of a possible voluntary approach (NEWP, 2011:22:2.41). Within the NEWP
(2011:22) the coalition government (2010-2015) depicted offsetting as:
1. A strategy for tackling the continuing impact of land use change on biodiversity levels,
2. A means to pool resources for ecological benefit and expanding the existing network of
protected areas,
3. A method of making the management of impacts simpler and more cost-effective for
developers.
Throughout the NEWP an underlying justification for offsetting was also linked to improving the
English planning system. Much of the rational and evidence base for offsetting, commissioned
Defra studies by David Tyldesley and Associates (2012) and Withers (2012), focused on exploring
the effectiveness of the pre-existing planning policy for biodiversity. Broadly, these studies
reported that planning policies are currently failing to deliver on aspirations to protect
biodiversity, or support and encourage the provision for habitat restoration and creation
(Withers, 2012:4), reflecting ideas in the early hybrid offsetting schemes and Treweek et al.
(2009). By developing this evidence base Defra tried to outline a justification for the introduction
of offsetting based on the idea of a broken planning system, not delivering for developers or
biodiversity.
This critique of the planning system was linked into a wider spectrum of planning reforms,
undertaken by the 2010-2015 coalition government, to overhaul the English planning system,
condensing 1,300 pages of policy into a 59-page National Planning Policy Framework (NPPF,
2012). The political stance underpinning this move was based on deregulation and a pro-growth
agenda, reducing perceived barriers to development and introducing a presumption in favour
of sustainable development. Deregulation was accompanied by decentralisation (Localism Act,
2011), a role-back of state funding and a move towards privatisation, within a wider context of
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austerity policy which underpinned the 2010-2015 coalition government’s tenure. Offsetting
was positioned as a means to complement this agenda, a win-win market-based solution for the
dual challenges of boosting economic growth and environmental sustainability (Defra, 2013).
This politicisation was thought to have shifted the focus of offsets:
“The original idea of offsetting was hijacked. It was originally going to be about
ecology and biodiversity but since the economic crisis hit itss all about developers”
(UK Expert Ecological Consultant: I.9(ngo))
For many actors and stakeholders, government interest has effectively diverted offsetting from
its original biodiversity based rationales (e.g. Lawton, 2010), towards the dominance of a more
economic agenda as a MBIs and a means to streamline the planning system to enhance growth.
This switch in focus has led some NGO members to describe the coalition government’s
influence as “poisonous” (I.10(ngo)). There has clearly been a shifting focus from ecological,
economic and planning-based justifications which has clouded the rhetoric around offsetting.
The original ecological focus of early offsetting schemes now competes with discussions of cost-
efficiency and developer benefits. The formalisation of offsetting based on this economic
narrative is linked to a loss of support from the conservation sector, increased level of suspicion,
and opened up offsetting to a wave of criticisms from NGOs such as FERN and Friends of the
Earth (FOE) as a permit for permission and more seriously the commodification of nature (e.g.
FOE 2013, 2014). Furthermore, the shift towards economic rationales appears to also have
somewhat divided the policy narrative of offsetting from emerging practice (5.2.2). Actors
engaging with the offsetting for the first time in 2011 were presented with multiple rationales
for offsetting which characterised its early evolution in the English environmental policy context.
5.3.2 Experimental Government Pilot Schemes (2012-2014)
The NEWP (2011) also signalled the coalition government’s intention to conduct pilot schemes,
as the first step towards developing a national policy. By 2011 Defra published guiding principles
for offsetting, focusing on the development a local level schemes which would not change
existing levels of protection, and yet also be straightforward, transparent, and value for money.
Attempting to cast offsets as a win-win solution for both developers and conservationists. By
2012 Defra had also formalised a draft offsetting metric, drawing heavily on the work done by
Treweek et al. (2009) and inspired by an Australian habitat hectares’ approach (Parks et al.,
2003; Figure 5.2). The establishment of a provisional offsetting metric enabled Defra to launch
the pilots and formally test the potential of offsetting in the UK. However, key details and
parameters of how the pilot schemes should operate remained unspecified. Therefore,
decisions on critical aspects of in the design of the offsetting schemes, such as what would
trigger an offset, what counts as no net loss and what local means, were left open for
interpretation in each piloting area (Pilot Ecology Officer Pers comm).
The formal piloting period ran from 2012-2014 and involved six pilot areas: Warwickshire,
Coventry and Solihull; Devon; Essex; Greater Norwich; Nottinghamshire; and, Doncaster. A
preliminary evaluation of the pilots, by Collingwood Environmental Planning (CEP) and the
Institute of European Environmental Policy (IEEP) (2013) outlined that:
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“A wide range of ecological, procedural and spatial planning expertise appears to
be necessary for the delivery of the offsetting strategy, but no universal governance
structure has emerged to date” (CEP and IEEP, 2013:2).
The pilot schemes were relatively unsuccessful in generating a generic or universal system and
informing how a potential national offsetting scheme could work. Instead, the pilots were
reported to have applied a range of different governance structures and frameworks (CEP and
IEEP, 2013; I.12(pm), I.22(ngo)) and, therefore, provided only a limited indication to
stakeholders as to how a national offsetting scheme would work. Some commonalities were
however picked out through the preliminary evaluation of the pilots. Commonly, developing
offsetting schemes was found to require a range of different organisations. Certain principles of
offsetting were found to be particularly challenging e.g. ‘in perpetuity’. Furthermore, the CEP
and IEEP (2013:3) report also suggested that, in many of the pilots, offsetting was being used to
deliver existing biodiversity and green infrastructure strategies, and therefore that offsets are
perhaps more of “an evolution rather than a revolution”.
Figure 5.2 Defra Biodiversity Offsetting Metric (Defra, 2012)
Score for habitat and distinctiveness to give the number of biodiversity units lost per hectare
Multipliers Units X Delivery Risk (Low (1), Medium (1.5), High (3), Very High (10))
Units X Spatial Risk (0, 2, 3)
Units X Time discounting (3.5%)
One of the most significant findings from the preliminary evaluations was that none of the pilots
made considerable progress in implementing offsetting during the piloting period (EAC, 2013;
CEP and IEEP, 2013). This lack of progress was widely attributed to the voluntary nature of the
scheme (CEP and IEEP, 2013; EAC, 2013; I.6(ob); I.9(pc)), and indicates that under these formal
pilots the application of offsetting was perceived as an additional burden by developers rather
than jumped on as a permit for permission. The sluggish development of the pilots was also
attributed to the difficulties in adapting offsetting to the local level, lack of resources, and the
limited applicability of offsetting (I.12(pm); I.20(ngo); I.22(ngo); EAC, 2013; CEP and IEEP, 2013;
2016). In the post-piloting period, a number of the areas are still employing offsetting, notably
Warwickshire, Devon, and Essex.
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Table 5.2 Defra Biodiversity Offsetting Pilot Schemes
Area Interpretation of biodiversity offsetting
Devon: The Devon pilot is composed of three projects, each exploring different aspects of
offsetting. South Devon prioritises offset design to benefit priority habitats and
two key species. The North Devon UNESCO Biosphere Reserve focuses on priority
habitats and aims to also offset for loss of ecosystem services provided by these
habitats. Exeter and East Devon Growth Point focuses on how offsetting can be
used to meet the objectives of the GI Strategy (Natural Devon, 2015).
Doncaster: During the pilot, Doncaster Council offered developers the choice of whether they
would like to provide compensation through an offsetting scheme or via the
traditional negotiations that take place during the planning process (Doncaster
Metropolitan Borough Council, 2016).
Essex: Essex County Council will be working closely with The Environment Bank and the
Mineral Products Association. Our offsetting strategy is guided by the Living
Landscapes Initiative, established by Essex Wildlife Trust (Essex County Council,
2012).
Greater Norwich: Mechanism to ensure adequate compensation for residual loss (biodiversity
offsetting) are being developed through the Greater Norwich Growth Board
(Greater Norwich County Council, 2013).
Nottinghamshire: The habitats which should be created or restored through offsetting are drawn
from the Nottinghamshire Local BAP. To ensure that the habitats are correctly
located, Natural England’s National Character Area approach will be followed
(Nottinghamshire County Council, 2012)
Warwickshire,
Coventry, and
Solihull:
The Warwickshire, Coventry, and Solihull biodiversity offsetting is an important
part in the delivery of the sub-regional Green Infrastructure Strategy
(Warwickshire County Council, 2016).
5.3.3 Ad-hoc Offsetting Projects (2012+)
Parallel to the pilots there were also a number of attempts to cross-cut the policy development
process and unofficially apply offsets prior to formal policy proposals (between 2012-2014),
some examples include:
Lodge Hill, Residential, Kent (Withdrawn);
Smithy Wood, Motorway Services, Sheffield (Pending);
South-Moor, Residential, Oxfordshire (Approved);
Rodborough Fields, Residential, Gloucestershire (Re-Applying);
Whitehouse Farm, Residential, North-Tyneside (Approved).
Although the emergence of offsetting varies between these different projects some
commonalities can be established. These ad-hoc attempts at offsetting have largely been
applied for residential developments. The impacts that offsets were applied for varied between
the projects, but in three of the cases offsets were applied for impacts on high-value biodiversity,
a Site of Special Scientific Interest (SSSI) at Lodge Hill, and ancient woodlands at Smithy Wood,
and a nature reserve at Rodborough fields.
“The most disturbing aspect of the whole affair [Lodge Hill] is the degree to which
leading players in the emergence of biodiversity offsetting were quick to latch on to
the commercial opportunity created by a planning authority needing a quick fix, and
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their readiness to take leave of the guiding principles about how the system should
be applied” (Woodfield, 2013:65)
In these three cases the impacts are associated with habitats which under both international
best practice (BBOP, 2012), and Defra’s emerging rules and principles (Defra, 2011), should
potentially be excluded from offsetting. The use of offsets for high-value or irreplaceable
biodiversity is criticised as offsetting working as effectively as a ‘licence to trash biodiversity’ by
undermining existing levels of biodiversity protection, and has been repeatedly warned against
in the Lawton review (2010), Treweek et al. (2009) and Defra (2011) (See also Chapter 2.5).
Attempts to apply offsetting in these cases generated considerable controversy, campaigns and
protests (Wilson, 2013; Woodfield, 2014; Sheffield and Rotherham Wildlife Trust, 2014; The
Woodland Trust, 2016).
Although the use of offsets for these projects has so far not been approved (see list above),
these opportunistic attempts to apply offsets for high-value biodiversity demonstrates the
propensity for the misuse of offsets, particularly outside of formal LPA led offsetting systems,
from very early stages of national system development in the English context (Woodfield, 2014).
These are potentially only early missteps and could be considered a product of a lack of clarity
on boundaries or the limits to offsets, and the definition of ‘significant residual impacts’. Yet,
they also confirm existing fears that offsets are perceived as a ‘permit for permission’ by
developers, and that offsets could work as a licence to trash.
However, this trend is not universal, as it is equally true that in some of these projects the use
of offsetting has also been driven by less valuable biodiversity or Biodiversity Action Plan
habitats as outlined as appropriate by Treweek et al. (2009) (e.g. Whitehouse Farm and
Southmoor). The opportunistic application of offsets in this ad-hoc manner presents a quite
different picture to that offered by the early hybrid schemes and the Defra pilots. The decisions
on these projects will help to define the ‘limits to what can be offset’, and the direction of any
UK offsetting scheme. Despite the fact that they have not necessarily been approved this form
of offsetting has dominated the emerging debate on offsetting, one critical review of offsetting
by Fern and FOE (2014) uses a number of these case studies to illustrate their concerns.
5.3.4 Formal Proposals: Green Paper Proposals and Consultation Responses (2013+)
By September 2013, 6 months prior to the planned completion of the piloting period, Defra had
developed formal policy options in the form of a Green Paper entitled ‘Biodiversity Offsetting in
England’ (Defra, 2013). In the Green Paper, Defra focused on a number of key principles,
including following the mitigation hierarchy, developing a transparent and consistent system,
ensuring local offsetting and applying a simple and standard metric. These principles were all
based on an underlying rational that offsets should help to streamline the planning system to
unblock development and enable conservation (Defra, 2013).
The language and narrative used throughout the GP is noticeably developer orientated:
"The political agenda in the UK is very clearly about using offsetting as a way of
speeding up the planning process and allowing more intensive development in
certain areas with offsets located in areas where land is cheaper. This is no secret
as there are references to 'increasing net developable area' and 'increasing the land
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available for development' and to 'unblocking' larger housing developments in
government documents" (Sandra Bell, Friends of the Earth, quoted in Vidal, 2014).
The narrative of Green Paper suggested that Defra is interested in offsetting but only as part of
a green growth agenda, in that they aimed to achieve no net loss of biodiversity but in a manner
that would also streamline the planning system with little additional cost or impact to the
developer.
The Defra proposals provide some indication of the possible parameters of a national offsetting
scheme, outlining a clear commitment to a voluntary approach and a simple habitat based
metric (Defra, 2013). However, most of the design parameters for the prospective national
scheme remained open for discussion in the GP, and there was no mention of a prospective role
for EIA. For example, the GP begins to outline restrictions for irreplaceable habitats but does not
explicitly state that offsets could not be used for protected sites (Defra, 2013:5.6-5.7). Leaving
considerable scope for interpretation of the meaning of ecological contingency factors such as
‘significant residual impacts’, ‘additionality’, ‘equivalence’ and ‘no net loss’. Therefore, the GP
was much more of a consultation document than a formal policy proposal, and Defra appeared
to be effectively using the GP to try to understand abstract principles such as ‘irreplaceability’
and ‘in perpetuity’.
Furthermore, some of the ideas outlined in the GP were somewhat conflicting. Firstly, the GP
advocates adherence to the mitigation hierarchy and ensuring offsetting does not undermine
existing policy and protection of biodiversity (Defra, 2013:3), but then, paradoxically, just a few
pages later suggests that offsetting can help to unblock development and possibly enable larger
development footprints (Defra, 2013:6). Likewise, the GP also suggests that one purpose of
offsets is to account for residual impacts which are currently ignored by the existing system, but
suggests that this will come at no extra costs to developers. As one NGO member summarised:
“I think that was the intention behind it but it wasn’t wholly clear, or particularly
well explained how it would work in reality” (I.20(ngo)).
Therefore, the GP did develop some parameters of a prospective English offsetting system
(Figure 5.3) but failed to resolve questions and concerns about how an offsetting scheme could
operate in principle and in practice.
Figure 5.3 Integrating Biodiversity Offsetting within the Planning System (Defra, 2013)
Plan-Making Stage
Use the metric to identify
high value biodiversity
areas and inform land
use planning.
Development Control
Stage
Consider residual harm in
terms of biodiversity
units and agree whether
additional steps should
be taken.
Decision Making Stage
Planning permission is
then subject to securing
an offset, and the
implementation
requirements form part
conditions.
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5.4 From Proposals to a Polemic (2013+)
The GP proposals generated a large-scale debate in the conservation sector, with some 460
substantive responses to the consultation from the public, conservation organisations,
environmental NGOs and activists, industry representatives, practitioners and experts (Defra,
2016). The debate around offsetting appeared in national media outlets, blogs and academic
papers (e.g. Sullivan and Hannis, 2015; Monboit, 2012, 2013; Winder, 2013, King, 2013),
generating counter-forums, inquiries and conferences (e.g. BBOP No net loss and Beyond
conference, June 3rd-5th 2014, London, Nature is NOT for sale, Biodiversity Counter-forum, June
2nd 2014). The dynamics of this debate encompassed both absolute positions, rejecting
offsetting policy based on the ethical arguments around the intrinsic value of nature (e.g.
Monbiot 2012; Fern 2013; Fern and FoE, 2013), alongside more nuanced pragmatic positions
focused on the urgent need to achieve no net loss of biodiversity and a willingness to explore
the potential of offsetting (Bull, 2015; Newey, 2014; The Wildlife Trusts, 2014; RSPB, 2013; Briggs
et al., 2010; Hill and Gillespie, 2008). In relation to how offsetting will operate as part of the
English planning system, there were two key distinctions between the arguments and positions
around offsetting which are fundamentally based on whether or not offsetting could help to ‘fix
the broken planning system’.
The logic of introducing offsetting policy to fix the planning system was considered misplaced
for some NGOs, practitioners and biodiversity experts:
“The main problem with the current planning system is not a lack of policy or
legislation but a lack of implementation” (I.20(ngo))
Rather than offsetting acting to fix the planning system, one of the main arguments against
offsetting was that existing problems need fixing prior to the addition of new policy, such as the
current poor record of implementation, compliance and adherence to the mitigation hierarchy
(I.11(ngo); I.19(pc)). With one interviewee arguing that if the planning system, policy and
legislation were all implemented properly then there would be no need for offsetting (I.13(ngo)).
The key point for this argument was that weaknesses in the current system influence our ability
to achieve offsetting. The idea that, at present, the English planning system is not particularly
good at protecting designated sites and species, was used to suggest that the current context is
ill-equipped to deal with more complex systems of offsetting (I.11(ngo)). Instead, offsets were
seen as a ‘get out clause’, or lifeboat, which would do little to actually remedy the problems with
the planning system. There were also questions about the institutional capacity of the planning
system and Local Planning Authorities (LPA) to cope with offsets, particularly whether there is
the right level of ecological expertise and capacity in LPAs and the absence of a strong statutory
body. These institutional challenges were linked with the potential for a lack of quality control,
enforcement and consistency in offsetting, and, more expressly, no ability to challenge what
developers were putting forward in terms of offsetting (I.11(ngo)).
Alternatively, disillusionment with the performance of the current planning system was seen as
the basis for applying offsets:
“I’m not sure whether the people who are criticising offsetting are aware of the
consequences of the status quo” (I.3(pc)).
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“I think there are genuine academic questions around the current system just not
working, but the big push in recent years has come from industry” (I.11(ngo)).
Those who saw offsets as a solution focused on the idea that, at present, the planning system
does not achieve no net loss, and instead residual impacts are largely ignored. Particularly, ideas
that protected sites and species are relatively well regulated, beyond this point there is nothing
to address wider losses of common biodiversity (Baker, 2014; The Wildlife Trusts, 2014; RSPB,
2013; I.1(ngo); I.8(ngo); I.9(pc)). These were often frontline environmental restoration charities
and practitioners, such as the RSPB and the Wildlife Trusts, involved in fighting against the
attrition of biodiversity levels at the planning application level.
The advantages of offsetting were strongly wrapped up in ideas that biodiversity decline is not
just caused by large scale losses but also ‘death by thousand cuts’ (Lawrence, 2010). This gap in
the English planning system is where they saw a role for offsetting, as a means to help planners
to take into account the environmental values of relatively low value sites.
“Offsets send a signal to the planning system that residual impacts on wildlife, you
can’t just shrug your shoulders and say oh well – which is basically the system at the
moment” (I.4(pc))
These proponents emphasised that the presence of offsetting could generate change by pushing
funds towards biodiversity conservation, and help to change perceptions regarding low level
biodiversity impacts (I.4(pc); I.1(ngo); I.8(ngo); I.9(pc)). In helping to account for these flaws,
offsetting was thought in theory to be able to provide a better deal for biodiversity, based on
the right mix of legislation, monitoring and enforcements.
A key component of the use of offsetting to fix the planning system was tied to the idea that:
“Rather than shooting biodiversity offsetting down outright (unless we offer a
realistic and superior alternative) I suggest we work out how, where and when it
can best be used to benefit nature” (Bull, 2015:1).
Essentially, as outlined in the literature review (Chapter 2.6) in operationalising offsetting the
success or failure of offsetting was seen as dependent on the detail of the scheme adopted, as
outlined in the Literature Review Chapter 2.6. Almost every expert interviewed emphasised the
need to operate offsetting under the right principles, parameters, or ‘checks and balances’. The
precise parameters of offsetting schemes became a central preoccupation of the national
debate, perceived as crucial for the success of offsetting.
Some of these principles, or ground rules, for a national offsetting scheme were largely agreed
upon (Sullivan and Harris, 2015), with the majority of experts interviewed stressing the need for
a mandatory system, rather than the voluntary one outlined by Defra, to provide support for the
Local Planning Authority and ensure developer participation (EAC, 2013). Equally, the proposed
Defra metric was widely lambasted as too simple to reflect complex habitats and ecosystem
connectivity (EAC, 2013), and critiqued for not including species (I.3(pc); I.11(ngo); I.20(ngo);
I.22(ngo)). However, other parameters remained open for debate. In particular, ecological
contingency factors such as how offsets should be triggered (thresholds, lists, levels of
significance), where they should be located, and what counts as equivalence. At present, it will
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be down to the political value judgements of planning inspectors to decide how offsets should
operate (I.11(ngo)). In relation to operationalising offsetting as part of the planning system there
was also clear consensus among NGO members interviewed that offsetting should feed into a
national scale biodiversity framework, in order to make individual offsets ecologically
meaningful (I.1(ngo), I.5(pc), I.8(ngo), I.10(ngo), I.11(ngo), I.13(ngo)). Without strategic planning,
the majority of interviewees thought that offsets would become an end of the pipe measure,
used simply to account for failures in the planning system.
5.5 Current State of Play: Offsets Out of Action?
The debate around both the principles and parameters of a prospective national offsetting
scheme resulted in an Environmental Audit Committee (EAC) inquiry into offsetting in 2013. The
EAC is a government select committee, made up of Members of Parliament, which considers the
extent that the policies and programmes of government departments and non-departmental
public bodies contribute to environmental protection and sustainable development. The EAC
inquiry concluded that Defra needed to wait for the full evaluation of the pilots to be complete,
potentially re-think their proposals and develop a more considered approach to offsetting (EAC,
2013). Since the EAC inquiry there has been a distinct lack of progress on the development of
the Defra offsetting scheme.
“Defra confirmed, in a 2014 correspondence with BSG ecology, that ‘there are no
plans at this stage to announce a way forward on offsetting’” (BSG Ecology, 2014:1).
The GP appeared to produce a gridlock of views around offsetting, technical dilemmas and
media backlash, this combined with a change in the Defra minister for the Environment in June
2014, appears to have switched Defra’s offsetting proposals from full steam ahead to an abrupt
halt (Milne, 2014).
The promised full independent evaluation, CEP and IEEP (2016), of the pilot schemes was quietly
published by Defra two years later than planned in January 2016. The evaluation highlighted a
number of key findings related to the governance, process and management, legal and
development planning, costs and ecological implementation and monitoring of the pilots. The
pilot evaluation provides some crucial early analysis and insight into the design, implementation
and operationalisation of the offsetting in England. The evaluation outlines the critical role of
the pilot hosts, who not only provided the leadership and momentum for the scheme but also
crucial ecological expertise, and developed core offsetting strategies which provided the focus,
principles and design parameters for each pilot. The hosts were also tasked with defining key
terms such as in-perpetuity and outlining preferred locations for offset. The pilot evaluation had
particularly notable findings in relation to the Defra offsetting metric. Despite some complaints
about accuracy of the metric, the evaluation highlighted that pilot hosts thought that the Defra
offsetting metric was generally beneficial for the planning application process. Specifically, the
metric was thought to have “provided a quantified, consistent transparent and simply process”
(CEP and IEEP, 2016:4) to biodiversity impact assessment. The Defra metric was also thought to
enable the planning process to account for a wider range of impacts than current practice, and
generate improvements in on-site mitigation and compensation.
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The evaluation also reported that early engagement between LPAs and applicants was
considered key to ensuring that the metric was used to achieve these benefits, and that early
application would better enable the application of biodiversity offsetting. However, the
evaluation also highlighted that the pilots were hampered by the voluntary nature of offsetting
in England, and there was, in general, a perception that national policy was not sufficient to
require offsetting for lower value habitats. Consequently, implementation was largely found to
require explicit reference to and inclusion of offsetting in local policy, or a particular
interpretation of the definition of significant harm. In contrast with Defra’s aspirations the costs
of offsetting were found to be higher than current practice, due to their higher standards and
the requirement to fund long term management. Moreover, costs were often uncertain due to
a lack of knowledge of the cost of restoration.
Due to the relatively low level of biodiversity activity within the 2 year pilot the evaluation largely
reported on the use of the metric, governance, process and strategy arrangement, identifying a
number of barriers, risk, challenges, costs, potential benefits surrounding offsetting, as well as
recommendations. Overall, the independent evaluation concluded that:
“Whilst biodiversity offsetting has the potential to deliver improvement in
biodiversity outcomes it will require additional resources and ecological expertise in
local authorities to deliver it. Where residual biodiversity loss is identified offsetting
will increase costs overall for development compared to current practice. It is likely
that it would at best deliver only marginal benefits in terms of streaming the
planning process for agreeing compensation for biodiversity loss” (CEP and IEEP,
2016: 6).
The pilot evaluation findings suggest that the application of offsetting is not the easy and cost
free solution that Defra had hoped for, with much more limited benefits than Defra had
idealised.
Since 2014, the formal policy proposals appear to be on hiatus. The GP focus on streamlining
the planning system and developer benefits appears to have fallen flat, and the
conceptualisation of offsetting as a ‘licence to trash’, appears to have gained more traction in
the media than the idea of offsetting as a tool for no net loss (Ferreira, 2014, 2015). Despite the
lack of a clear policy direction, offsetting remains in action. A number of the pilots are still
operating, alongside the pre-existing compensation-offsetting approaches in the Scottish
Borders and Somerset, as well as the ad-hoc application of offsets often facilitated by the
Environment Bank (The Environment Bank, 2016; BSG Ecology, 2015). Therefore, offsetting
appears to be continuing without the government’s stamp of approval. Effectively, Defra have
left the door open for offsetting in a way which has enabled its continued use but without any
clear direction or consistency. However, the hiatus on offsetting policy could be short lived.
Looking to the future, the prospective EU No Net Loss Policy Initiative (IEEP, 2013) could restart
offsetting discussion in the UK.
5.6 Chapter Conclusion: Emerging Offsetting Practice and Policy Polemics
Tracing the emergence and evolution of offsets in the English context reveals a number of
divisions between the theoretical debates, policy narratives, and emerging practice. Firstly,
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taking a historical analysis approach suggests that offsets are not actually entirely new, the
concepts that underpin offsets have been around, in UK planning practice, since the 1990s.
Furthermore, this Chapter shows that development of offsetting, in the UK, has not just been
prompted by top-down government policy interest in market incentives, but also by pre-policy
bottom-up approaches linked to biodiversity pressures and disillusionment with the planning
system.
Through exploring the development of offsetting, in the UK context, it is also evident that there
are a number of different forms of offsetting occurring in practice, reflecting different
institutional arrangements, motivations, driving actors, and relation to policy proposals. The
broad divisions between these types of offsetting are shown in Figure. 5.4 (p106). Some of these
forms match up with concerns that offsetting will work as a licence to trash, particularly the
project-by-project application of offsetting linked to high value biodiversity (5.3.3). However,
early hybrid compensation/offset LPA led schemes and offsets for Corporate Social
Responsibility purposes, bare much less resemblance to the conceptualisation of offsets as a
licence to trash. Therefore, debates around offsetting may be focusing on certain ‘types’ of
offsetting rather than the full picture. Furthermore, the variety of different forms of offsets
makes absolute positions on offsetting hard to reconcile with the complexities of current
practice and could explain some of the highly diverse positions on offsetting outlined in 5.4.
Variability and flexibility are currently key characteristics of offsetting in the English context, and
at present offsetting appears to be able to encompass both innovative award winning schemes
and also acting as the ‘devil in disguise’.
There is no collective or universal approach to operationalising offsets in England. Looking across
the different approaches to offsetting in the UK context shows the potential for a wide range of
ways that offsetting can operate within planning systems, from intentional systematic LPA-led
schemes to informal project-by-project offsets. Equally, offsets can require new policy or be
used to enforce existing policy. Furthermore, offsets can operate at very different stages in
planning systems, retrospectively after planning permission or within the planning application
process. These different forms of offsets can be driven by different principles and actors from
developers to consultants, to LPA Ecology Officers or offset-brokers. The question of why, when
and how offsetting will operate is clearly a challenging one, which the GP and consultation on
offsetting has done little to solidify.
There appears to have been little explicit consideration of the role of EIA in emerging practice
and policy developments around offsetting in the UK context. However, the existing
compensation context, into which offsets will be introduced, is already convoluted. The
dynamics of existing compensation practice in the UK suggests that offsets may introduce a
much more specific or stricter approach. Compensation has historically been considered both a
burden for developers and a loophole by conservationists. Early hybrid offset-compensation
schemes highlight that offsets have perhaps been used to account for inadequacies with current
EIA practice, whilst the use of offsets for Corporate Social Responsibility (CSR) suggest that
consultants have found offsets to be a useful environmental management, communication, and
engagement tool, with the potential to add value to the EIA framework. In particular, the final
pilot evaluation (CEP and IEEP, 2016) suggests that there is considerable potential for the metric
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to have beneficial effects on the planning application process, and prospectively therefore also
for the EIA process.
Treweek et al. (2009) is the only study to really explore the potential connections between EIA
and offsets in any significant detail. This study suggests that EIA could play a role in offsetting
practice though identifying significant residual impact and triggering offsets. Given that the
limits to offsets remain open for interpretation in English offsetting proposals the EIA framework
may also work as a key forum for discussion of the appropriateness of offsetting. However, the
narrative around the role and relationship between EIA and offsets is not entirely a positive one,
and highlights that their relationship should perhaps be treated with caution. Treweek et al.
(2009) were particularly concerned with the prevailing poor performance of EIA in relation to
offsetting but did not explicitly spell out what poor EIA practice could mean for offsets.
From exploring policy and emerging trends in practice it appears that although EIA could be
relevant in operationalising offsets, integrating offsets within EIA could also be challenging. The
exact role for EIA in operationlising offsetting remains undecided. The diversity of types of
offsetting practice in the UK means that a vital part of the case studies will be to capture some
of this variability and assess how offsets, EIA, and the planning system will work together, under
different rationales and approaches to offsetting. The selection of the case studies, analysed in
Chapter 7, has therefore been based on trying to capture the different types of offsetting
outlined in Figure 5.4. However, the remit for the next Chapter is to, first, further expand on
ideas around the utility of EIA, in helping to operationalise offsetting. In order to investigate the
split perspectives and concerns outlined in Treweek et al. (2009) around how offsetting and EIA
will operate together.
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Figure 5.4 Typology of Forms of Offsetting Taking Place Across the UK
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6. Exploring Expectations surrounding the Interaction of EIA and
Biodiversity Offsets
6.1 Introduction to the Chapter
The remit for this Chapter was to comprehensively map out expectations around the
interactions between EIA and offsetting, using the findings of 23 semi-structured interviews with
expert practitioners, policy-makers and NGOs members. Offsets have been portrayed as a
subset of the paradigm of impact assessment, and the EIA process as an obvious vehicle for the
integration of offsetting into existing planning systems (BBOP, 2009a; Race and Fonesca, 1996).
However, an early scoping study concerning the parameters of a possible national English
offsetting system highlighted that there are also questions about the advisability of linking up
EIA and offsetting (Treweek et al., 2009). Through analysing the perspective of experts in a series
of interviews, the aim was to more fully assess perspectives on the possible interactions,
disconnections, tensions and implications of any connection between EIA and offsetting.
To catalogue the interaction between EIA and offsets this chapter is divided up into the three
major sections. First, section 6.2 catalogues perspectives on the practical utility and prospective
role(s) for EIA in aiding the operationalisation of offsetting. Section 6.3 then outlines the
perceived conceptual divisions between EIA and offsetting, highlighting the interviewees’
perspectives on the possible limitations and constraints surrounding the use of EIA as a means
to operationalising offsetting. Finally, section 6.4 focuses on the implications and outcomes of
linking up EIA and offsetting, providing insight into perspectives on the possible risks, or
unintended consequences, and returns, or unexpected opportunities associated with linking
these two mechanisms. A final synthesis is provided to bring together these ideas and outline a
preliminary model of the integration and interaction of EIA and biodiversity offsetting.
6.2 Practical Utility and Prospective Role(s)
In initiating the interviews, the starting point was to establish the interviewees perspectives on
the basic utility of the EIA process for operationalising offsetting, specifically how EIA is relevant
to offsetting and what role(s)s EIA could play in relation to offsetting. Both the literature review
(Chapter 2.6.4) and the historical analysis (Chapter 5.6) hinted at potentially significant
prospective roles for EIA in offsetting, such as helping to trigger offsets by establish ‘significant
residual impacts’ (e.g. Treweek et al., 2009) or working as a legal machinery for implementing
offsetting (Doswald et al, 2012; BBOP, 2009a). Through the semi-structured interviews it was
possible to delve much deeper into the exact connections and nature of the utility of EIA for
offsetting, to ask whether, why and in what way EIA could possibly be relevant in
operationalising biodiversity offsetting. The following section outlines the range of ways in
which interviewees thought that EIA could help to operationalise offsetting. Please note that the
roles identified are not necessarily mutually exclusive.
Presented with the question as to how EIA and offsetting could prospectively work together, the
opening response of many interviewees focused on the idea that:
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“I think EIA will end up doing is a lot of detail qualitative survey work and then we
will take that and use it in a quantitative biodiversity offsetting metric calculation”
(I.6(ob)).
Practitioners, consultants, policy makers and NGO members all recognised the potential to use
the baseline ecological data, collected through EIA, as a raw data source or input for offsetting
metrics and assessments (I.1(ngo), I.3(pc), I.4(pc), I.13(ngo), I.12(pm), I.19(pc), I.21(pc), I.23(pc)).
A perspective based on ideas that EIA’s strength is as a tool for establishing baseline
environmental conditions and measuring the change caused by developments (Glasson et al.,
2012, Jay et al., 2007). This role for EIA echoes ideas by Coggan et al. (2013) and BBOP (2009a)
that the data for offsetting may already lie within existing EIA practice. The conceptualisation of
EIA as a data source suggests that interviewees primarily identified EIA as a tool to generate,
accurate, scientific data. In essence, interviewees envisaged that the qualitative ecological data
already collected under the EIA process could be readily transformed into quantitative figures
through offsetting metrics. Interviewees considered that offsetting metrics, by quantifying
biodiversity impacts, would be able to tell you something different about the information
already collected within the EIA process, or at the very least transform it into a different format
(I.6(ob)). Based on the semi-structured interviews, a primary part of the utility of EIA appears to
be its practical value as an information source for offsetting. This proposed use of EIA
emphasises a rational perspective on EIA as an analytical science tool which produces systematic
and comprehensive facts to inform correct policy making (Jay et al., 2007; Cashmore, 2004).
The information produced by the EIA process was not only considered as a passive data input
but also as having a potentially more active role:
“A typical example of a trigger for offsetting could be the identification of a
significant residual impact on biodiversity through EIA, caused by a proposed
activity for which consent is sought” (I.4(pc)).
Interviewees also linked the EIA process to the identification of impacts which could be
addressed through offsetting. Impact evaluation within EIA was described as a key route for
catalysing the need for an offset, a means of pointing out the remaining residual impacts after
the application of the mitigation hierarchy (I.8(ngo), I.6(ob), I.4(pc), I.1(ngo)). The prospective
use of EIA as a trigger reflects the general perception of the role and relation between EIA and
offsets in academic, grey literature and guidance on offsetting (e.g. BBOP, 2009a; Treweek et
al., 2009; and Gillespie, 2012). By using EIA as a trigger offsetting would be making use of a
process which already occurs within EIA, and utilising existing information to move beyond the
status quo (I.19(pc), I.12(pm)). However, the impacts which offsets are triggered for is one of
the most controversial parameters of offsetting systems (Pilgrim et al., 2012). There has been
considerable debate on the limits to offsets, what should and should not be offset (e.g. Pilgrim
et al., 2012; Gardner et al., 2013). Working as a trigger for offsets means that EIA could play a
part in some of the key decisions regarding the acceptability and appropriateness of offsetting
(BBOP, 2009a; Wissel and Wätzold, 2010; Underwood, 2011; Quétier and Lavorel, 2011).
Therefore, EIA could have a much more active and crucial role in the offsetting, central to the
initiation of the process and actively working to help determine offset feasibility.
Six interviewees took the idea of EIA having a role in the offsetting process much further:
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“The nuts and bolts of making offsets happen could be through EIA, by extending
offsets from the existing EIA process” (I.17(ngo)).
There were also some suggestions by interviewees that EIA could have more than an input role
into offsetting, and prospectively work more as overarching framework or medium through
which to manage the operationalisation of offsetting. However, exactly what was meant by the
role of EIA as a ‘framework’, and the extent to which the offsetting process could be managed
through the EIA process varied between the interviewees. Some interviewees envisaged that
EIA consultants could include the offsetting metric as part of the ecology chapter (I.6(ob)), and
actively undertake the metric calculations and analysis (I.12(pm), I.21(pc)). The use of EIA
consultants and the EIA process to undertake metric calculations was thought to have the added
benefit of “making the numbers mean something” (I.23(pc)), by ensuring the metric outputs
were understood in the context and value of the site for biodiversity. In this scenario,
biodiversity units would sit side-by-side with estimations of impact magnitude and significance,
a situation which in the UK at least remains untried and untested (I.9(pc)). Other interviewees,
particularly NGOs, envisaged EIA as a “framework to ask the right questions” (I.10(ngo)),
focusing on ideas that by incorporating offsets into the EIA framework this should enable the
offsetting process to be scrutinised through EIA consultation and public participation stages.
Another highlighted that offsets need to be incorporated throughout the EIA process to enable
offsetting to be “borne in mind from day one” (I.21(pc)). Finally, EIA was also outlined as a
medium to help design offsets through habitat management plans and environmental action
plans (I.6(ob), I.21(pc), I.10(ngo)).
When, how and to what extent offsets should be incorporated into the EIA process, and the role
EIA should play, clearly varied between the interviewees. Despite differences in the role
attributed to EIA the connection between these two mechanisms was described as inevitable,
with interviewees highlighting that:
“There is going to come a point that biodiversity offsetting, in whatever shape and
form it is finally introduced, will need to fully engage with EIA” (I.2(pc)).
The inevitability of EIA operating as a management framework for offsetting was linked to
practicality and logistics (I.6(ob); I.9(pc)). EIA already plays an active role in managing and
designing mitigation proposals and helping developer formulate landscape design proposals.
Therefore, connecting offsetting with the EIA process was simply seen as the easiest situation
logistically. Furthermore, linking EIA and offsets was also seen as a means to enable developers
to accommodate offsets efficiently as part and parcel of the overall project planning (I.21(pc)).
Resource availability was also key, with one interviewee suggesting that realistically schemes
need to use EIA consultants to undertake the metric and analysis due to the lack of ecological
skills and resources in Local Planning Authorities (LPAs) (I.9(pc), I.6(ob), I.13(ngo), I.11(ngo)).
In envisaging EIA as a framework for offsetting interviewees were essentially describing a much
more central role for EIA in offsetting, where offsets and EIA would fully be working together.
This perspective was clearly based on envisaging EIA as a much more of an active tool for
environmental and project management. These ideas expand on initial suggestions by BBOP
(2009a) and present offsetting as an easy subset or extension of the EIA process. However, there
is clear variability in perceptions of exactly what role EIA can take as an overarching framework
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for offsetting: with some interviewees perceiving EIA as an analytical tool, others as a forum for
discussion and debate, and other still as a negotiation tool for ‘green gains’, or for adaptive
environmental management.
One final dynamic of the utility of EIA for offsetting was based on the notion that:
“Offsets should first be extended from existing frameworks” (I.7(pm)).
A number of interviewees highlighted that the value of EIA for offsetting was as a means to
embed offsetting in existing practice (I.12(pm), I.3(pc)). Extending offsetting from existing
frameworks, such as EIA, was considered a critical means of aiding the transformation of offsets
from a policy innovation into effective planning practice (I.4(pc), I.21(pc)). Specifically, EIA
represents a well-defined and established institutional building block; subsuming offsets within
the already established and accepted EIA process was seen as a means to help legitimise
offsetting as a valid and effective policy tool (I.12(pm)). The use of EIA in this way was bound up
with ideas of building up acceptability and confidence in offsetting. This perception of EIA as a
clear or obvious legal route through which to integrate offsets into planning practice was
acknowledged by Treweek et al. (2009), and Darbi et al. (2009:168) even suggests that offsets
needs to be first established as a valid approach through EIA before they can be rolled out more
widely.
Overall, the semi-structured interviews strongly support the relevance of the existing EIA
process in aiding the operationalisation of offsetting. The interviewees conveyed a clear sense
of the logistical value of EIA for offsetting, and even that a connection between EIA and offsets
is inevitable. However, the form that this connection would take, the exact role for offsetting,
was much more up for debate with multiple roles for EIA outlined:
1) Data Source: An information input for the offsetting metric.
2) Information Trigger: Means to identify residual impacts which require offsetting and
discuss offset feasibility.
3) Analytical Framework: Medium to not only trigger offsets but also undertake the
offsetting calculation and analyse findings.
4) Management Framework: for managing the whole offsetting process, including design and
implementation.
5) Discussion Forum: An opportunity for offset discussion and debate with stakeholders.
6) Institutional Building Block: A means to embed offsetting in the planning system and build
acceptability and confidence.
The logistical value of EIA in offsetting clearly ranged from quite simple practical roles, with EIA
working as a data input, to much more active roles, where EIA works much more as an
overarching management framework for offsetting, and even ideas about building acceptance
of offsets through connections with EIA.
As shown in Figure 6.1, these different roles, or connections, can be linked to different levels of
integration between EIA and offsetting. For example, EIA is likely to have a minimal level of
integration with offsetting when working as an information input, compared to operation as an
analytical framework for the offsetting metric. However, it must be noted that the range of
different connections between EIA and offsetting were not universally acknowledged. The use
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of EIA as an information source and trigger for offsets was by far the most frequently mentioned,
with fewer interviewees suggesting the application of EIA as an overarching framework or
means of legitimising offsets.
These different roles also highlight quite different perspectives of EIA, some solely perceiving
EIA as a rational tool for information provision whilst others identifying EIA as a more dynamic
tool for adaptive management, deliberation, and negotiation. Therefore, the perspectives of the
actors involved could considerably influence the role EIA plays in offsetting. It is also important
to note that EIA appears to have the potential to connect to some of the most controversial
areas of the application of offsetting, namely triggers, thresholds and limits for offsetting, and
the openness, transparency, and acceptability of offsets. Alongside multiple perspectives on the
potential utility of EIA, interviewees also recognised the conceptual differences between EIA and
offsets which could potentially limit its use value.
Figure 6.1 The Range of Possible Roles for EIA in Operationalising Offsetting
Information Source Management tool
Data Source Information
trigger
Analytical
tool
Discussion
Forum
Delivery and
management
Framework
Institutional
Building Block
1 2 3 4 5 6
Low Degree of Interaction between EIA and offsets High
6.3 Conceptual Divisions and Barriers
Interviewees outlined a wide range of different roles for EIA in operationalising offsetting (Figure
6.1). However, out of the twenty-three experts interviewed only three thought that offsetting
could easily be incorporated into the UK EIA process (I.19(pc), I.6(ob), I.4(pc)). Through
undertaking interviews, it was possible to catalogue a number of conceptual characteristics of
EIA which interviewees thought likely to restrict its usefulness for operationalising offsetting.
This section outlines the key disconnections between EIA and offsetting identified by the
interviewees.
One of the most common concerns of interviewees was that:
“The EIA process is designed to comply with the EIA directive, and that directive is
not based on a system of biodiversity offsetting. It is not aimed at picking up low-
level residual impacts, and the thresholds for EIA kicking-in can be relatively high”
(I.11(ngo)).
A strong principle and underlying ethos of EIA is that it is designed to capture significant impacts
on the environment (e.g. Glasson et al., 2012; Wood, 2003; Jay et al., 2007). This characteristic
means that the EIA process is not universally applied to all developments. Instead, projects with
lower level impacts are screened out of EIA, and the assessment process focuses resources only
on the most significant impacts (Glasson et al., 2012; Wood, 2003). This characteristic clearly
jars with the underlying ethos of offsetting as a tool for low level or common biodiversity, and
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small scale impacts on biodiversity which result in ‘death by a thousand cuts’ (Treweek et al.,
2009; Latimer and Hill, 2007, ten Kate, 2004). Consequently, five interviewees stressed that EIA
could have a strong role but only when relevant, and offsetting needs not to be restricted just
to EIA developments (I.8(ngo), I.5(pc), I.7(pm), I.9(pc)). Others saw this aspect of EIA as
potentially more of a concern and raised questions as to whether EIA would ever engage with
the right level of impacts to work as a trigger or data source for offsetting. This disconnection
between the remit of EIA and offsetting brings into question the idea that offsets are a subset
of the paradigm of EIA. However, there were equally questions raised about how offsetting
would be triggered in the absence of the EIA process (I.2(pc)).
Furthermore, EIA is generally described as a decision-support or decision-informing tool.
Consequently, the EIA process is orientated around the decision-making stage of planning
applications and largely considered complete after the planning application has been decided
(Glasson et al. 2012). However, interviewees highlighted that significant parts of the offsetting
process, such as the critical question of site selection, offset design and the development of
habitat management plans, generally take place after the decision to develop and therefore
after the completion of the EIA process (I.9(pc), I.5(pc)). Moreover, offsetting, as an MBI and
linked to economic valuation, is derived from a contrasting disciplinary approach to much more
multi-disciplinary EIA. The different orientations of EIA and offsetting brings into question the
degree to which EIA could be a useful framework for the holistic management of the offsetting
process, reflecting the concerns of ten Kate et al. (2004) and Hayes and Morrison-Saunders
(2007).
Furthermore, as a development management tool the stage at which EIA occurs was also
perceived as potentially problematic for the strategic aspirations of offsetting:
“If offsets are only planned late in the EIA stage, in the approval conditions, it is very
much an end of the pipe measure, this means that offsets will not be considered in
project financing. I think offsets need strategic planning” (I.21(pc)).
For the NGO members interviewed there was a clear emphasis on the need to ensure that
offsets are strategically planned, to enable the full consideration of alternatives and avoidance
and ensure the greatest biodiversity benefits through linking offsets into landscape-scale
conservation (I.1(ngo), I.10(ngo), I.8(ngo), I.13(ngo), I.15(ngo), I.20(ngo)). The narrow site based
remit of EIA has long been criticised. Therefore, the interviewees highlighted a number of
questions about whether EIA operates at the right stage of the planning system to trigger offsets
(I.2(pc)).
The practical utility of EIA in aiding the operationalisation of offsetting was thought to be
significant by the interviewees, with a range of different roles for EIA envisaged and illustrated
in Figure 6.1. However, the interviewees also highlighted a number of conceptual disconnections
between EIA and offsetting. These disconnections confirm ideas identified through the
integration framework (Chapter 3.5) which suggested that EIA is not the perfect framework for
offsetting. These differences bring the role and utility of EIA, as a means to operationalise
offsetting, into question, particularly EIA’s role as a trigger for offsetting and as a comprehensive
management and delivery framework (Figure 6.2).
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Figure 6.2 Updated Potential roles for EIA in Offsetting Reflecting Conceptual Disconnections
Information Source Management tool
Data Source Information
trigger
Analytical
tool
Discussion
Forum
Delivery and
management
Framework
Institutional
Building Block
1 2 3 4 5 6
Low Degree of Interaction High
6.4. Unintended Consequences and Unexpected Opportunities
Alongside ideas around the utility and conceptual compatibility of offsetting and EIA,
interviewees also highlighted a number of possible implications, or knock-on effects, of linking
these two mechanisms. These implications can be divided into two main areas: the possible
unintended consequences or risks, and possible unexpected opportunities or returns. Section
6.4.1 discusses interviewees’ concerns related to knock-on effects of existing weaknesses and
areas of poor performance in EIA practice for offsetting. Highlighting the potential links between
procedural and behavioural aspects of EIA quality and offsetting performance. Section 6.4.2
then details the possible procedural and behavioural opportunities surrounding the integration
and interaction of EIA and offsetting. Highlighting the perspectives of a smaller proportion of
interviewees who also recognised that offsetting could have potential as a catalyst for change
in relation to existing EIA practice.
6.4.1 Risks: Knock-on Effects of Weaknesses in EIA Practice
6.4.1.1 Procedural Risk: Instrumental Issues and Technical Competency
Interviewees were clearly preoccupied with the nature of EIA performance, and whether this
was likely to influence offsetting process and outcomes in some way. The idea that, at present,
EIA “is not done well” was an underlying theme for the majority of the interviewees (I.20(ngo),
I.17(ngo)). Concern about the performance or effectiveness of EIA is by no means a new topic,
and academic research has been on going in this area since the 1980sHowever, exactly how they
could affect the application of offsetting is much more of an unknown.
The idea that EIA could act as a data source or trigger for offsets was suggested to be a key
aspect of its use value in operationalising offsetting, however, both NGOs and consultants also
had reservations about the quality of data produced in EIA and the expertise of EIA consultants
(I.21(pc), I.10(ngo), I.11(ngo), I.5(pc)).
“EIA professionals often know very little about biodiversity and its finer points.
Whilst biodiversity experts or specialist may be unfamiliar with the EIA process”
(I.11(ngo)).
Environmental Impact Statements, or EISs, the formal output of the EIA process, were described
by NGO members as containing only a narrow interpretation of biodiversity impacts such as
direct impacts through habitat loss and were therefore liable to exclude ecosystem components
and connections, and lack an appreciation of the carrying capacity of the landscape (I.9(pc),
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I.10(ngo), I.8(ngo)). There were also suggestions that there is a lack of appreciation of what
critical habitats entail in the UK EIA field, a lack of understanding of what biodiversity priorities
should be, and little acknowledgement that the biodiversity impacts of the project can be quite
unrelated to the project’s physical dimensions (I.5(pc)). The points raised by interviewees
reflected many of the findings from academic research (e.g. Drayson and Thompson, 2013;
Byron, 2000; Slootweg et al., 2012; Treweek and Thompson, 1997).
For interviewees, this limited interpretation and understanding of biodiversity impacts could
mean that data on lower tier and less visible dynamics of biodiversity value, the ideal target for
offsets, may not be available through the EIA process. Furthermore, these ideas challenge the
appropriateness of using EIA results to trigger offsets and the prospective role of EIA consultants
in analysing and evaluating offsetting metrics. However, the extent to which some of these ideas
would affect offsetting is questionable as, to some extent, the Defra metric already focuses on
direct habitat loss as a measure of biodiversity loss (see Chapter 5). Equally, many of these
complaints are likely to stem not from a lack of expertise but because EIA consultants are often
not given the mandate to think ecologically and this gives EIA a bad name.
However, interviewees were not simply concerned about EIA as a data source but more
substantively questioned EIA’s appropriateness as an approach to managing biodiversity
impacts, stressing that:
“EIA is not fit for purpose, it has no modern relevance for managing biodiversity
impacts, it is still relevant for impacts like hydrology or erosion, but biodiversity is
so for outside the scope of modern EIA mitigation and planning requirement it is
almost irrelevant” (I.5(pc)).
One biodiversity consultant suggested that there is a lack of understanding of how to manage
biodiversity impacts to the extent and scale that is needed within the EIA framework (I.5(Pc)).
Complaints about the EIA framework were also linked to the silo-based approach taken in EIA
(I.9(pc)), which was seen as an inappropriate means to understand the threats and pressures on
biodiversity.
“I am not at all happy about how EIA works at the moment, as currently we have a
kind of recipe thing where we look for what are the issues, send out a team of
experts and all of their records get stapled together. I think that is the wrong
approach” (I.21(pc)).
The formulaic and segregated nature of the EIA process was thought to be at odds with
contemporary understanding of biodiversity impacts and management. Furthermore, the
production of Environmental Impact Statements (EISs) were considered by interviewees as more
of a hoop that developers had to jump through for planning permission, an act of going through
the motions, rather than a proactive mechanism for environmental sustainability and
biodiversity management. Interviewees were clearly concerned that the current formulaic
nature of EIA could potentially have a domino-effect on offsetting, and result in offsets simply
becoming another tick-box activity rather than a proactive mechanism to achieve no net loss
(I.10(ngo), I.9(pc)). The evident disenchant with how EIA currently operates brings into question
its potential role as a holistic management and delivery framework for offsetting.
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Linking EIA and offsetting was also perceived as problematic due to issues with the way that EIA
attributes impact significance. Interviewees questioned the use of EIA as a transparent and
appropriate trigger for offsetting based on a perspective that impact prediction and the
attribution of impact significance is “complex” (I.20(ngo)), “contentious” (I.1(ngo)), and a “black
box exercise” (I.10(ngo)). The relationship between impact significance and mitigation was
described as ‘warped’ by one expert consultant:
“When we’re looking at residual impacts I come across with real pie-in-the-sky
mitigation measures, that you know are not ever going to reduce impacts. There is
an assumption that if you give a list of mitigation measures you are within your
rights to downgrade the significance of an impact until it's almost meaningless”
(I.21(pc)).
The possibility for a disproportional relationship between mitigation proposals and impact
significance highlights that, at present, residual impacts could be being underestimated. This
issue with the relationship between mitigation and impact significance could potentially mean
that the EIA would work as an inconsistent trigger for offsetting, and sits in contrast with ideas
that triggering offsets should be an open and transparent process (BBOP, 2012a; Pilgrim et al.,
2012). Not all interviewees agreed with these criticisms, in particular, practitioners highlighted
that significance is much more structured since the CIEEM (2006) guidance. Furthermore, one
interviewee also suggested that more structured approaches such as thresholds and lists are
equally subjective in their construction (I.11(ngo)).
Finally, the embeddedness of the mitigation hierarchy, in current EIA practice, was a key
complaint:
“Whether the mitigation hierarchy is currently applied or not is a moot point”
(I.17(ngo))
The introduction of offsetting has been linked to considerable concern that it could undermine,
circumvent or disrupt the application of the mitigation hierarchy (e.g. Clare et al., 2011).
However, interviewees stressed that the current application of the mitigation hierarchy is
already shaky (I.10(ngo)).
“My case study works indicated that habitat mitigation measures are particularly
poorly implemented and often unsuccessful where they have been implemented”
(I.9(pc)).
Currently, levels of implementation of mitigation measures were reported to be poor, with
discrepancies between mitigation promises and construction realities (I.13(ngo), I.15(ngo),
I.17(ngo), I.19(pc), I.6(ob)), reflecting the findings of Drayson and Thompson (2013). Equally, one
interviewee (I.21(pc)) stressed that existing planning conditions for mitigation are often poorly
written, and thus not auditable or enforceable (also I.19(pc)). However, the application of the
mitigation hierarchy is often intuitive, rather than explicitly stated, and consequently, its
application can be underestimated (I.19(pc)). On the whole, these findings suggest that rather
than undermining the mitigation hierarchy offsets may simply act to make a bad situation worse.
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6.4.1.2 Behavioural Risk: Perverse Incentives and Conflicts of Interest
Concern around connecting EIA and offsetting was also linked to the prospective behaviour of
ecological consultants.
“There is a fundamental problem that ecological consultants write their reports for
their clients, the developers. We consistently see the wilful incorrect interpretation
of ecological data to fit the will of the developer. I would also add that we think it’s
something that is getting worse. EIS are getting bigger and fatter but it’s not better
information” (I.20(ngo)).
A number of NGO members interviewed brought into question the reliability of the data
produced by EIA consultants, citing conflicts of interest and the priorities of ecological
consultants. Interviewees were particularly concerned that consultants are, currently,
perversely incentivised to downplay impacts, to make the developments look more
environmentally friendly for their clients (I.6(ob), I.21(pc), I.11(ngo)). One NGO member, who
regularly reviews EISs, was particularly concerned that this propensity to downplay impact is
getting worse, due to increasing competition, austerity and the decline in power of the UK
statutory environmental agency. There were even suggestions that EISs are increasingly full of
“voluminous words” or “weasel words” which work to reduce the accessibility of impact
communication (I.20(ngo)).
There was also a clear acknowledgement that there are also very good consultants, who
encourage their clients to do the right thing (I.11(ngo)). However, concern surrounding the
neutrality of EIA consultants meant that interviewees perceived the content of EIS as tainted or
bias in some way. For offsetting, this brought into question how much the information contained
in EISs, and produced through the EIA process, can be trusted, and, therefore, whether the EIA
should be used as a data source or trigger for offsetting. Particularly, in relation to EIA’s
prospective role as a trigger for offsetting, these issues were thought to be able to result in
offsets being applied incorrectly, underestimated, or not required at all. Issues with bias also
brought into question EIA’s prospective role as a management framework for offsetting, as they
clearly conflict with ideas that there should be an open and transparent system of offsetting
(I.11(ngo); BBOP, 2012a; ten Kate et al., 2004). On the whole, there was clear concern around
whether the consultants who will be making offsets work are truthful or not, or tilted towards
the misuse of offsets. Evidently, bias, vested interests or conflicts of interest are likely to have a
critical influence over the outcomes of biodiversity offsetting, and its relation to the EIA
framework. Yet, it must also be noted that dividing the offset calculation from the EIA process
was equally perceived as problematic, by one consultant, thought to have the potential to
conflict with the findings of the EIA practitioners and could cause issues if practitioners are
required to adopt the conclusions of the offset metric (I.2(pc)).
6.4.1.3 Risks in EIA Performance for Offsetting
Regardless of offsetting, the quality of EIA has always been an issue, as the EIA directive only
brought in the requirement to have EIA, not good quality EIA. The historic focus on instrumental
rationality in EIA is often used to suggest that there has been an increase in procedural and
technical quality of EIA over the three decades of practice (Glasson et al., 2012; Jay et al., 2007;
Cashmore et al., 2004). However, EIA was described as “weak”, “poor”, of “inconsistent quality”
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and even “rubbish” by interviewees in this study (I.5(pc), I.6(ob), I.9(pc), I.17(ngo), I.20(ngo)).
Complaints about EIA practice derived both from its technical capacity and also issues with the
behaviour of EIA consultants. Throughout this section, the overarching message has been that
interviewees clearly perceive that poor quality EIA could cause poor quality biodiversity
offsetting. Therefore, the interviewees clearly elaborate on ideas briefly mentioned by
Morandeau and Vilaysack (2012) and Middle and Middle (2012), who identified the possibility
that offsets could become part of the existing problems which are already inherent in the EIA
framework. These factors bring into question the logic of using EIA as a data source, trigger, or
management framework for offsetting (Figure 6.3).
Almost all interviewees identified some weaknesses in the EIA framework, however, not all
agreed that these would negatively impact upon offsets. Some interviewees suggested that
offsets were unlikely to be affected. Other interviewees took this idea one step further and
argued that when you have this situation it can go one of two ways: it can either provide an
argument against offsetting, in that we are rubbish at mitigation measures already and we
should not even try, or it could provide an argument for offsetting as a catalyst for change.
Figure 6.3 Updated Potential Roles for EIA in Offsetting After Consideration of Procedural and
Behavioural Risk
Information Source Management tool
Data Source Information
trigger
Analytical
tool
Discussion
Forum
Delivery and
management
Framework
Institutional
Building Block
1 2 3 4 5 6
Low Degree of Interaction High
6.4.2 Returns: Offsets as Catalysts for Change
Alongside ideas that EIA could negatively influence the application of offsetting, interviewees
also envisaged areas where the incorporation of EIA into offsetting could potentially have
beneficial effects, particular for existing EIA practice. These ideas that offsetting could have
beneficial effects were often placed in direct opposition with views on how poor quality EIA
could cause poor quality offsetting. Rather than focusing on existing complaints about EIA, some
interviewees saw opportunities, conceptualising biodiversity offsetting as a mechanism through
which to counteract the poor treatment of biodiversity in EIA, an opportunity to catalyse change.
6.4.2.1 Procedural Opportunities: The Prospective Technical Benefits of Offsetting for EIA
Offsetting, particularly the offsetting metric, was seen as having the potential to positively
influence the procedures and technical capacity of the EIA process. One of the most frequently
mentioned areas was the way EIA captures impacts on biodiversity:
“What became blatantly obvious for me was that biodiversity impacts, in EIA, were
very narrowly interpreted primarily in terms of threatened species and habitats,
very much in a silo, and any effort to reduce impacts so that they became of medium
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or low significance was all that you had to do. For me offsetting kind of says well
you can’t just stop there you have to go one step further than reducing. That is why
I became really passionate about offsetting” (I.21(pc)).
Interviewees suggested that, by requiring consultants to measure the residual negative impacts
on biodiversity, offsetting could improve EIA’s performance for biodiversity impacts through
enhancing its technical capacity for impact identification. Addressing residual impacts would be
a considerable step change in thinking, a shift in the perspective outlined in Section 6.3.
Additionally, a number of consultants argued that offsets may be a better way to implement
mitigation.
“At the moment there is no compensation really going on, mitigation is unchecked
within the site boundary and ineffective” […] “we need to use offsetting as the
mechanism to ensure that compensation gets done” (I.6(ob)).
These ideas were not only linked to developing smarter mitigation linked to landscape
conservation planning but also wrapped up in the notion that offsets could be easier to enforce
and ensure compliance is delivered and combat the ‘mitigation myth’, the separation between
planning promises and construction realities (I.17(ngo)).
The effectiveness of mitigation was not the only area which interviewees thought that offsetting
could improve EIA practice:
“The thing with Environmental Statements is that they are so complex and long
winded and no one actually looks at it. All of the old research done in the 90s showed
that the planners don’t look at it the planning inspectors don’t look at it, just about
the only people who do might well be the statutory consultees” (I.9(pc)).
Interviewees argued that although EISs are considered in planning applications, to be more
effective the EIS potentially needs a new way of presenting information. Translating ecological
information into numerical form was considered a potentially more accessible way to
communicate biodiversity impacts (I.17(ngo), I.12(pm), I.23(pc), I.9(pc)). These ideas reflect
arguments around the valuation of nature as a means to promote arguments for biodiversity
conservation (e.g. MEA, 2005; TEEB, 2010; Costanza and Daily, 1992) and making EIA more
decision orientated (Pischke and Cashmore, 2006). One NGO member stressed that quantifying
ecological impacts could not make EIA practice any worse, given the size and complexity of the
some current EIS (I.9(pc)).
“Numbers help to communicate biodiversity in a way businesses are familiar with
and could readily understand and could transform the typical response of the
business sector to biodiversity” (I.23(pc)).
Furthermore, practitioners placed considerable weight on the idea that developers and
executive boards could react better to numbers than narratives, suggesting that offsetting
metrics could facilitate better engagement between EIA consultants and developers (I.23(pc)).
However, this perspective was by no means universal. Many interviewees also stressed
arguments against the valuation of nature, as highlighted in Chapter 2.4, emphasising that
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planning and ecology are simply too complicated to be easily communicated through a single
figure and highlighted concerns around the pseudo-quantitative approach of the metric.
Whether and how this pseudo-quantitative approach will really make a difference to EIA remains
to be seen (I.17(ngo)).
6.4.2.2 Behavioural Opportunities: Offsetting as a means to influence on the Behaviour of EIA
Consultants
Alongside ideas that offsetting would work as a technical and procedural enhancement for EIA,
there were also indications that interviewees thought that it could positively influence the
behaviour of developers and EIA consultants. Applying biodiversity offsetting in-line with the
mitigation hierarchy has undoubtedly been one of the most discussed and debated aspects of
introducing offsetting, as offsetting is seen as a potential disruption or means to circumvent the
mitigation hierarchy (e.g. Clare et al. 2011). However, one interview stressed that:
“If a proper system for offsetting assessments is developed then this could offer a
useful tool for an applicant and the planning authority to measure the likely impact
of a development, it could also help define avoidance and be used to divert
development away from areas of biodiversity impact” (I.13(ngo)).
The application of the biodiversity offsetting metric was also acknowledged by interviews as
having potential at the strategic level to help identify high-value nature areas and incentivise
the diversion of developer away from these areas. This picks up suggestions by Kiesecker et al.
(2009, 2010) and Defra who saw potential in EIA as a framework to assess different development
options impact on biodiversity (Defra, 2013:3). Moreover, on a site scale:
“Biodiversity offsets aren’t cheap; they send a strong price signal to people to be
more careful about what they are doing in the first place” (I.4(pc))
The extra cost of offsetting was thought by interviewees to have some potential to act as a
deterrent for developers (I.1(ngo), I.3(pc), I.2(pc)). Somewhat paradoxically, the threat of having
to undertake an offset could effectively push developers to go the extra mile towards greater
onsite avoidance and mitigation in order to drive down the additional cost of offsetting.
Effectively, if applied correctly offsetting could help to reinforce avoidance, rather than
undermine the mitigation hierarchy.
Whether offsets would act to generate this behaviour was by no means certain and seen as
highly conditional on having onerous exchange rules for any offsetting system, i.e. high
multipliers or ratios to ensure developers are dissuaded from building on high biodiversity value
sites (I.21(pc)). While other interviewees made clear that there was simply too much potential
profit to be made from development in England for the cost of offsets to incentivise this
behaviour from developers (I.11(ngo)). Furthermore, few interviewees could give evidence of
offsetting incentivising avoidance in practice. Only, one interviewee was able to provide an
interesting example from the French experiments with offsetting:
“They ended up re-writing good practice guidance for all the other stages of the
mitigation hierarchy because they suddenly realised that if the residual offset is
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going to cost us, we need to be much more careful about how we end up getting
there” (I.4(pc)).
The relationship between offsetting and the mitigation hierarchy is by no means set in stone.
Although there are clearly concerns about the influence of the metric on the mitigation
hierarchy there is also some indication of the potential to use the offsetting process to generate
improvements to the mitigation hierarchy, specifically these improvements could be a by-
product of the greater scrutiny brought by the introduction of offsetting.
Not only was offsetting thought to potentially be able to incentivise greater adherence to the
mitigation hierarchy but also to possibly shape consultant’s behaviour by making them more
accountable.
“If consultants have to use the Defra metric then this could bring in a consistent and
empirical way of assessing impacts, by converting them all into biodiversity units”
(I.6(ob))
Interviewees suggested that the use of a consistent methodology, in the form of offsetting
metrics, could work to counteract issues around subjectivity and the perceptions of the
underestimation of impacts, as highlighted in section 6.3. This perspective presents a clear
contrast with the dominant narrative around offsetting which predicts that the use of calculative
measures will largely play into the hands of developers.
Furthermore, through introducing offsetting into EIA this would introduce a more explicit
substantive aim for the ecology side of EIA, in the form of no net loss. The idea of having a
tangible obligation underpinning EIA, rather than just regard for policy, was seen as particularly
advantageous by NGO members interviewed. The advantages of introducing an objective for the
ecology aspect of EIA was linked to ideas that currently the no net loss commitment in the
National Planning Policy Framework is only perceived as the ‘decent thing to do’ not a
requirement for developers (I.10(ngo), I.19(pc)). Introducing a substantive aim through
offsetting was thought by interviewees to potentially be able to act as a limit or red-flag around
impacts (I.21(pc). These interviewees reflect the ideas of both Gillespie (2012) and Vilarroya and
Puig (2010) who also suggest that offsets could improve EIA by introducing an emphasis on
making a choice rather than simply the full collection of information. However, one practitioner
interviewed thought that it would be misguided to say that EIA has to work to a single objective
(I.2(pc)). Moreover, interviewees’ perspectives on whether no net loss of biodiversity was a good
or effective goal varied considerably, and some considered that the aspiration of no net loss
implies ‘perpetual deterioration’ (I.11(ngo), I.22(ngo)), and viewed no net loss as encouraging
the perception that development has not really caused any damage.
6.4.2.3 Transformations of Offsets through Practice: Offsets for Uncertainty, Residual Risk and
Insurance
For two interviewees the way that EIA and offsets might work together remained open to
possibilities, stressing that biodiversity offsetting is still experimental at present (I.2(pc);
I.19(pc)).
“If your level of uncertainty was set so it triggered a certain type of offsetting, then
I could see this as a useful link between EIA and offsets. Particularly, to catch people
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who are trying to take an overall optimistic view, offsetting could provide checks
and balances on uncertainty which just aren’t there at the moment” (I.2(pc)).
It was also possible to envisage new forms of offsetting developing through using EIA and
offsetting together. With two interviewees outlining the possibility to develop conditional
offsets or worst-case-scenario offsets through linking offsets into the level of risk or uncertainty
around impacts (I.2(pc)). This reflects ideas by Middle and Middle (2010), who highlighted new
forms of insurance based offsetting developing in Australian biodiversity banking. The idea of
using the requirement to offsets against high levels of uncertainty was seen as a means to
transforms the conception of offsets from a last resort to a threat which could leverage better
impact prediction and greener development. Although these ideas remain highly theoretical,
they highlight there is potential for new forms of offsetting to evolve in practice, and for offsets
to work with EIA in more intuitive ways to enhance practice and outputs for sustainable
development.
6.4.2.4. Opportunities to Enhance EIA Performance through Offsetting
“Biodiversity offsetting could be tremendously helpful in shaping the whole EIA
process and project” (I.21(pc)).
As summarised in the quote above, the value of integrating EIA and offsetting may not solely be
based on the use or logistical value of EIA in aiding the operationalisation of offsetting. Offsetting
could also shape EIA practice. Historically, the ecological side of EIA has been less quantitative
and more qualitative (Glasson et al., 2012; Rhodes, 2012), in contrast, biodiversity offsetting is
an aggregated decision-making tool which reduces evaluation to a single figure. Both the
pseudo-quantitative nature of offsetting, and its commitment to no net loss of biodiversity, are
at odds with the current operation of EIA. Much of the change that offsets could bring to EIA
appeared to be wrapped up in the pseudo-quantitative nature of offsetting. The offsetting
metric was seen as a means to extend the impacts captured by the EIA process, enhance the
consistency and accountability of impact predictions, and even communicate the findings of the
EIA process in a more persuasive medium. For interviewees, there was clearly considerable
scope in the metric, beyond simply identifying the need for offsets. Offsetting, and the aspiration
of no net loss, was also portrayed as a means to do more for biodiversity, to enhance the
substantive objective of EIA and even act to incentivise avoidance through working as a cost
deterrent. For these interviewees offsetting could potentially transform EIA into a more active
tool for sustainability, more outcome orientated, more engaging and accountable.
However, little solid evidence could be given by interviewees as to whether any of these benefits
were more or less likely to occur, instead the language surrounding this link often contained
questionable phrases such as “it will be interesting to see if it drives change or not” (I.20(ngo)),
“it could be useful in theory” (I.9(pc)), or “it could be tried” (I.17(ngo)). Furthermore, some of
these ideas, particularly EIA operating as a tool to incentivise avoidance, were highlighted as
highly conditional and dependent on ensuring onerous ratios or multipliers in the offsetting
equation (e.g. I.21(pc), I.4(pc), I.8(ngo)). Moreover, almost all of the interviewees questioned
the adequacy and validity of the metric, as a means to measure biodiversity loss, advocating that
the value of ecosystems cannot be simply translated into an excel spreadsheet (I.11(ngo),
I.2(pc)). How the use of the metric may affect and transform our understanding of impacts on
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biodiversity in EIA was clearly a key concern for interviewees. Nevertheless, one interviewee
pointed out that:
“If putting a number on biodiversity is too difficult, then the choice is to keep the
current system, which we already know is failing” (I.23(pc)).
Offsetting was clearly perceived as risk but for some disillusionment with the status quo and the
opportunities to enhance practice clearly outweighed the possible risks related to offsetting.
6.5 Chapter Conclusions
Exploring the expectations around the interaction and integration of EIA and offsetting revealed
that the relationship between these two environmental management mechanisms is by no
means simple; indeed, it is imbued with contradictory ideas around implications. Four aspects
were found to dominate expert’s ideas and expectations around the integration of EIA and
offsetting (summarised in figure 6.4). These include the utility of EIA in helping to operationalise
offsets, the conceptual differences which could limit the connections between EIA and offsets,
the possible knock-on effects of pre-existing weaknesses in the EIA framework for offset
performance and finally, the possible opportunity to use offsets to enhance existing EIA practice.
EIA was clearly acknowledged to be a potentially significant factor in the operationalisation of
offsetting by the interviewees, and the interaction between EIA and offsets portrayed as
inevitable. Therefore, the interviews confirmed that EIA was regarded as having considerable
practical utility in operationalising offsetting EIA was considered to include a range of
prospective roles from working as a prospective data source or trigger for offsetting to an
analytical framework for offsetitng metrics and even a means to institutionalise offsets in the
planning system. The benefits of connecting EIA and offsetting were not only logistical in nature
but also linked to ensuring that offsetting takes place in a transparent manner, and even
associated with building acceptance of offsetting. Evidently, there are a range of ways that EIA
could promote offsetting practice, moreover, some of these roles reprent essential logistical aids
for offsets whereas others represent added value.
Nevertheless, the utility of EIA, in helping to operationalise offsets, was also perceived to be
limited due to conceptual disconnections between these two mechanisms. Specifically,
differences in the way that EIA and offsets relate to decision-making, the impacts they target
and the extent or remit of their interventions, and the stage at which they occur in planning
systems. These disconnections highlight that the compatibility of EIA and offsets is questionable,
and hence also the logic of using EIA to aid the operationalisation of offsetting. EIA is certainly
not the perfect framework for the application of biodiversity offsets.
The interviews also reveal clear concerns that pre-existing issues with EIA performance bring
into question the advisability of integrating EIA and offsetting. There were reservations about
the technical capacity of the EIA process as approach to identify and manage biodiversity
impacts. While the attribution of impact significance in EIA, and therefore the identification of
residual impacts, were portrayed as ‘black box’ exercises, complex and opaque, rather than a
transparent and robust trigger for offsetting. Furthermore, existing reports of poor adherence
to the mitigation hierarchy in EIA, and a lack of implementation of mitigation measures, were
used to suggest that offsets would be adopted into a context that is poorly placed to facilitate
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adherence to the mitigation hierarchy. The idea that EIA is at present not performing well for
biodiversity was clear from the interviews, and moreover poor quality EIA was linked to poor
quality offsetting. EIA was clearly considered as a point of risk for offsetting practice and the
achievement of no net loss by interviewees.
Both issues with the performance of EIA and the conceptual compatibility of these two
mechanims provide a strong warning against the headlong rush to integrate. However, the
separation of EIA and offsets could be equally problematic. Questions arose as to how these two
mechanisms would be artificially separated, how offsets would be triggered in the absence of
EIA, and whether that in the absence of integration these two mechanisms would clash.
Furthermore, some interview could also envisage counterfactual scenarios. Rather than EIA
having an adverse knock-on effect on offsetting performance, the alternative suggestion was
that offsets could also work as a catalyst for change and even improve EIA performance. Notably,
quantitative offsetting metrics were seen as technical improvements for EIA which could
improve the thematic coverage of the EIA framework and even enhance accountability in EIA,
or communicate findings more persuasively. Therefore, offsetting was seen as having
considerable potential to shape the EIA process, and strengthen EIA as a tool for sustainable
development, echoing suggestions of BBOP (2009a), linked to the use of offsetting to ‘fix the
broken planning system’ and disillusionment with the status quo.
Analysing the interviewees perspectives revealed a clear dualism in the relationship between
EIA and offsets. For some interviewees, the focus was on EIA’s relevance, utility, and
opportunities in connecting up with offsets, whereas others identified restrictions,
disconnections and threats. The exact outcomes of integrating offsetting and EIA are clearly
unknown, and, as shown in Figures 6.4 and 6.5 below, there are potentially numerous points
and issues which could shape the interaction, integration and implications of bringing together
these two mechanisms. Although current ideas around implications of integrating EIA and
offsetting are contradictory it is evident that there are likely to be some form of knock-on effects
through bringing together these two mechanisms. However, there was little clear evidence to
support one outcome over another (see figure 6.5). Fundamentally, through exploring expert
expectations it is evident that the integration of EIA and offsets should not be undertaken lightly
and, moreover, their interactions should not be presumed to be neutral.
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Figure 6.4 Summary of Interviewees’ Expectations
Utility EIA working as a:
- Data Source
- Information Trigger
- Analytical Tool
- Discussion Forum
- Delivery and management framework
- Institutional building block
Limitations Conceptual difference between EIA and
offsetting:
-Different target impacts
- Different relationship to decision
making
- EIA is site based - offsetting is
strategic
Risks Procedural Risk
- Lack of Biodiversity expertise
- Poor existing performance of the
mitigation hierarchy
- Formulaic and silo based nature of
EIA unsuitable framework for
biodiversity management
Behavioural Risk
- Communicative distortion, conflicts
of interest and incentives
Returns Procedural opportunities
- Technical enhancement
- More effective mitigation
- More persuasive format for impacts
Behavioural opportunities:
- Cost incentive to reinforce the
mitigation hierarchy
- Increase accountability and
consistency
- Enhance substantive purpose
Operationalising
Offset through EIA:
Expectations
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Figure 6.5 Expectations of the Integration and Interaction of EIA and Offsetting
EIA
Kn
ock
-on
eff
ects
of
po
or
per
form
an
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Off
sets
EI
A Te
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EIA
Imp
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IA
Pra
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Lice
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- Tr
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Gai
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Mak
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De
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EIA
Sign
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Imp
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Fo
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6.6 Preliminary Model of the Relationship between EIA and Offsetting
Based on the findings of this Chapter, three main scenarios or models of the interaction between
EIA and offsetting can be envisaged, and outlined in Figure 6.6. Firstly, there could be no
integration of EIA and offsets based on their conceptual disconnections and the risks arising
from their interaction. Instead, these two mechanisms could be deliberately separated and
offsets could be maintained as an independent approach rather than embedded in existing
practice. However, it is difficult to envisage this detachment being effective when EIA and
offsetting occur in parallel. Furthermore, this separation could create problems for triggering
and informing offsetting. Moreover, detaching offsetting so completely from the EIA process
this could open up tensions between the findings of offsetting metrics and the findings of the
EIA consultants.
Partial integration could also occur. Under a partial approach EIA could work as an information
trigger and data source but would not be actively involved in analysis, design or implementation
of offsets. Taking a partial approach could avoid some of the conceptual disconnections between
EIA and offsets, yet offsets would still be subject to issues with EIA performance associated with
data quality and impact significance. Under this model, offsets would effectively be bolted onto
the EIA process. However, this model reflects the outdated perception of EIA as a rational tool
for technical information provision, as highlighted in section 3 the nature of the data produced
in EIA is not only limited by technical aspects but influenced by the motives and agendas of
consultants and developers who produce EISs (e.g. Bartlett and Kurian, 1999; Elling, 2009;
Cashmore et al., 2008, 2004; Weston, 2000).
Finally, offsets could also be fully integrated into the EIA process as an additional component,
with offsetting becoming an integral part of existing EIA procedures and legislation. Under this
model EIA would not only work as a data source or trigger but also an analytical and delivery
framework. Therefore, offsets would effectively become part and parcel of EIA procedure.
Under the incorporated model, EIA would act as an umbrella under which offsetting could be
pursued, legitimised, negotiated and managed. Although this could mean that offsets would
have the opportunity to catalyse change in the EIA process, and could enable EIA to be a more
dynamic tool for ecological impacts, offsets would equally be subject to issues around
conceptual disconnections and the quality of EIA and expertise of EIA consultants. There could
be greater returns for both tools, but equally greater risk. Of particular note is the fact that EIA
was not designed to achieve no net loss. Therefore, this model requires EIA systems to be robust
and transparent, to ensure that offsets are not used as a licence to trash or buy-off (ten Kate
and Crowe, 2014). Opting to take an integrated approach, and subsuming offsets within the EIA
framework is by no means simple. Figures 6.6 and 6.7 shows how the different dynamics of the
interaction between EIA and offsets could be associated with the various degrees of integration.
Evidently, questions as to what extent and when offsets should be incorporated into the EIA
process is at present unanswered, and remains an open topic for discussion with different ideas
between statutory authorities, planning officers, practitioners and NGOs interviewed. The three
models presented in this section envisage very different relationships between EIA and
biodiversity offsetting, and each bring with it a particularly set of challenges and opportunities.
The case studies present an opportunity to explore the various roles for EIA and to examine the
split perspective around offsetting and EIA in action. For the case studies, the aim is not only to
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identify which connections are present and how limitations and weakness of EIA are affecting
biodiversity offsetting, but also whether and how these models manifest in practice.
Figure 6.6 Model of the Possible Relationships Between EIA and Biodiversity Offsetting
Figure 6.7 Degrees of Integration of EIA and Offsetting
No
Integration Partial
Integration
Full
Integration
Information
Provision
model
Operational
Framework
model
Separate
Offset and
EIA
EIA works as an input for
offsetting, a trigger or
data source
FULLY INTEGRATED PARTIALLY INTEGRATED SEPARATE
EIA
OFFSETS
EIA EIA OFFSETS OFFSETS
Offsets are
undertaken
separately from EIA.
Potential issues with
triggering offsets
EIA works as a framework
for offsetting,
undertaking the
offsetting calculations
and helping to deliver
and implement offsets
High potential risk of
knock-on effects of issues
with EIA performance
Risk of knock-on effects
through using EIA as an
information input
Encompassing offset
within the EIA
framework high potential
for offsets to act as a
catalyst for change
Utility of EIA
Risk of knock-on effects
from EIA performance
Offsets as a means to
enhance EIA performance
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7. Analysing Biodiversity Offsetting and EIA in Action
7.1 Introduction to the Case Study Chapter
The aim of Chapter 7 is to explore the interaction and integration of emerging offsetting
mechanisms and existing EIA practice, within the UK planning and development management
context. Chapter 5 has already demonstrated that the application of offsetting is currently open
for interpretation, with no strict or defined role for EIA promoted in early policy proposals. While
examining expert expectations, in Chapter 6, outlined the potential for a complex and
convoluted relationship between EIA and offsetting, with contradictory perspectives on the
logistical value and conceptual disconnections, risks and returns, of integrating these two
mechanisms. Through examining practice, the remit for this Chapter was to establish the forms
of connections or disconnections which are beginning to take place between EIA and offsetting
in emerging practice, and the main implications manifesting. Effectively, to try to shed light on
the interaction of these two mechanisms by looking at a snapshot of practice, and identifying
whether and how the prospective relationships, as outlined in Chapter 6, are materialising in
practice, under what conditions, and to what end.
The format for this Chapter is based on comparative case study analysis. Taking a comparative
approach provides a means to interrogate any differences in the interaction of EIA and
offsetting. Effectively, to explore how different connections/disconnections between these two
mechanisms play out in practice and capture any range of possible implications. Therefore, the
case study selection was based on capturing some of the different forms of offsetting taking
place in the UK (see Chapter 5, and Chapter 4.4.3.4), to encompass the widest range of possible
relationships in the case studies. In order to account for the focus on ‘difference’, the case
studies are wide-ranging in terms of their type, scale, and context. For each case, a wide range
of data was systematically collected, through semi-structured interviews and document reviews,
and triangulated to establish an overall narrative of how offsetting progressed for each
development and where offsetting interacted with the EIA process. A full list of the documents
reviewed and interviewees can be found in Appendix 5 and 7. Throughout Chapter 7 the
documents reviewed are referred to by the titles shown in Appendix 5.
The cross case study analysis was built around analysing the findings from each case study in
relation to different types of interaction or connections, occurring at different stages of the
planning application process. The main stages of exploration included:
Structural connections (7.2): the sequence of events, steps, procedures, main drivers
and influential factors that led to the development of offsetting, and the role and
relation to EIA.
Causal connections (7.3): the main implications and causal effects of connecting up
EIA and offsetting processes, and the treatment of biodiversity impacts.
Substantive connections (7.4): the influence of offsetting in development consent and
decision-making, the role of EIA or the EIS, and any implications for the treatment of
biodiversity impacts.
Delivery connections (7.5): the translation of offsets into restoration realities, and the
role of EIA or EIA consultants.
126
This Chapter begins with a brief introduction into each case, including the basic parameters and
their wider geographical, regional, and local context, and their links to the typology of offsetting
forms identified in Chapter 5. A broad schematic of the main sequence of events which takes
place is also provided for each case. The main body of text is devoted to exploring the four forms
of connections, outlined above, and the concluding sections provides a summary of the main
findings. The four case studies included:
Glenkerie Windfarm, Scottish Borders, part of a pre-policy hybrid compensation-
offsetting scheme developed independently by a Local Planning Authority.
Cheddar Reservoir Two, Somerset, part of a pre-policy hybrid compensation-offsetting
scheme developed independently by a Local Planning Authority.
The Warwickshire and Coventry Gateway, Redevelopment Master Plan, Coventry, part
of an experimental Local Planning Authority led Defra pilot offsetting scheme.
Whitehouse Farm, Housing Development, North Tyneside, an ad hoc offsetting project.
Figure 7.1 The Geographical Context of the Case Studies
127
Glenkerie Windfarm, Scottish Borders, Scotland (*hereafter Glenkerie)
Glenkerie Case Study
Glenkerie is an eleven turbine windfarm, operational since 2012 (Infinis, 2015). The site is on land east of
Kingledores Farm in the Scottish Borders, situated on an upland ridge between two tributaries of the River Tweed
Special Area of Conservation (SAC), within the Upper Tweeddale Area of Great Landscape Value (Glenkerie EIS,
2007). The pre-existing land use was rough pasture for sheep and cattle grazing. The site is covered in a mosaic of
heath, degraded mire, and grassland habitats, with small amounts of conifer and broadleaved plantations (ibid.).
Kingledores burn, which runs through the site, is a tributary and listed component of the River Tweed SAC. Both
the habitats and burn are considered in relatively poor condition as a result of overgrazing, and the moorland on
top of the ridge is described as degraded (ibid.). A number of protected species have been recorded around the
site, including black grouse (Lyrurus tetrix), Atlantic salmon (Salmo salar), adder (Vipera berus), common lizard
(Lacerta Zootoca vivipara), mountain and brown hare (Lepus timidus, Lepus europaeus), brown trout (Salmo trutta)
and otter (Lutra lutra) (ibid.). Glenkerie was approved in 2009 by the Scottish Borders Council (SBC), granting
permission for 25 years (SBC, 2009). The site falls under the SBC Renewables and Biodiversity Offsetting Initiative
run by the LPA Ecology Officer (Tharme and Aikman, 2012; SBC, 2016). The requirement for an offset was linked
to residual unavoidable impact on 5ha of blanket bog resulting in a £50,000 contribution by the developer
(Glenkerie Landscape and Habitats Management Plan, 2008; Glenkerie Supplementary Environmental
Information, 2008). The LPA used a local NGO to deliver the offset, resulting in 6 main areas of riparian planting,
with measures ranging from fencing to areas of tree planting between 1-7ha, and 4ha of blanket bog restoration
through grip fill (Tweed Forum, 2011; Glenkerie Offset provider pers com.).
Location: Kingledores Farm, Tweedsmuir, Biggar Jurisdictions: Scottish Borders Council, Scotland
Development Type: Wind Farm, Renewable
Energy
Scale: 22MW, 11 turbines, up to 105-120m high, 9.3km of new access track and, 1.3km of upgraded access track
Status:
Planning application: 2007
Approved: 2009
Operational since 2012
Extension planning application submitted May 2013
Main Actors
LPA: Scottish Borders Council
Developer: Infinis
Consultants: Atmos Consulting Ltd
Statutory Consultees: Scottish Natural Heritage
Interested Parties: RSPB
Offset Broker: Scottish Borders Council
Offset Provider: Tweed Forum
Policy Context SBC Biodiversity Offset Project or Renewables and Offsetting Initiative (SBC 2016)
SBC (2011) Consolidated Local Plan Policy G5 and NE3
SBC (2006) Supplementary Planning Guidance on Biodiversity
Offset Typology Independent LPA led scheme developed prior to policy interest in offsetting in England.
Case Overview
Policy Planning Application Decision Making Delivery
SBC Renewables
and Biodiversity
Offsetting
Initiative SBC
Supplementary
Planning Guidance
on Biodiversity
Project Development and Design
EIA Process
draft EIS
Consultation Revised EIS
+ Offset
LPA Offset
Requirement
Project
Approval
Developer
Contribution
SBC Offset
Broker
Offset
Provider
Offset(s)
FinalOffset
Independent
Offset
Calculation
128
Map 7.1 Glenkerie Site and Local Context (Source DigiMap, Downloaded 2016)
129
Cheddar Reservoir 2 (*hereafter CR2)
CR2 Case Study
CR2 is proposed to provide 9,440 Megalitres of water storage, along with utility works, stream diversions, a new
visitor centre, access, and green infrastructure. The total site area covers 210ha, with the reservoir taking up 97ha
(45%) (CR2 EIS, 2013). The proposed site is adjacent to the existing Cheddar Reservoir. The pre-existing land use is
largely arable land, characterised by a patchwork of generally species-poor semi-improved grassland and small
patches of more diverse grasslands, bordered by a network of wet and dry ditches, species rich hedgerows and
mature trees (ibid.). Two European Protected Species (EPS) have been recorded on-site, including barn owl (Tyto
alba), kingfisher (Alcedo atthis), badger (Meles meles), otter (Lutra Lutra), grass snake (Natrix natrix), slow worm
(Anguis fragilis), dormouse (Muscardinus avellanarius) and water vole (Arvicola amphibious), bats (lesser and
greater horseshoe bats) (Rhinolophus hipposideros and Rhinolophus ferrumequinum) (ibid.). Somerset County
Council (SCC) has operated a form of offsetting policy referred to as the Habitat Evaluation Procedure for EPS since
2009 (SCC, 2014), and is classified as a complementary Defra pilot (SCC, 2016). The Habitat Evaluation Procedure
was applied to measure impacts on lesser and greater horseshoes bats, as a result of changes in site design and
on-site mitigation plans a final offset was not required. The site was approved by Sedgemoor District Council in
June 2014 (decision no. 17/13/0080). Bristol Water was prevented from funding construction through customer
by the Competition and Market Authority, and CR2 is currently on hold (Bristol Water, 2016).
Location: Land surrounding and to the south and East of, Cheddar Reservoir, Wedmore Road, Cheddar
Jurisdictions: Sedgemoor District Council (SDC), Somerset
Development Type: Utilities, Water Storage, Reservoir Scale: Reservoir Capacity 9,400 ML. The site 210 ha
Status:
Planning application submitted 2013 (Application no.17/13/0080)
Approved: SDC granted planning permission in June 2014
Implementation: Cancelled 2015, Competition and Market Authority reduced the scope of investment and expenditure allowed by Bristol water, therefore, Bristol Water are now unable to build Cheddar Reservoir 2.
Key Actors
LPA: Sedgemoor District Council, Somerset County Council
Developer: Bristol Water
Consultants: Ove Arup
Statutory Consultees: Natural England, Environment Agency
Interested Parties: CPRE, Somerset Wildlife Trust, Bat Conservation Trust
Policy SCC (2014) Somerset Habitat Evaluation Procedure
SCC (2008) Somerset Biodiversity Strategy ‘Wild Somerset’ 2008-2018
Mendip District Council Local Plan (2006-2029)
Offset Typology Independent LPA led scheme developed prior to policy interest in offsetting.
Case Overview
Policy Planning Application Decision Making
LPA requires
use of the HEP
SCC
Biodiversity
Strategy
SCC Habitat
Evaluation
Procedure
(HEP)
Project Development
and Design
Revised Project and Landscape
Design
EIA Process: Baseline
and impact prediction
Consultation with
LPA Ecology Officer
EIA Process + Habitat Evaluation
Procedure Calculations
HEP metric
indicates no
net loss
Project
Approval
CMA
funding
dispute
130
Map 7.2 CR2 Site Map and Local Context (Source DigiMap Download 2016)
131
Coventry and Warwickshire Gateway (*hereafter the Gateway)
The Gateway Case Study
The Gateway project is a proposed mixed use logistics and technology park, designed to provide new business
space (The Gateway NTS, 2012). The total site area is 308ha of greenbelt land (ibid.). The site is currently rural and
arable land, with a range of past uses (The Gateway EIS, 2012). The habitats on-site are a mosaic of arable, semi-
natural woodland, plantation, veteran trees, scrub, grasslands (improved to semi-improved), short ephemeral
vegetation, wetlands (ponds, scrapes, pools, lagoons, wet-rush pasture), and amenity grassland (ibid.). There are
two statutory sites of national nature conservation within 2km of the site, 2 county level Local Nature Reserves
and 10 Local Wildlife Sites within 1km (5 LWS adjacent and 4 within the site boundary) (ibid.). A range of species
have been recorded around and with the site, including grass snake (Natrix Natrix), common lizard (Lacerta
Zootoca vivipara), common toad (Bufo bufo), hedgehog (Erinaceus europaeus), badgers (M.meles), breeding and
overwintering birds, grass snakes (Natrix natrix) and great crested newts (Triturus cristatus), and 11 species of bats
(ibid.). The site is part of the Warwickshire, Coventry and Solihull Defra offsetting pilot, and the adapted
Warwickshire District Council (WDC) Defra metric was applied in the EIA process (The Gateway EIS, 2012; WDC,
2016). A final offset of 43 biodiversity units was required for cumulative habitat loss (The Gateway EIS, 2012). The
application was initially approved in 2014 (decision no. W/12/1143), but later called in by the Secretary of State
and overturned based on greenbelt impact. The proposal could potentially be re-submitted in the future.
Location: Land within, to the North, West and South of, Coventry Airport
Jurisdictions: Coventry City Council, Warwickshire District Council, England
Development Type: ‘comprehensive redevelopment’ to build a multi-use Logistics and Technology Park.
Scale: 439,280sqm of business floor space, site covers an area of some 308ha
Status:
Planning application - 2011-2013
Approved by in June 2014 (W/12/1143)
Appeal: Decision was called in by DCLG based on
the quantity of objections in 2014.
Inquiry: Overturned permission by Secretary of
State in 2015 (DCLG, 2202736 and 2202738).
Potential for appeal in the future subject to Local
Development Plan
Key Actors
LPA: Warwick District and Coventry City Council
Developer: Coventry and Warwickshire
Development Partnership LLP
Consultants: FPCR
Statutory Consultees: Natural England,
Interested Parties: Warwickshire Wildlife Trust,
CPRE
Offset Broker: Environment Bank
Policy Context Warwickshire, Coventry and Solihull Sub-regional Green Infrastructure Strategy (2016),
Offset Typology Defra Pilot Scheme
Case Overview
Policy Planning Application Decision-Making
Sub-regional
Green
Infrastructure
Strategy
Warwickshire
District
Council Core
Strategy EIA Process +
Offsetting Metric
Biodiversity Impact
Assessment Calculator
Landscape Design and
on-site mitigation
plans
Net
loss
Project Development
and Design
Biodiversity Offsetting Pilot
Project
Approval
Reduced
net loss
Inquiry
Refusal
EIS + Offset
commitment
and
calculation
132
Map 7.3 The Gateway Site Map and Local Context (Source: DigiMap, Downloaded 2016)
133
Whitehouse Farm, Residential Development, North Tyneside
Whitehouse Farm Case Study
Whitehouse Farm is 366-unit housing scheme, incorporating wildlife corridors, open space and access
(Whitehouse Farm NTS, 2011). The total site area is 32ha, with a net developable area of 22ha (ibid.). The site is
situated on the urban fringe (ibid.). 600m to the west of the site lies Gosforth Park, a Site of Special Scientific,
immediately to the east of the site is Killingworth Sliding former Site of Nature Conservation Interest (Whitehouse
Farm EIS, 2011). The existing site is predominantly arable farmland (87%), along with small areas of species-poor,
semi-improved grassland, hedgerows, seasonal wetlands and a stream (ibid.). Arable birds including skylark
(Alauda arvensis), lapwing (Vanellus vanellus), reed bunting (Emberiza schoeniclus), yellowhammer (Emberiza
citronella), grey partridge (Perdix perdix) and starling (Sturnus vulgaris), badgers (Meles meles), Soprano Pipistrelle
(Pipistrellus pygmaeus) and Daubenton’s (Myotis daubentonii), and otters (Lutra lutra), have all been recorded on-
site (ibid.). The site is considered of relatively low ecological value arable land, but it is a designated wildlife corridor
and safeguarded land under the North Tyneside Unitary Development Plan (2002, e12/6, e12/2). The site is not
part of an Local Planning Authority led offsetting scheme. The development was initially rejected by the North
Tyneside Council (NTYC) planning committee, based on biodiversity and traffic justification. Offsetting proposals
were brought in prior to the appeal to account for residual impacts on arable birds (Whitehouse Farm Inquiry
Report, 2013). The project was subsequently approved by the Secretary of State in 2013 (DCLG, 2013:
APP/W4515/A/12/2175554) with offsetting as a planning condition. An offset of 23.6ha, 122.5 credits, was
delivered by the developer in partnership with E3 Ecology and the Environment Bank (Environment Bank, 2014).
Location: Whitehouse Farm, Station Road, Killington, North Tyneside
Jurisdictions: North Tyneside, Newcastle Upon Tyne,
Development Type: Residential Development Scale: 366 housing unit, 32 ha
Status:
Planning application: 2010-2012
Refused: North Tyneside Planning Committee 2012
Appeal: Bellway appeal refusal
Inquiry: Recommend for approval 2013 (APP/W4515/A/12/2175554)
Implementation: offset construction and housing construction in progress
Key Actors
LPA: North-Tyneside District Council,
Newcastle City Council
Developer: Bellway Homes
Consultants: E3ecology, Arup
Statutory Consultees: Natural England
Interested Parties: Westmoor Residents Association, Northumbria Wildlife Trust
Offset Broker: Environment Bank/E3ecology
Policy Context No local offset policy
Offset Typology Ad hoc, developer led offset
Model of the relationship between EIA and offset
Planning application Decision Making Implementation
Project
rejected
Project Development
and Design
Consultation
EIA process
NTYC Ecology Officer
suggests the need
for compensation
No
compensation
provided
Appeal approves
project with offsets
Developer
suggests
offsetting
Offset site Search
group set up
Site purchase and
restoration works
Search for long
term site manager
134
Map 7.4 Whitehouse Farm Site Map and Local Context (Source DigiMap, Downloaded: 2016)
135
Table 7.1 Sequence of Events Leading Up to Offsetting in the Case Studies
Denotes when offsetting was first instigated in the case study
136
7.2 Structural Connections between Offsetting and EIA
In analysing the case studies the starting point was to assess the structural approaches taken to
offsetting. The term ‘structures’ is used to, collectively, refer to the key actors, entities, systems,
components, processes, and conditions which shaped the development of offsetting in each
case. Through examining the structural approach taken in each case this section provides a
picture of the sequence of events and drivers which led to offsetting. The importance of
analysing structural approaches stems from the findings of Chapters 5 and 6. Chapter 5
highlighted that offsetting is being applied in the UK in very different formats, by different actors
and at different stages in of the planning process (5.6). While Chapter 6 emphasised that EIA has
potentially multiple possible roles, and limitations in helping to operationalise offsetting (6.2,
6.3), based on different perceptions of EIA and the risks and opportunities which surround
offsetting (6.4). By assessing the structural approach taken, this section builds a basic picture of
who, how and why each offset took place and an understanding of the operational role and
relation between EIA and offsetting. Essentially, to answer fundamental questions about the
perceived utility of the EIA process for operationalising offsetting. The sequences of events or
stages which took place in each case are summarised above in Table 7.1 to provide simplified
comparative perspective on the main processes, drivers, and stages which formed the basis for
the application of offsetting in each case. The following section provides a more detailed
discussion of the structural approaches taken in each case, highlighting the similarities and
difference in the way that offsets were initialised and operationalised.
7.2.1 Structural Approaches to Offsetting and the Role of EIA
Analysing the structural approaches taken in the four case studies illustrated three broad
approaches to initiating offsetting which can be broadly categorised as reactive offsetting
(Glenkerie and CR2), pre-emptive offsetting (the Gateway) and retrospective offsetting
(Whitehouse Farm). They present quite different models of how EIA and offsetting can work
together and the roles EIA can play in operationalising offsetting.
In the Glenkerie and CR2 case studies, the initialisation of offsetting was structured around the
findings of the EIA process, as shown in Table 7.1.
The key steps [for offsetting] mainly came out of the EIA process for major
developments, as EISs dictate where consultants have identified a residual impact”
(Scottish Borders Ecology Officer).
In these cases, the Local Planning Authority (LPA) Ecology Officers (EOs or EO) used the
consultation stage in the EIA process, in a reactionary manner, to initiate offsetting (Glenkerie
Response to Planning application, 2008; CR2 EIS Consultation Record, 2013: Appendix A1). The
draft EIA findings acted as an ‘information trigger’ for offsetting, as predicted in Chapter 6.2,
effectively alerting the EOs to the presence of ecological impacts on certain environmental
receptors for which they then chose to initiate offsetting. In Glenkerie for impact on 5 ha of
degraded blanket bog (Glenkerie Response to Planning application, 2008; G.I.1 and G.I.3), and
in Somerset in response to the prospective landscape connectivity impacts on a nearby
populations of Lesser and Greater Horseshow bats, European Protected Species (EPS) (CR2 EIS
Consultation Record, 2013: Appendix A1; C.I.1 and C.I.2). In both cases, the use of EIA as a trigger
137
was intentional, as both of these cases fell under the remit of pre-existing offsetting schemes
(Chapter 5.2.2), backed up by overarching LPA policies with established methodologies (SCC,
2014; Tharme and Aikman, 2012; Tables 7.1 and 7.2). Furthermore, the use of EIA to trigger the
offsetting process was considered by both EOs as a practical and logical choice.
After offsetting was initiated it was then integrated into the EIA process to quite different
degrees by EIA consultants in these two cases. In the CR2 case the Somerset offsetting metric,
referred to as the Habitat Evaluation Procedure (HEP) (SCC, 2014), was undertaken and analysed
by the CR2 EIA consultants. The HEP calculations were incorporated into the EIA process and
included in the Environmental Impact Statement (EIS) and mitigation proposals. In Glenkerie,
the degree of integration was much more descriptive than analytical, with a simple commitment
to funding an offset added to the Landscape Habitat and Management Plan (2008) of the EIS
(G.I.3; G.I.1). Therefore, these cases had similar structural components, driving actors, policy
backing and approach to triggering offsetting, but once initiated the degree to which offsetting
was incorporated into EIA was quite different in nature. Furthermore, the Somerset EO also
emphasised one major downside of this approach, highlighting that using EIA as a trigger was
practice but also made the application of offsetting highly dependent on when developers
choose to consult LPAs (C.I.1).
In the Gateway case, the requirement to undertake the offsetting metric was introduced by the
EO prior to the initiation of the EIA process (Table 7.1). Rather than being triggered by a specific
impact identified through the EIA process, the Defra metric was used throughout the EIA process
and as part of the EIA process (GA.I.1; GA.I.2). The EIA consultants for the Gateway were
effectively required by the LPA to use the offsetting metric as part of the EIA process from the
beginning (GA.I.2; GA.I.1), the EIA process then worked as an operational framework to
undertake the metric calculation and analysis (The Gateway EIS, 2012:6.2.8;6.4.55). This
approach was driven by the system designed for the Warwickshire, Coventry and Solihull (WCS)
Defra pilot scheme developed by the Warwickshire District Council (WDC) Ecology Officer (EO).
The WDC EO aimed to make the metric, referred to as Biodiversity Impact Assessment in
Warwickshire (WDC, 2016), a relatively uniform requirement for all developments with the
potential for major to minor biodiversity impacts. Evidently, Warwickshire has adopted a more
pre-emptive than reactive approach. Offsetting is applied based on the potential for biodiversity
loss rather than for a specific identified impact. By revealing a loss of biodiversity units it is the
offsetting metric, not EIA findings, which triggers the requirement to offset (GA.I.1; GA.I.2).
The Whitehouse Farm case sits in stark contrast to the structural approach, drivers, and
sequence of events in the other three cases. In this case offsetting was applied on a one-off basis
by the developer rather than linked to a local offsetting scheme, a form categorised as ‘ad hoc
offsetting’ in Chapter 5.6. There were some suggestions of the need for off-site compensation
by the North-Tyneside Council (NTYC) EOs and local interest group (Whitehouse Farm Inquiry
Report, 2013: para157). However, the initiation of offsetting did not occur during the planning
application process or EIA process for Whitehouse Farm, but retrospectively after the refusal of
planning permission (W.I.1; W.I.2; W.I.3). Instead, the ecological consultant highlighted that it
was the developer and ecological consultants who initiated offsetting in preparation for the
appeal, using an offset broker to undertake the offsetting metric for the site and develop
preliminary proposals for the inquiry (Whitehouse Farm Inquiry Report, 2013: para160). In
138
reviewing their case for appeal, offsetting had effectively been seized upon as a means to try to
comply with earlier suggestions of the EOs and local interest group. The late introduction of
offsetting after the completion of the EIA process meant that the findings of the EIS disagreed
with the need for offsetting (Whitehouse Farm EIS, 2011:6:41/42; Whitehouse Farm Inquiry
Report, 2013: para161), although there was some later involvement of the EIA consultants in
the offset proposals.
To summarise the three models presented in the case studies:
Reactive offsetting using EIA as an information trigger: In this model, offsetting is initiated
and structured around the findings of the EIA process, which acts as an information trigger
for offsetting by alerting EOs to the presence of certain impacts. Under this model, EIA plays
a relatively passive role in initiating offsetting, in that the EIA process itself is not actively
suggesting offsetting or even identifying that these impacts need mitigation. Triggering
offsetting under this model is heavily reliant on the LPA EO and LPA policy, but also
procedurally dependent on when the EO gets access to the EIA findings, a reactive approach.
Once triggered offsets can then be partially integrated into the EIA process (Figure 7.2)
Proactive or pre-emptive offsetting using EIA as an analytical framework: The second
model apparent from the case studies shows that offsets can be initiated prior to the
commencement of the EIA process. Under this model, the application of offsetting metrics
is proactively structured around the potential for impacts rather than established impacts.
By fully incorporating offsetting into the EIA process it can then work as a means to
operationalise offsetting, with EIA consultants undertaking the metric as an additional
methodology and analysing the calculations within the EIA process. In the event of finding a
net loss of biodiversity units, the offsetting metric effectively automatically triggers the need
to consider a physical offset (Figure 7.3).
Retrospective offsetting separate from the EIA process: The final model presented in the
case studies was a structural approach where offsetting was separated from the EIA process,
and instead introduced at the decision-making stage. In this approach, the application of
offsetting is retrospective for residual unavoidable impacts not addressed through the EIA
process. Therefore, the need for an offset appeared to work in conflict with the findings of
the EIA process (Figure 7.4).
The different structural approaches taken in the case studies highlight that all three of the forms
of integration predicted in Chapter 6.6 are occurring in practice, and particularly emphasise roles
for EIA as both an information trigger and analytically framework in established LPA led
offsetting systems (6.2, Figure 6.1). The proactive vs. reactive application of the metric was also
reported by the CEP and IEEP (2016) evaluation of the pilots. These models point to three quite
different relationships between EIA and offsetting depending on the stage that offsets were
introduced and the actors driving offsetting (LPA or developers). Furthermore, the use of
offsetting in a reactive, pre-emptive and retrospective manner, point to very different
perceptions of how offsets should link into EIA practice.
139
Figure 7.2 Reactive Offsetting Using EIA as an Information Trigger
Figure 7.3 Proactive or Pre-Emptive Offsetting Using EIA as an Analytical Framework
Figure 7.4 Retrospective Offsetting Separated from the EIA Process
7.2.2 Structural Consequences of Different Interpretations of Offsetting
The case studies reveal a range of different structural approaches to offsetting with different
alignments and points of engagement with the EIA process. In the absence of a national
mandatory scheme for offsetting, or clear policy direction (see Chapter 5.3.3), the main
influential factor over the different approaches and structures outlined in section 7.1 appears
to be the perspective of a dominant single actor or organisation. For Glenkerie, CR2 and the
Gateway, it was the LPA EOs who shaped the offsetting policy, created metrics and actively
triggered offsets (Table 7.1). Whereas in the Whitehouse Farm case, the application of offsetting
appears to have been much more dominated by the developer, with the EIA consultants.
Chapter 5 indicated that there are multiple narratives and justifications around offsetting,
however, from the case studies, it is apparent that actors and organisations have initiated
offsetting based on two broad interpretations of the value and purpose of offsetting.
In the CR2 and Gateway cases the initiation of offsetting appeared to have been largely focused
on the application of offsetting metrics, with much less mention of the possible need for a
physical off-site offset to take place at the point of initiation. In initiating the offsetting process
EIA Process EIA Impact ID Decision Making
Physical
Offset
Metric Calculation
Appeal+
Developer
Pre-existing offset policy framework
EIA Process EIA Impact ID
Decision
Making
EIA +
Offsetting
EO
Physical Offset Metric Calculation
Pre-existing offset policy framework
Offsetting metric
Physical
Offset
Decision
Making
EIA + Metric
Calculation
140
through EIA consultation for the CR2 case the Somerset EO specifically requested the use of the
Habitat Evaluation Procedure (HEP) as the basis for the assessment of the impact on the Lesser
and Greater Horseshoe Bats (CR2 EIS, 2013: Appendix.A).
“In triggering the Habitat Evaluation Procedure my concern was the spatial
arrangement of the impact in relation to distances between bat colonies and the
method to be used in carrying out the mitigation” (Somerset EO).
Whilst for the Gateway the WDC EO recounts that the metric was used throughout the EIA as a
framework for the discussion of biodiversity on-site. In applying the Warwickshire metric, the
WDC EO and Project officer (PO) stressed that they were not explicitly asking for an offset, but
for an assessment. Equally, in the CR2 case a final offset was not required as compensation was
achieved on-site (CR2 EIS, 2013: para438). Offsetting in these cases is not linked to a concrete
or firmly established impact but the potential for impact(s). The application of offsetting metrics
is linked to establishing impacts: the cumulative impacts on biodiversity at the Gateway (GA.I.1),
and landscape connectivity impacts on European Protected Species (EPS) species for CR2 (C.I.1).
The WCC EO and PO even described the term biodiversity offsetting as a ‘misnomer’ as it
misconstrues the independent value of the offsetting metric as an assessment tool (e.g. CR2 EIS,
213: para417). However, the use of offsetting in this manner was also problematic. Although the
Somerset EO stressed that the CR2 case had been undertaking using the offset calculator
principles and parameters, the ecological consultant did not actually see CR2 as the application
of offsetting due to the fact that off-site compensation was not required. This interpretation of
offsetting clearly brings into question the limits to the definition and nature of offsetting as a
mitigation tool.
The application of offsetting based on its value as a methodology had clear implications for the
structural approach taken to offsetting.
“You, therefore, can’t follow DEFRA’s original thinking that you undertake the
mitigation hierarchy and then look into doing biodiversity offsetting. You need to
apply the metric early on to find out if there is any impact or compensation needed,
when you’re first doing the planning application, or in the pre-application stage”
(WDC EO).
The focus on the value of offsetting as a methodology directly led the WDC EO to require the
early application of offsetting, prior to the EIA, and use of EIA process as a management and
analysis framework for offsetting. Equally, the HEP offsetting metric in the Somerset case was
adopted early on, at the baseline and impact prediction stage (C.I.1, C.I.2), and incorporated into
the rest of the EIA process and the metric undertaken by the EIA consultants.
In contrast, the initiation of offsetting at Glenkerie and Whitehouse Farm cases was linked to a
much more traditional conceptualisation of offsetting.
“The driver for the offset was that there no way to mitigate for this onsite to improve
blanket mire, simply no suitable habitat onsite” (G.I.3).
At Glenkerie and Whitehouse farm, the application of offsetting was clearly linked to the notion
that these impacts were ‘unavoidable’ on-site, a product of the topography at Glenkerie (G.I.1;
G.I.3) and the fundamental change in land use caused by the conversion from arable to
141
residential at Whitehouse Farm (W.I.2). The application of offsetting in both cases was as a
physical mitigation solution to impacts which were considered by the developer as ‘unavoidable’
without significant design modifications; offsetting was therefore predominantly being used as
an output rather than a means to measure impact. The structural consequence of this
interpretation of offsetting is that in both of these cases the application of offsetting occurred
at a much later stage of the planning application process, the full EIA consultation at Glenkerie,
and the appeal stage for Whitehouse Farm (Table 7.1).
7.2.3 Structural Connections
Figure 7.5 Links Between the Different Structural Approaches and Conceptualisations of
Offsetting
This section had explored how offsetting was configured in the case studies and confirms ideas
in Chapter 6.2 that there could potentially be quite different ways of linking up EIA and
offsetting. Three main structural approaches to how EIA and offsets are operating together were
identified in the case studies: pre-emptive offsetting using EIA as an analytical framework,
reactive offsetting using EIA as an information trigger, and retrospective offsetting after the
completion of the EIS, echoing ideas in section 6.6. These different approaches not only indicate
quite different potential roles for and perceptions of EIA, but also quite different interpretations
of the nature of offsetting as a mitigation tool, and its place in the planning process, by the actors
and organisations initiating offsetting.
The case studies suggest that there are two different perceptions of the value and purpose of
offsetting in relation to EIA. These two interpretations of the value and purpose of offsetting,
present very different visions of the conceptual relationship and structural engagement
between EIA and offsets. Moreover, they have the potential for quite different causal effects
and connections between these two mechanisms. The focus of the next section is to explore the
interaction and implications of these two different interpretation of offsetting for the EIA
process.
Glenkerie Whitehouse Farm Cheddar Reservoir 2 The Gateway
Focus on the Metric Focus on the Physical Offset
Conceptualisations of Offsetting
Metric Incorporated into EIA Separate EIA and Offsets
Formal LPA Policy/EO
Led
Informal Developer Led
Structural Approaches to Offsetting
EIA as an Information Trigger
Pre-emptive Reactive Retrospective
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7.3 Causal Connections Between EIA and Offsetting
Moving beyond structural connections, there was also evidence of causal connections and
feedbacks caused by complex interactions between EIA and offsetting processes. The term
‘causal connections’ was used to refer to the consequences of different forms of interaction
between EIA and offsetting, i.e. whether their interaction was commensurable or parasitic in
nature. Through looking at causal connections the aim was to explore the nature and outcomes
of the interactions between the EIA and offsetting processes. To determine whether, and which,
of the unintended consequences or risks, and unexpected opportunities or returns, outlined in
Chapter 6.4, occurred in practice. Moreover, by assessing the causal connections this section
can contribute to wide discussions around the effectiveness and operational challenges for
offsetting, and its integration into the development management.
The analysis of causal connections has been divided based on the different perceptions of the
value and purpose of offsetting in relation to EIA, as outlined in 7.2. First, to assess the
interaction and implications of the offsetting metric and more metric based applications of
offsetting for the EIA process (7.3.1). Second, to assess the interaction and implications of the
option to offset off-site, and therefore more offsite-solution based conceptualisation of
offsetting, for the EIA process (7.3.2). Therefore, the following sections discuss how the presence
of these different formulations of offsetting were able to interact with fundamental aspects of
the EIA process, namely: impact identification, the attribution of impact significance and the
adherence to the mitigation hierarchy.
7.3.1 The Implications of Metric-Based Offsetting
7.3.1.1 Measuring Impacts through Metrics
First, exploring the interaction of offsetting metrics and the EIA process, the case studies
indicated that one of the primary areas where offsetting metrics were found to interact with the
EIA process was in relation to impact identification. In the CR2 case, the Somerset offsetting
metric, the HEP, was specifically designed to assess the suitability of habitats on-site for lesser
and greater horseshoe bat species (SCC, 2014; SCC EO).
“During the operational phase of the proposed development: the value of the
foraging habitat for both species of horseshoe bat will increase: 158.47 units for
Greater Horseshoe and 99.92 for Lesser Horseshoe (roughly 19-17% for both
species)” (CR2 EIS, 2013:215).
For the CR2 case, the presence of the HEP in the EIA process was used to examine the how the
spatial arrangement of the development would impact on the suitable habitat for horseshoe bat
species, and thereby provide an estimate of impacts on landscape connectivity for nearby
populations of these EPS (C.I.1; CR2 EIS, 2013). Impacts on landscape connectivity features, such
as foraging and commuting habitat, have traditionally not been captured effectively through the
EIA framework (Slootweg et al., 2010; Gontier et al., 2006). Therefore, for the SCC EO, the
presence of the HEP metric worked as an additional impact measure within the EIA process, and
a technique to measure compliance for the European Protected Species (EPS) legislation in a
wider landscape context (SCC, 2014).
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Equally, in the Gateway case, the WDC EO interpreted the Defra metric as a cumulative measure
of the impact of “land-take” or “land-use change” on biodiversity. Again, measures of
biodiversity loss in terms of the cumulative impact of land-use change have traditionally not be
undertaken in the EIA process (Gontier et al, 2006; Wale and Yalew, 2010), which has historically
focused on designated sites and protected species impact. Therefore, the Warwickshire metric
was presented by the EO as a new or additional methodology for the Gateway EIS (2012:
para6.2.8). In comparison, in the Whitehouse Farm case, where offsetting was interpreted more
as an off-site solution, there was no mention of offsets as a new or additional methodology, but
instead simply a contrasting means of measuring impacts already identified in the EIA process
(Whitehouse Farm Inspectors Report, 2012).
By providing new techniques for impact measurement, beyond direct impacts, or impact silos,
the presence of offsetting metrics in the CR2 and Gateway was perceived as working to expand
and extend the EIA process (GA.I.2; GA.I.1; C.I.1). In both cases the application of the metric was
acknowledged as picking up new levels of impact which “EIA in the past never did” (GA.I.2),
working to inform the EIA process (C.I.1). These features of metrics meant that they were clearly
perceived as a beneficial addition to the EIA process (GA.I.2; GA.I.1; C.I.1; C.I.3), echoing the
findings of the CEP pilot evaluation (CEP and IEEP, 2016).
Furthermore, there were also suggestions that metrics were perhaps an improvement on
traditional approaches, and could even be providing a better measure of impacts for the EIA
process. By introducing a pseudo-quantitative predictive approach, the Somerset EO argued that
metrics measure landscape connectivity impacts with much more certainty, and the Somerset
HEP was even described as more scientifically based than the current more subjective qualitative
methods. Therefore, the integration of metrics into the EIA process was not just considered a
useful addition or extension, but also brings into question the accuracy of traditional more
qualitative approaches to impact assessment.
For the Somerset ecological consultants, the perceived benefits of the metric were more limited,
focusing on the metric as a “useful tool for the job”, and as having practical value to help “work
out the area used by bats and establish how the development would affect these areas” (C.I.2).
Although in both cases the EOs had endeavoured to make offsetting metrics as user-friendly as
possible (C.I.1; GA.I.1), in implementing metrics EIA consultants have been required to
understand and implement quite complex metrics, with significant time and resource
commitments. In the CR2 case, the metric required the consultants to develop complex GIS
models, reportedly involving some 6000 calculations (C.I.2). Whilst in the Gateway the
consultants were undertaking detailed mapping of habitats and working to help test an evolving
metric (GA.I.1).
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Box 7.1 Offsetting Metrics and Impact Identification in EIA
7.3.1.2 Biodiversity Units, Impact Magnitude and Significance
Alongside working as an additional measure of impacts in the case studies, there is also evidence
that metrics had knock-on effects for impact evaluation and the attribution of significance in the
EIA process. In the Gateway EIS, the inclusion of the Defra metric not only identified a
biodiversity impact of 1207 biodiversity units but also provided a measure of impact magnitude,
as ecological consultants reasoned that the quantity of biodiversity units lost equated to a
“substantial impact” (the Gateway EIS, 2012:6:25). Essentially, biodiversity units provided an
evaluative measure of the degree of impact of the project, interpreting the value and
importance of the impact in relation to no net loss or 0 unit’s loss. Similar effects were also
reported for CR2:
“The results of the Habitat Evaluation Procedure (HEP) show that the loss of habitat
for both species, from within the construction footprint, is mitigated by the habitat
creation and enchantment works. The mitigation proposed thus removes the
significant effect, resulting in a not significant effect on a feature of international
importance” (CR2 ES, 2013:205-206).
At CR2 it appears that the presence of the HEP metric, not only provided a measure of impact
significance but also effectively replaced the need for the qualitative assessment of impact
significance.
Both of these cases suggested that, as an aggregate measure of biodiversity loss, the presence
of biodiversity units in the EIA process appears to introduce a new conceptualisation of impact
magnitude and significance. Biodiversity units were perceived as somewhat different to
traditional measures of ecological impact magnitude and significance, as set out in CIEEM (2006),
based on aspects such as conservation policy and legislation and the geographical scale of
predicted impacts, regional, county, district, local, or parish (Gateway EIS, 2012:9-10). For the
Somerset EO, the use of the HEP to replace expert judgement was reportedly a pro-active
decision based on the perspective that at present the approach to measuring impact significance
within the EIA framework was too hierarchical, too rigidly based on the presence or absence of
statutorily protected species which were simply not considered representative of significant
impacts on biodiversity. A perspective also echoed by NGOs in the Whitehouse Farm and
Gateway case studies. Impact significance in EIA has traditionally been linked to expert
judgement, parameters, guidance, and matrices, therefore the introduction of offsetting metrics
also resulted in a shift to much more technical or methodology-driven means of determining
impact significance.
The offsetting metric and impact identification:
Identification of ‘new’ impacts: In terms of impact identification offsetting metrics were considered a
technical enhancement or positive addition to the EIA process, as the metric extended the scope of EIA in terms of biodiversity impacts by capturing new impacts.
Scientific enhancement of EIA: There were some suggestions that offsetting metrics, as quantitative
measure of impacts, were more ‘scientific’ than traditional more qualitative measures of impact identification, a technical improvement.
Practical tool for EIA: Some EIA consultants considered the metric as having practical value for EIA, a useful means of determining impacts.
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Even where metric calculations were conducted after the completion of the EIA process, metrics
still appears to have the ability to influence conceptualisations of impact significance. At
Whitehouse Farm, the impacts on arable birds were concluded to be of parish importance, a
minor adverse impact in the EIS (Whitehouse Farm EIS, 2011). However, the classification of the
impact as minor adverse was heavily criticised at the planning inquiry (Whitehouse Farm Inquiry
Report, 2012; W.I.1), where it was argued that the ecological consultants had incorrectly
interpreted the value and sensitivity of the impact.
“During the inquiry, the appellant conceded that 122.5 conservation credits were a
requirement for ‘substantial’ off-site compensation. It must follow, therefore, that
the residual adverse impact is also ‘substantial’. The inescapable conclusion to be
drawn from the Environment Bank report is that there is a significant adverse
residual impact” (Whitehouse Farm Inquiry Report, 2012: para169:38).
The presence of metric calculations was effectively used as a measure of impact magnitude and
significance to help refute the level of significance attributed by the ecological consultants,
alongside other justifications and criticisms of the methodological approach taken (Whitehouse
Farm Inquiry Report, 2012). The way the Defra metric was used in this case appears to be
another example of metrics working in conflict with traditional qualitative expert-driven
approaches used by the EIA consultants, effectively helping EO to question the judgments made
by ecological consultants.
The influence of offsetting metrics in these three cases shows their potential to clash with
judgements on impact magnitude and significance in EIA, effectively providing new pseudo-
quantitative measures of impact and even replacing or helping to overturn qualitative
judgements of impact significance. However, the comparison between the Gateway and
Whitehouse Farm cases shows that as a measure of impact importance what is considered a
‘substantial’ impact under offsetting metrics is by no means consistent, 1207 in one case and
122.5 in another. This difference is explained by the WCC EO:
“I was going to go to a public enquiry last week about significance, as one consultant
couldn’t believe that they needed to offset for 2 units loss. They kept trying to tweak
the metric, to distort the real value. I said ‘look we can’t change the Defra metric if
there is a loss then there is a loss’. But they refused to compensate. I looked at the
definition of significant harm in the NPPF and the first thing that it says is that
development should result in no net biodiversity loss. So I was prepared to go to
public enquiry and say zero is our baseline for significance”.
For the WCC EO, the relationship between impact significance and biodiversity units is simple, a
single unit loss is significant as it represents a net loss of biodiversity. This interpretation means
that anything from two to a thousand units can be referred to as a substantial impact. This
perspective is a considerable step change in thinking for the EIA framework and challenges
traditional ideas in EIA that lower level impacts can remain unmitigated as well as the place of
expert judgement in the attribution of impact significance. Within EIA, the presence of offsetting
metrics and the aspiration of no net loss appeared to work as a consistent benchmark for impact
significance. By reducing the space for subjective judgements around impact significance the
metricwas argued by the WDC EO and PO to introduce a greater level of standardisation,
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accountability and consistency, reflecting the findings of the pilot evaluation (CEP and IEEP,
2016).
Evidently, the presence of offsetting metrics in EIA could potentially generate a shift in thinking
in relation to impact significance, as an ‘independent’ or ‘separate’ measure of biodiversity loss
and gains (Gateway EIS, 2012:9). Offsetting metrics appear to be introducing new
conceptualisations of what is considered a significant or substantial impact, what should and
should not trigger an offset.
Box 7.2 Offsetting Metrics and EIA Impact Significance
7.3.1.3 Offsetting Metrics and the Mitigation Hierarchy
The presence of offsetting metrics did not only have implications for impact identification and
significance but also appeared to influence the adherence to the mitigation hierarchy. As a
measure of residual biodiversity loss, offsetting metrics were interpreted as also providing a
means to indirectly measure mitigation (in)effectiveness.
“The biodiversity offsetting matrix highlights that the on-site compensation scheme
does not deliver equivalent biodiversity credits to that being lost to the development”
(The Gateway Inquiry Report, 2015:520).
The success of mitigation, its effectiveness, is rarely measured or evaluated in the EIA framework
(e.g. Tinker et al., 2005; Drayson and Thompson, 2013; Hill and Arnold, 2012). Consequently,
interviewees in Chapter 6.4 complained that there is an unsubstantiated link between mitigation
proposals and impact significance reduction, referred to as the ‘mitigation myth’. The SCC EO
highlighted that he effectively used the HEP as a tool to work out where developers have under-
mitigated for the loss of habitat. Whilst the WCC EO emphasised that through employing the
Defra metric to capture residual impacts they have been able to put a measure on mitigation
effectiveness and “almost every development is coming out with a loss”.
Moreover, in the Whitehouse Farm case, metric calculations were used to help arguments that
the on-site mitigation was insufficient and simply not as effective as they claimed.
“I could shout blue in the face when people say to me that biodiversity offsetting
will lead to loss of Local Wildlife Sites, they are already being lost. All statutory and
The offsetting metric and impact significance:
A new measure of impact significance: Offsetting metrics are not just about impact identification but also
say something about impact evaluation, the level of significance of impacts in relation to the aspiration of
no net loss of biodiversity. Biodiversity units were clearly considered a separate or different approach to impacts significance for EIA.
Influencing impact significance: Offsetting metrics showed the potential to replace, reinforce or even
overturn qualitative measures of impact significance in EIA. Taking a quantitative approach to measure
impact significance was seen as more consistent and standardised than qualitative approaches, challenging the place of expert judgement on impact significance.
Raising the bar for residual impacts: The use of 0 units’ loss or no net loss as a benchmark for significance
is a considerable step change in thinking for EIA which has traditionally considered residual or slightly adverse impacts acceptable without mitigation. Metric can be seen as raising the bar for biodiversity in EIA.
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non-statutory sites are under threat, and 9 times out 10 there have been sub-
optimal mitigation and compensation strategies. This is because there is simply no
way of demonstrating that it needs greater mitigation and compensation.
Biodiversity offsetting gives us a tool to start making sure that we are holding LPAs
and developers to account” (GA.I.3).
One NGO member for the Gateway case argued that by providing a measure of residual impacts,
of mitigation effectiveness, the presence of an offsetting metric effectively helped to empower
the positions of environmentalists and NGOs (GA.I.3). Therefore, metrics appear to be being
used to provide some transparency on the effectiveness of mitigation measures, and their value
for biodiversity and are being used to hold developers to account for their mitigation proposals.
By providing an estimation of mitigation effectiveness the ecological consultant for CR2
highlighted that the metric was actively used to help establish what was needed in terms of
mitigation and inform both on-site and off-site mitigation requirements (C.I.2).
“When we first started on the landscape design we were thinking that it was going
to be more about bird habitat and boardwalks for recreation. But using the HEP
metric to test these plans we had a residual loss for Horseshoe Bats. We then tested
a number of landscape design scenarios to see which produced no net loss. What
we ended up with was a design which tried to maintain connectivity, and existing
floodplain grazed fields instead because that's what horseshoe bats like” (C.I.2)
For the CR2 project, through providing information on what was needed in terms of mitigation,
the presence of the HEP metric appeared to generate changes in the on-site mitigation and
landscape plans. In this case, the metric was operationalised through a GIS model, which allowed
the ecological consultants to directly compare possible mitigation scenarios and landscape
designs against no net loss. Effectively, the EIA consultant interviewed highlighted that they had
used the HEP metric as a design tool and the aspiration of no net loss as a target to drive
alterations in the proposed on-site compensation and mitigation measures (C.I.2). Therefore,
the presence of the HEP in the EIA process appeared to encourage a shift in the landscape design
from one based on social amenity value to one based on biodiversity value.
Similar effects were also apparent for the Gateway case, although on a smaller scale. The NGO
and EO interviewed suggested that the presence of the Defra metric led to a change in the
composition of habitats proposed on-site, along with replacing key ecological features, such as
ponds, on-site to reduce the overall biodiversity units lost. The two documented calculations for
the Gateway show a reduction of 10.3 units (43 units loss reported in the August 2012, Gateway
Biodiversity offsetting report, and 32.7 reported in the November 2012 Gateway EIS, 2012:
Appendix 3). Both the WDC Ecology Officer and PO suggested that the presence of the Defra
metric acted to raise the ecological standards of the project. Through providing a clear measure
of the mitigation required on-site and a target of no net loss offsetting metrics can incentives
changes, appear to make choices and trade-offs more apparent and emphasises the benefits of
doing more on-site vs. paying for an additional offset (GA.I.1; GA.I.2).
However, the Defra metric cannot claim sole credit for the changes made in the Gateway as
these were also encouraged through the consultation and incentivised by the link between the
site and a nearby SSSI (GA.I.3). Furthermore, the changes made to on-site design were also
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limited as the development footprint and the general layout and design of the proposals did not
change significantly. Conversely, where an offsetting metric was applied very late on in the
project for Whitehouse Farm these effects were not reported.
In working as a measure for mitigation (in)effectiveness offsetting metrics were used to hold
developers to account where they had under mitigated and incentivise more mitigation through
design changes on-site (C.I.1; GA.I.2; GA.I.1). This influence of the Defra metric on the on-site
mitigation and compensation was also reported by the CEP and IEEP (2016) pilot evaluation
Therefore, there was a strong sense that the presence of offsetting metrics in the EIA process
effectively worked as a negotiating tool for the EOs in the case studies, a means for EOs to
leverage more mitigation. As highlighted earlier this was related to the use of offsetting metrics
to identify instances of under-mitigation. However, there was also a sense from the WDC project
officer for the Gateway, the WDC EO and a local NGO that the quantification of impacts through
metrics allowed for a more practical discussion of the impact, in comparison to “woolly
qualitative statements” which were considered open for interpretation (GA.I.3). In particular,
metrics were reported to also work as a communication tools which enabled cross-disciplinary
discussions between landscape architects, developers, ecological consultants and LPAs. For the
EOs, biodiversity units provided clarity on losses and gains and worked as an ‘objective’
benchmark through which they could demand more mitigation. Moreover, both the SCC and
WDC EO argued that biodiversity units enabled them to move past restrictive qualitative
hierarchical approaches, based on statutory protected sites, and to justify compensation for
lower level biodiversity impacts. Furthermore, one NGO involved in the Gateway case suggested
that the use of a metric provided much more confidence that mitigation and enforcement would
be delivered (GA.I.3), rather than simply being at the discretion of the developer.
Box 7.3 Offsetting Metrics and Adherence to the Mitigation Hierarchy in EIA
7.3.1.4 The Nature of Offsetting Metrics
The CR2 and Gateway cases demonstrate that offsetting metrics were by no means a passive
addition to the EIA process. EOs appeared to be actively using offsetting metrics as a tool to hold
developers to account for mitigation proposals and challenge traditional elements of EIA,
particularly the traditional qualitative judgement based approach to impact identification and
significance. However, this positive perception of metrics was not universal:
“In Warwickshire, we’ve had a very good uptake of the calculation, and many
ecologists have said that they find it a very useful tool, but you do come across
The offsetting metric and the mitigation hierarchy:
A measure of mitigation (in)effectiveness: In relation to the mitigation hierarchy offsetting metric was
thought to work to provide a measure not only of the need for an offset but also a measure of on-site
mitigation effectiveness. This had two main impacts -
o No net loss target as an incentive to adhere to the mitigation hierarchy: By providing a
quantitative measure of the performance of the development, against no net loss, metrics worked to incentivise design changes on site and more on-site mitigation.
o Numbers empowering EO: By identifying where developers were ‘under-mitigating’ impacts the
metric helped EO to hold developers to account for their mitigation choices, and ask or more mitigation. Having a quantitative metric was argued to give EOs better bargaining positions.
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occasional ones who say that they do not see the need for a metric because EIA is
sufficient” (GA.I.2).
Not all EIA consultants were supportive of the switch from traditional qualitative approaches to
more quantitative ones, and some have, reportedly, been resistant to this change (GA.I.1).
Moreover, the validity and credibility of offsetting metrics were criticised by ecological
consultants in some of the case studies, particularly in the Gateway and Whitehouse Farm cases
which both applied the Defra metric.
What the Defra metric was actually measuring was perceived as questionable by some
consultants. There was evidence of a lack of buy-in to the ecological basis for the Defra metric
in the Whitehouse Farm case:
“I think my breakthrough point was when I saw it as a means of transferring money,
land value gains from development to conservation. If you look at it as a financial
tool it starts to make sense, whereas if you look at it as an ecological tool it makes
less sense. Once I had done the number crunching, I started to see that it provided
the structure that you could get decent ecological enhancement over an area of
land” (W.I.2).
Complaints about the simplicity of the metric were reported by the Environmental Audit
Committee’s investigation into national offsetting proposals in 2013 (see Chapter 5) and
highlighted in the Defra consultant feedback (Defra, 2016). For the NTYC EO neither qualitative
nor quantitative estimations of impacts can get it right. For instance, at the Whitehouse Farm
site the NTYC EO emphasised that although the qualitative communication understated the
impacts in the EIS, describing the Whitehouse Farm site as essentially a desert, the number of
biodiversity units calculated by the Defra metric were equally unrepresentative and effectively
overstated the impact. The ecological omissions of the Defra metric are similarly outlined in the
CEP and IEEP pilot evaluation (2016:34) as including connectivity and fragmentation, species and
features, accounting for mosaic, and loss of function.
However, the ecological consultants did not appear to be outright rejecting offsetting metrics
but highlighting that for them it was not really capturing biodiversity values. Two ecological
consultants saw metrics and offsetting as a structure for financial transfer, a “brown envelope”
(W.I.2). Although the ecological consultants for both the Gateway and Whitehouse Farm were
not entirely convinced by the science behind the approach, they still seemed to appreciate the
presence of the metric based on the idea that it “gave a fair deal for biodiversity” (W.I.2). To
some extent the WDC EO acknowledged this and highlighted that the offsetting metric is really
a measure of “land take” rather than biodiversity and that the Warwickshire metric has even
been described as a tax. In the Scottish Borders, there is no formal offsetting metric but instead,
a mitigation costing based approach to determine the monetary contribution required for the
measures which would have been taken on-site (G.I.1).
The Warwickshire PO emphasised that the metric is by no means set in stone but is being trialled,
tested and progressively improved:
“The Gateway is a very early attempt offsetting; it’s never going to be perfect from
the beginning. If Gateway was done now it would have a much higher value through
the offsetting metric” (GA.I.2).
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In Warwickshire they are reportedly now on version 18 of the metric. Highlighting that the
outcome of the metric very much liable to change based on the choice of parameters, ratios and
multipliers and weighting (GA.I.1). The exception to this perspective is the Somerset HEP which
takes a species based approach, such complaints about the metric were noticeably absent.
7.3.1.5 The Implications of Interactions between offsetting metrics and the EIA Process
The case studies suggest that the presence of offsetting metrics are actively influencing the EIA
process by affecting: impact identification, impact significance, and the mitigation hierarchy (see
Boxes 7.1, 7.2 and 7.3). Through exploring the relationship between EIA and metrics, it is
apparent that metrics have value for the EIA process beyond solely determining the need for an
offset. For EOs, offsetting metrics can help to raise the bar for biodiversity, incentivise more
mitigation on-site, and even generate a step change in thinking regarding impact significance
(Figure 7.6). For ecological consultants, metrics also appear to have practical value as a useful
tool to communicate and discuss development impacts and determine what is required in terms
of mitigation both on and off site. The presence of offsetting metrics can be seen as challenging
long-held concepts in EIA, questioning the place of qualitative judgement. Moreover, the switch
to a more quantitative measure of impacts also appeared to empower EOs to leverage more
mitigation, effectively changing the dynamics of the relationship between the LPA EO, ecological
consultants, and developers. Yet, the scientific validity of offsetting metrics, what it is actually
measuring, was clearly brought into question by EIA consultants. Although what offsetting
metrics are actually measuring is up for debate, metrics do appear to capture a different level
of impact, in that the impact was assessed to be significant enough to do something more than
was being proposed (W.I.2). The focus for the next section is to move on from offsetting metrics
to consider the interaction of option to offset off-site and the EIA process.
Figure 7.6 Summarising the Interaction Between EIA and Offsetting Metrics
New basis for asking
for more mitigation
Incorporating
offsetting metrics
into the EIA process
Impact
Identification
Impact
Significance
Mitigation
Hierarchy
New measure of
impacts and impact
significance
A new measure of
mitigation
effectiveness
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7.3.2 The Implications of the Option to Offsets Off-site
7.3.2.1 Offsets for Residual Impacts
The focus for this next section is to move beyond metrics and instead explore how the option to
offset impacts off-site interacted with the EIA process and the treatment of biodiversity impacts.
Firstly, offsets are understood as having a limited remit and widely referred to as only intended
to account for ‘residual losses’ or ‘residual significant impacts’ (e.g. ten Kate et al, 2004; Treweek
et al, 2009; Pilgrim et al, 2012; Defra, 2011). However, there are no definitive ideas about which
impacts should and should not be offset, in the UK context, and therefore EOs and project
proponents had a lot of discretion in this area. This first section discusses the nature and type of
impacts that offsets were used to address in relation to EIA. The proposals to use offsets as a
form of mitigation were linked to a range of different impacts, shown in Table 7.2. There were,
however, some clear similarities between these impacts.
Table 7.2. Impacts that Offsets Were Used to Address in the Case Studies
In both the Glenkerie and Whitehouse Farm cases the application of an offset was clearly linked
to Local Biodiversity Action Plan (LBAP) habitats and species (Glenkerie EIS, 2007; Whitehouse
Farm EIS, 2011, G.I.1). The LBAP label indicates that an ecological feature is likely to be locally
important (Biodiversity Planning Toolkit, 2016). In the Glenkerie case, this was by the design of
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the LPA EO. While in the Whitehouse Farm case offsetting for the LBAP habitat was the
incidental result of ad hoc offsetting. The focus on local impacts is also inherent in the Gateway
case where offsetting was designed as a measure of general land take a local concern for the
WDC EO (GA.I.1, GA.I.3). This suggests that offsets have not been applied for high-value
biodiversity such as designated sites (SSSI, SPAs) or ancient woodlands, which ecological
consultants refer to as “show stoppers” or grounds for refusal (G.I.1). The contrasting case to
this conclusion is CR2, where although an offset was not required, the application of HEP metric
was linked to EPS and therefore impacts of international level significance, however the EO again
talked about the landscape impact on EPS as being a local impact due to the high level of EPS in
the Somerset district.
Not only were the impacts that offsets were applied for strongly associated with local level
significance they were all considered ‘unavoidable impacts’. At both the Gateway and
Whitehouse Farm the unavoidable aspect of the impact derived from the fundamental change
in the nature of the site, from arable to residential in the Whitehouse Farm case (Whitehouse
Farm EIS, 2011) and from brownfield to industrial in the Gateway case (The Gateway EIS, 2013).
At Glenkerie the impact was also deemed unavoidable by the ecological consultant due to the
topography of the site combined with health and safety limitations. Furthermore, the impact
was not considered significant enough to refuse planning permission by the Glenkerie EO, but
could not be accounted for on-site due to the lack of suitable habitat for restoration.
“This loss would have just been written off otherwise. They would have just said we
can’t deal with it, and we would have had to agree that there was no reasonable
way of dealing with it. The habitat loss would have occurred and nothing would
have been returned. So we are actually pushing the boundaries through requiring
developers to offset” (G.I.1).
In the absence of the option to offset, the EO at the Glenkerie case argued that these impacts
would have simply been written-off without any direct mitigation. Equally, at the inquiry for
Whitehouse Farm the unavoidable nature of the impact meant that the developer originally
decided to simply accept the residual impact on arable farmland birds, “taking the impact on
farmland birds on the chin” (Whitehouse Farm Planning Inspector Report, 2014: para155:35).
The unavoidable nature of these impacts presented offsets as a positive addition and a move
beyond the traditional remit of EIA.
These three cases portray unavoidable impacts as an inescapable product of circumstance, the
result of the placement of habitats on-site, design constraints and inherent contradictions
between development and biodiversity. However, other aspects of the case studies suggest the
term ‘unavoidable’ is somewhat misleading in its decisiveness.
“The developers wanted housing over as much of the site as possible there was no
way you were going to be able to maintain habitat for species such as grey partridge
and lapwing” (W.I.2).
For Whitehouse Farm, the unavoidable nature of the impact was linked to the fundamental
change in nature of the site land use but also the need to ensure profitability by maximising the
housing units on-site. Equally, at Glenkerie the ecological consultant argued that more could
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have been done on-site but that moving to off-site compensation was seen as an easier option,
which “made everybody happy” (G.I.3). While, at the Gateway the remaining residual loss of
32.7 biodiversity units translated into an area of approximately 7ha, given that the total site area
of 208ha this lack of willingness to account for 7ha was perceived by opponents as prioritising
the maximum development footprint with no space left for ecology (The Gateway Inquiry
Report, 2015: para733).
Looking into these impacts in more detail suggests that their ‘unavoidable’ classification as
entirely inescapable does not hold true. Instead, the unavoidable nature of these impacts are
the product of trade-offs when mitigation comes into conflict with profitability, and derived
from situations where on-site compensation is particularly challenging or would require a
significant redesign. Therefore, to some degree, the presence of offsets can be seen to have
extended the scope of EIA capturing additional impacts and pushing developers to account for
rather than ignore impacts. However, the validity of the label ‘unavoidable’ is questionable and
the presence of offsetting is also facilitating trade-offs and value choices between economic
gains and biodiversity, offering an easy way out for developers where on-site mitigation
becomes difficult.
Box 7.4 Offsets and Impacts
7.3.2.2 Offsets and Impact Significance
Not only were offsets associated with local and unavoidable impacts, but in the two cases, the
requirement for offsets were clustered around minor to moderate levels of impact significance
(Table 7.2).
“Your justification for demanding offsetting depends on what sort of impact you
have. If we are losing highly degraded but low-value habitat it is difficult to make a
case for an offset. If it is a high-value site then it is off limits. At Glenkerie it was
degraded blanket bog, a local issue of moderate significance, and therefore it was
appropriate for offsetting” (G.I.1).
Making a case for requiring an offset was by no means easy for the Glenkerie EO, but appeared
to rely on having a just the right level of impact significance, not too high, not too low, but just
right (G.I.1). Equally, in Whitehouse Farm case the low, parish, level of significance attributed to
the impact on arable birds, in the EIA, was used by the developers as an initial argument against
the need to offset (Whitehouse Farm Inquiry Report, 2012). Leveraging a commitment to offset
Offsite offset and impacts
Extending the scope of EIA through offset: Offsets were used in the case studies for impacts considered
‘unavoidable’ and ‘local’ in nature, it was argued that in the absence of offsetting these impacts would have been ignored and therefore the presence of offset led to additional mitigation taking place
o Offset for Unavoidable impacts: By linking offsets to impacts deemed unavoidable this provided
an impression of a black and white case for the need for offset, but the unavoidable impacts
were also linked to trade-offs, value judgements, profits margins and the notion of what level of
mitigation is reasonable to require.
o Offsets linked to having the ‘right kind of impacts’: EO highlighted the difficulties of leveraging offsets and the need for the specific kind of impacts, on the right kinds of habitats and species.
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at the Whitehouse Farm case necessitated the re-designation of the impact at the planning
inquiry.
This link between the requirement to offset and specific levels of impact significance made the
application of offsetting highly dependent on the subjective expert judgement, dependent on
different stakeholders’ perspectives and positions to leverage an offset.
“Significance was a moot point for Glenkerie. Blanket Bog is an Annex 1 habitat
under European law and should be protected. The problem is that its definition is up
for debate, and this particular site didn't comply with a lot of the definitions.
Therefore, the initial valuation of the blanket bog was reasonably low. When the
statutory authority stepped in they took the view that if a degraded habitat can be
restored then it should be valued as if it was an entire habitat, and said you are
going to have to do something about it” (G.I.3)
This relationship between the off-site offset and EIA significance appears to allow certain actors
to have considerable influence over the impacts that offsets were used to address, a clear
contrast to more metric orientated offsetting were biodiversity units were seen as a new way of
identifying impact significance (7.3.1.2).
Box 7.5 Offsets and Impact Significance
7.3.2.3 Off-site Offsets as Components of the Mitigation Hierarchy
In terms of impact coverage, Section 7.3.2.1 suggested that the option to offset offsite may have
generated more mitigation by accounting for impacts that may otherwise have been ignored.
However, one of the major concerns around the introduction of the offsetting was its potential
effect on the mitigation hierarchy, specifically the requirement to first avoid and mitigate for
impacts on-site prior to offsetting off-site (e.g. Clare et al. 2011). In the case studies, the
presence of offsets as an offsite solution to unavoidable impacts was found to have a complex
relationship with the mitigation hierarchy in the case studies, interacting with the adherence to
the mitigation hierarchy in a number of different ways.
Firstly, in the Gateway case the EO highlighted one relatively positive result of the presence of
offsets:
“The site is next to the airport and the Airport Association did not want the ponds
put back on-site. These pools provide winter habitats for bird species so we said that
they had to offset and create ponds at a nearby site. Then they asked how much I
thought it would cost. I phoned up the RSPB and they said it comes to about £5
million in total. When FCPR reported this to the developer, the ponds were put back
Offsite offsets and impact significance:
Justifying offsets is linked to subjective levels of impact significance in EIA: The impacts that offsets have
been used to address are clustered around certain levels of impact significance, moderate to minor.
Leveraging commitments to offset from developers requires the correct level of impact significance. This
means offsets can be linked into the subjective debates on impact significance in EIA, variably depending on stakeholder’s positions and perspectives within structured parameters.
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in the on-site compensation plans in a few seconds flat. The projected costs
dropped-down. Offsetting puts a value on nature and it’s very effective” (GA.I.1).
For the Gateway the threat of having to pay for a potentially expensive offset was sufficient to
incentivise more mitigation to be recreated on-site, effectively offsets worked as a cost
deterrent and arguably helped to reinforce on-site mitigation commitments. However, such
positive effects on the mitigation hierarchy were not true across all of the cases.
In cases such as Whitehouse Farm, the prospective costs of offsetting did not appear to have
been discussed prior to decision making and, therefore, the potential for offsets to work as a
cost deterrent was missed. Equally, in cases such as Glenkerie the costs were lower enough
(around £50,000, Glenkerie Landscape and Habitat Management Plan (2008); G.I.2) that the
developers were willing to finance off-site offsets. Furthermore, the requirement to finance an
offset at Glenkerie managed to have negative side-effects on the mitigation hierarchy:
“I had to re-work the budget for the on-site work because they were giving a lump
sum to the council for the offsetting scheme. Because they had a figure in mind
already that they wanted to spend offsetting just ate into that budget for what we
did on-site. So offsetting did mean that we spent less on on-site mitigation” (G.I.3).
The unexpected requirement to finance an offset for Glenkerie reportedly acted to indirectly
undermine the mitigation hierarchy by reducing the amount of money available for the on-site
mitigation. The contrast between these two cases shows that the relationship between cost,
offsets, and the mitigation hierarchy is by no means clear cut. The cost-threat of offsetting may
deter developers when it is high enough and when it is outlined early on in the EIA process.
However, where offsets are brought in at a late stage in the EIA process their costs can indirectly,
and unintentionally, undermine the mitigation hierarchy, even when they are applied as a last
resort.
Although the threat of having to offset in the Gateway case was reported to have had a positive
effect on the lower end of the mitigation hierarchy, and even led to more on-site compensation
and restoration of habitats. The presence of the option to offset also appeared to have had
negative consequences for the higher tiers of the hierarchy, and one NGO member highlighted
that:
“When we first came across this project the general attitude was that it was going
ahead, a done deal, and we had to get on compensation straightaway to get the
best possible deal. Because the offsetting scheme is available, then compensation
seemed to be a straightforward route. In hindsight, if we had taken a step back and
thought about whether this site should have been used, we would have put more in
our consultation response about avoidance” (GA.I.3).
The Community Group for the Gateway suggested that the developers had misused offsetting
and ignored steps 1 and 2 of the mitigation hierarchy, effectively jumping straight to offsetting
at the expense of trying to avoid impacts (The Gateway Inquiry Report, 2015: para730).
In the inquiry both the developer, ecological consultants, and the WCC EO acknowledged that
the offsetting metric had been used throughout the EIA process but argued that this was not the
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misuse of offsetting as the application of an offsetting metric does not imply an intention to
offset (see The Gateway Inquiry Report, 2015: para232). They also highlighted that the impact
that the offset was used to account for amounted to only 32.7 units out of a total of 1207 units,
3% of the area of the site and therefore that offsetting does not enable the acceptability of the
development. This may all be true but looking at the Gateway EIS (2012) it is evident that the
majority of on-site measures were compensation-based, with 105 ha of habitat restoration and
enhancement planned on-site, indicating that out of a 208ha site little has been preserved.
Therefore, the offset component may not have enabled the acceptability of the project or
directly undermined the mitigation hierarchy, but may instead have led indirectly to a greater
focus on compensation measures on-site at the expense of avoidance (GA.I.3). Whether any
greater consideration of avoidance would have taken place without offsetting is an unknown.
However, the Gateway case shows that in situations where there are short timescale for the
planning application the presence of offset may increase the opportunity for officials to skip past
avoidance and focus on compensation, both on-site and off-site.
Finally, proposals to undertake an off-site offsets, in both the Glenkerie and Whitehouse Farm
cases, occurred alongside reports of concerns regarding the adequacy of on-site mitigation.
“They had a tree lined avenue going across the site which was the ‘connectivity’ but
underneath it, there was the bicycle route and footpath with lighting going along
the supposed wildlife corridor. So it was actually a row of trees and a path, it wasn’t
mitigation or a wildlife corridor” (W.I.3).
At Whitehouse Farm one NGO member was clearly concerned about the effectiveness of the
main mitigation measures proposed on-site, these concerns were also evident at the planning
inquiry where the council questioned the extent of on-site mitigations benefits for biodiversity
(Whitehouse Farm Inquiry Report, 2012 para155/156). The perceived ineffectiveness of the on-
site mitigation was used by the Planning Inspector for Whitehouse Farm as an argument for the
need for offsets (Whitehouse Farm Inquiry Report, 2012: 156,157). Equally, in Glenkerie the
presence of the offset was also associated with on-site mitigation measures which were
considered by ecological consultant unlikely to be implemented or implemented poorly as a
consequence of an un-cooperative site-manager.
Therefore, for some interviewees in these case studies, the link between offset and reports of
ineffective mitigation mean that the presence of offset was working as an ‘easy way out’ or a
‘quick fix’ for the developers, rather than improving on-site mitigation they could instead move
off-site. However, for the NTY EO the presence of the requirement to offset was seen as much
more of a penalty:
“It gave them a bit of a kicking from a planning point of view, it has hopefully taught
them a bit of a lesson” (W.I.1).
A lesson, or future deterrent, to developers, which in the long term was thought to have
the potential to generate behavioural change and future adherence to the mitigation
hierarchy (G.I.1).
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Box 7.6 Offsets and Adherence to the Mitigation Hierarchy in EIA
7.3.2.4 The Implications of Off-site Offsets as a Component of the EIA Process
Moving compensation off-site represents a considerable shift in thinking for the EIA framework
which has traditionally concentrated efforts within project boundary. Exploring the interactions
in the cases studies suggests that off-site offsets have not been easily subsumed within the EIA
framework. In fact, the relationship between EIA and offsets, portrayed in the case studies, is
convoluted and hard to pin down as having one definitive outcome. What is apparent is that the
presence of offset can challenge pre-existing parameters and assumptions in EIA that local,
residual and unavoidable impacts can be reasonably ignored. By widening the remit of EIA, the
presence of offsets could generate a step change in thinking around the acceptability of
biodiversity impacts.
However, the case studies also suggest that leveraging commitments to offset from developers
is connected to a having a specific level of impact significance, and therefore when brought in
at a late stage in the EIA process the requirement to offset can be heavily dependent on
subjective discussions and nuances around the attribution of impact significance in EIA.
Furthermore, the credibility of offsets is also bought into question by their link to the label
unavoidable impacts, which appears to mask trade-offs and the use of offsets as an ‘easy way
out’. Although the option to offset off-site may a greater quantity of mitigation the presence of
offsetting does not necessarily always have a positive relationship with the mitigation hierarchy.
In some situations, offsets can undermine the mitigation hierarchy, indirectly through
influencing project costs and more seriously by distracting attention away from early stages of
the hierarchy. In particular, these characteristics appear to be facilitated through existing poor
levels of adherence to the mitigation hierarchy in EIA, and contextual factors such as timing or
stage that EIA is introduced, political willpower and project time-frames. Yet, it must also be
noted that developers in these cases did not appear to be jumping on the chance to offset to
apply it to circumvent the mitigation hierarchy, but these negative effects have been more
incidental than by design.
Offsite offsets and the mitigation hierarchy:
Offsets have a complex relationship with the mitigation hierarchy: The relationship between offsets and
the mitigation hierarchy appears to vary depending on how offsetting and EIA are used together, the stage
that offsets are introduced in the planning systems and also wider contextual factors such as political pressure and the overall timescale of the planning application.
o Offsets and project costs: When integrated early into the EIA process offsets, and if costs are high
enough, the prospect of offsetting can be a cost deterrent and incentivise greater efforts to retain
habitats on-site through increased mitigation and on-site compensation. When offsets are
introduced late on in the EIA and planning application process they can indirectly undermine the mitigation hierarchy by affected the financial budget for on-site mitigation measures.
o Distracting attention away from avoidance and mitigation efforts: In situations where project
timescales are restricted and there is considerable political will power behind project then the
presence of offsetting can lead to a greater emphasis on the end of the mitigation hierarchy, not
necessarily on off-site offsets per se but on compensation both on and off-site at the expense of consideration of avoidance.
o Offsets linked to (in)effective on-site mitigation: Offsets can occur alongside concern around
(in)effective on-site mitigation. Whether an offset is an ‘easy way out’ or a ‘penalty’ is unclear and dependent on the position of actors involved.
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Table 7.3 Comparing the Implications of Metric-based Offsetting and Off-site Offsets with EIA
7.3.3 Causal Connections: Linking Interpretations and Implications
This section has analysed the causal connections between the EIA process and the two different
interpretations of offsetting identified in Section 7.2; offsetting applied primarily as a metric or
methodology and offsetting as an off-site mitigation solution. The case studies show that these
two different formulations of the value and purpose of offsetting have clearly resulted in quite
different relationships with the EIA process and EIA consultants (e.g. 7.3.1.5 and 7.3.2.4, Table
7.3). One of the clearest examples of this is their relationship with impact significance. Where
offsetting is applied primarily based in its value as a metric it can introduce new interpretations
and benchmarks for impact significance. In contrast, where offsets are bolted on to the EIA
process as an off-site solution they are dependent on existing interpretation and subjective
judgement on impact significance within the EIA process. Evidently, different structural
approaches and interpretation of offsetting are resulting in quite different interactions with the
EIA process, and very different outcomes for biodiversity impacts.
Generally, metric-based offsetting appears to have a broadly positive relationship with the EIA
framework, shaping and influence the existing EIA process, echoing more general findings of the
CEP and IEEP Pilot report (2016) (see Table 7.2). In comparison, the relationship between EIA
and offsite offsetting was much more two-way and mixed in nature. However, there are also
commonalities in their relationship with EIA, and both forms of offsetting show the potential to
have a considerable level of engagement with the EIA process, an active rather than passive
relationship. Furthermore, both forms of offsetting show the potential to challenge existing or
traditional aspects of EIA, particularly assumptions about impact acceptability. Moreover, they
both show that engagement concentrates on three fundamental aspects of the EIA process;
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impact identification, impact significance and the mitigation hierarchy. Finally, both the
reported beneficial effects of offsetting metrics and the outcomes of off-site offsets are thought
to be highly conditional on certain aspects such as the timing and stage of the planning
application process that offsetting is introduced, the degree of design flexibility, the personality
of EOs involved, and even the willingness of EIA consultants and developers to take up offsetting.
7.4 Substantive Connections for Decision-Making
Through exploring causal and structural connections this Chapter has, thus far, investigated how
offsetting and EIA have begun to work together and identified some of the main implications of
their interaction. It is also possible to explore more substantive connections which result from
the interaction between EIA and offsetting, particularly the extent to which offsetting has led to
‘greener’ decisions on developments. The term ‘substantive’ is used here to refer to a sense of
the wider or more overarching purpose of these two mechanisms. The remit for this section was
to unpick the interaction between offsetting, EIA and decision-making, looking for direct and
indirect ways in which offsetting played a part in decision-making and any connection with EIA
or EIS.
7.4.1 Interactions Between Offsetting, EIA and Decision-making
In two of the case studies the EIS was found to work as a mechanism to integrate offsetting
commitments into decision-making. In the Glenkerie case, the commitment to offset was
included as a planning condition in the landscape and habitat management plan adjoining the
EIS. Therefore, the EIS provided a vehicle for integrating offsetting into decision-making,
however any discussion and debate surrounding the application of offsetting had effectively
been resolved prior to decision-making through the EIA consultation (Planning application
07/02478/FULEO response 17 April 2008). This use of the EIA proces was also apparent in the
CR2 case where the results of the HEP calculations were simply included in the EIS as a statement
that there was no impact on Lesser and Greater Horseshoe Bats (CR2 EIS, 2013: para438).
Including the offsetting calculations in the EIS effectively presented this impact as a closed or
technically resolved issue that required no further discussion. Therefore, the HEP metric
effectively made the EIS much more decision-making tool in contrast to the traditional decision-
informing remit of EIA. Through its incorporation into the EIS the application of the HEP does
not try to change decision-makers’ considerations of biodiversity value but attempts to resolve
biodiversity issues outside the decision-making framework, and provides assurance for the
assessor that the impact has already been dealt with. Therefore, the inclusion of offsetting
metric results and commitments in the EIS of these case studies appears to almost bypassing
deliberation in decision-making.
In contrast, the presence of offsetting in decision-making was much more notable in the
Gateway and the Whitehouse Farm cases, as in both cases the inclusion of offsetting generated
considerable controversy during decision-making. For the Gateway case, incorporating the
Warwickshire metric into the EIS was interpreted by the local resident's group as the intention
to offset from the beginning (The Gateway Inquiry Report, 2015:para730; The Gateway
Community Group, 2015). Effectively, the use of the Warwickshire metric was seen as an
attempt to bypass the mitigation hierarchy, an instance of the misuse of offsetting to imply false
environmental credentials (The Gateway Inquiry Report, 2015:730).
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“The ecology witness contends that the scheme is not acceptable because the metric
suggests that some off-site habitat creation or enhancement is required. This
misunderstands the very objective of the offsetting metric and fails to recognise that
the off-site additional compensation demonstrates net enhancement utilising the
metric” (The Gateway Inquiry Report, 2015: para234).
Despite the fact that the offset was only use to account for some 3% of the overall impact of the
project (Gateway Inquiry Report, 2015: para909; Gateway EIS, 2013), there was a clear
perception by community groups in the Gateway case that offsetting had had a considerable
influence on the development decision. For the WDC EO, this controversy resulted from
stakeholders conflating the use of offsetting metrics in the EIA process with the intention to
offset, a misunderstanding of the nature of offsetting metrics driven by controversies around
offsetting (Gateway Inquiry Report, 2015). In the end, the presence of offsetting did not enhance
the developer case and the council’s approval was overturned at the appeal based on the impact
on the green belt (Gateway Inquiry Report, 2015).
There were equal levels of confusion about the degree to which offsetting influenced decision
making in the Whitehouse Farm case. The case was initially rejected (North Tyneside Council
(2012) Application no 11/02337/FUL) then offsetting was brought in at the appeal and the case
was subsequently approved by the Planning Inspector (DCLG, 2013 decision number
APP/W4515/A/12/2175554). An apparently black and white case for offsetting being used as a
permit for planning permission. Whether or not it was the offset that made the development
acceptable was, however, questionable.
“I think that biodiversity offsetting became almost an easy way out for the inspector
it was heading towards it being a finally balanced decision - but with biodiversity
offsetting added into the pot it made the decision easier” (W.I.2).
Rather than overturning the decision, the option to offset was argued to have been used as a
means to help to account for, or demolish, one of the remaining arguments against the
development. The opponents to the case argued that the offset had distracted attention away
from some of their fundamental arguments against the development, particularly social and
community impacts such as the loss of space, community identify and tranquillity (W.I.4).
However, by providing an offset the developer was also complying with an earlier request for
compensation made by the EO during the EIA consultation, which had not been included in the
EIS (Whitehouse Farm Planning Inquiry, 2013:730). Therefore, the influence of offsetting on
decision making is often far from clear.
One particularly notable area of the relationship between offsetting and decision-making was
that enforcing commitments to offsetting appeared to necessitate particularly astute
negotiators:
“The council effectively ‘sold’ their scheme to the developer, who then had to sign
up if they wanted planning permission” (G.I.3).
The application of offsetting required considerable negotiation power from the LPA EO in the
Glenkerie case, to bargain the offset commitment against planning permission. The ecological
consultant was described the EO as “very astute” and “hard-nosed”. These traits were also
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apparent in the Somerset EO who emphasised that “I sort of enforce the HEP myself”. In
comparison at Whitehouse Farm:
“We kept asking for more and more mitigation, but we reached a bit of a standstill.
I was always on the back-foot. I set out quite clearly that they needed to consult
with the NWT and the NHSN about finding off-site mitigation sites. They just said
we can’t find anything, so we’re not doing anything more, we’ve given you
everything we are going to give you” (W.I.1).
Although the idea of undertaking off-site compensation had already been proposed in principle
during the consultation on the EIA (Whitehouse Farm Inquiry Report, 2013:157) off-site
compensation was not made a necessary condition for planning permission and the
developers/ecological consultants were not persuaded to offer compensation. It was only the
refusal of planning permission by the NTYC planning committee which drove the developer to
voluntarily introduce offsetting on their own terms, as a means to leverage planning permission
(W.I.2, W.I.1). Despite proposing offsetting the developers appeared to remain extremely
reluctant, arguing against the necessity to offset during the appeal (W.I.2; Whitehouse Farm
Planning Inquiry Report, 2013: para170).
As offsetting is currently voluntary in the UK context the requirement to offsets for residual
impacts sits outside formal policy and legislative triggers and traditional conceptions of impacts
which require mitigation under the EIA framework. For the case studies, this meant that
planning permission, or recommendation for planning permission, was often used as a necessary
bargaining chip by Eos to leverage commitments to offset. Moreover, leveraging the voluntary
requirement to offset may need particularly astute or hardnosed EOs, with considerable
negotiating power.
Finally, the presence of offsetting, particularly the use of the metric, was also found to influence
stakeholder engagement in the decision-making process:
“Even if you ask sensible questions at planning committees they seem to answer
with jargon. The whole point of having a metric is that there should not be
alternative views” (C.I.4).
One NGO member, in the CR2 case study, felt technically excluded by the presence of the HEP
metric in the EIS. Arguing that the presence of the metric closed spaces for stakeholder
discussion of impacts and therefore public participation. This NGO member also emphasised
that he felt that the whole point of metrics was not to have alternative views. This perspective
was also echoed by a local resident group in the Whitehouse Farm case, who stressed that it felt
like metrics were being used to “blind you with science” and spoke of the “mystique of figures”.
The degree of influence of offsetting over planning permission clearly varied between the case
studies. In the Gateway case, both the WDC EO and PO perceived that by valuing biodiversity
this makes it more visible and tangible to decision makers, effectively arguing that offsetting
enhances the profile of biodiversity impacts in decision-making.
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“Biodiversity has been a material consideration for a while but biodiversity
offsetting strengthens its position in the planning process, it most definitely helps
put biodiversity at the heart of planning” (G.I.1).
Equally, despite the controversies around offsetting the EO for the Whitehouse farm case
considered that the council had actually “done well out of the scheme”.
However, the evidence for offsetting having a positive influence on decision making was not
readily apparent. Moreover, this perspective was not universally supported.
“Not that I’m aware of no, they haven’t been involved. The problem that I have is
that the council isn’t very green, and I don’t think offsetting has affected this at
all” (C.I.1).
For the Somerset EO neither the Somerset nor Sedgemoor District Council Committee members
had been significantly affected by the presence of offsetting thus far. Offsetting may, however,
generate more long term benefits through raising awareness around lower value biodiversity
impacts, and changing mindsets around the acceptability of residual losses. The NTC EO certainly
suggested that the Whitehouse Farm case caused quite a stir locally about the acceptability of
residual impacts, and could potentially generate a step change in thinking around the
acceptability of impacts. Moreover, in the aftermath of the Whitehouse Farm case, the
ecological consultant stated they would now be advising clients that they may need to account
for these kinds of impacts (W.I.2). Therefore, offsetting could potentially influence decision-
making on a more long term scale.
7.4.2 The Presence and Influence of Offsetting in Decision-Making
Analysing the substantive connections between EIA, offsetting and decision-making presents a
rather convoluted picture. In some of the case studies, offsetting appears to have either been
subsumed within EIS planning commitments and subsequently ignored or accepted in decision-
making. Alternatively, in other cases offsetting has generated considerable controversy in
planning appeals and decision-making. Where offsets are subsumed within EIA, the presence of
offsetting could potentially present a shift in ideas around EIA role and relation to decision-
making, making EIS more decision-forcing or decision-making through offsetting commitments.
In cases where offsets have played an active role in decision-making, they have generated
considerable debate about their acceptability. Nevertheless, the extent that they influenced
decision consent is hard to establish.
The controversial nature of offsetting means that offset proposals have in some case been
subject to undue levels of scrutiny and the presence of biodiversity offsetting metrics in EIS can
easily be misinterpreted as an intention to offset. Offsets may not completely overturn decisions
but offsetting did show the potential to demolish remaining arguments against planning
permission, tilting the playing field for decision-makers by offering a ‘quick fix’ in finely balanced
decisions. Yet, it is hard to say this there are black and white case for the use of offsetting as a
permit for permission and developers were often reluctant to commit to offsetting.
Furthermore, there is also potential that offsets will have a more of a long-term positive
influence over cases, rather than shaping short term decision approval. By changing opinions
around the acceptability of residual impacts, offsets could effectively generate a longer term
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effect on decision-making. However, at present to leverage commitments to offset from
developers requires some degree of relationship between offsets and planning permission, with
EOs’ bartering the requirement to offset against their position to recommend projects for
approval. EOs position, persuasive ability and ‘hard bargaining’, were all closely linked to
leveraging voluntary commitments to offset from developers. One of the clear negative effects
on decision-making was that the presence of the metric appeared to have the potential to
technically excluded local residents, interest groups and NGOs perspectives on impacts.
7.5 Delivery Connections Between EIA and Offsetting
The final area of analysis for the case studies was the connection between EIA and the
enactment or delivery of offsets. The aim of this section was to trace the case studies through
to completion and explore the process of translating biodiversity units or commitments in
planning conditions into final habitat restoration sites. Delivering offsets involves the conversion
of biodiversity units into the habitat plans and priorities and then final sites, restoration works
and long term maintenance (ten Kate et al, 2004). The delivery of offsets is guided by a number
of principles of best practice, such as ensuring offsets are equivalent, additional and in-
perpetuity, and that their delivery is undertaken in an open and transparent manner.
Furthermore, offset delivery is also linked into landscape-scale conservation planning and
idealised as a strategic or smarter form of mitigation through which to generate greater benefits
for biodiversity (Kiesecker et al, 2009, 2010). However, existing mitigation practice is reported
to suffer from a lack of implementation. Hill (2013:8) reports that only 30% of mitigation
schemes are ever implemented and that mitigation promises are often perceived as discretional
by developers (Morrison-Saunders et al., 1999; Tinker et al., 2015). Therefore, implementation
is a notoriously weak aspect of both the EIA process and the broader planning system, the term
‘mitigation myth’ was used by interviewees to describe the gap between planning commitments
to mitigate and construction realities. This section provides an opportunity to explore the
implementation challenges in the conversion of biodiversity units into green gains, and the place
of EIA in this process. However, the data available is relatively limited, as not all of the case
studies moved into the delivery stage (See Table 7.1) due to issues with financing or the rebuttal
of planning permission at inquiries.
7.5.1 Converting Offsets from Planning Commitments to Restoration Realities
The two case studies that achieved planning permission proceeded to implement offsets
through very different formats and with different degrees of connection to the EIA process. In
one case through an offset provider and in the other in-house by the developer. In the Glenkerie
case, to discharge the offsetting commitments under the SBC Offsetting Initiative, the developer
transferred funding to the Council through a Section 69 agreement (G.I.1). This approach
enabled the developer to make a financial contribution without needing to have a confirmed
site and shifted the burden of responsibility for implementation to the council (G.I.1). To deliver
the offset commitments the SBC worked with an established networks of partners, employing
offsets to contribute to existing schemes rather than setting up fresh schemes for each offset
(Tharme and Aikman, 2012; G.I.1). In Glenkerie the offset delivery partner was a local NGO and
after transferring responsibility to this partner the SBC had relatively little further influence and
involvement in offset design and implementation, only represented as a steering group and the
developer as an interested party (G.I.1). Therefore, these established partners were seen as key
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to the success of the schemes, and the EO highlighted that “if we didn't have those partners out
there we wouldn't take this responsibility” (G.I.1). The offset was then achieved through
‘borrowing sites’ and developing environmental stewardship agreements with landowners
(G.I.2).
In the Whitehouse Farm case, the realisation of the commitment to offset was very much the
responsibility of the developer who opted to lead the process themselves using the Environment
Bank (EB), to provide additional expertise on offsetting and site selection (Whitehouse Farm
Planning Inquiry, 2013: para160). The developer also continued partnership with the EIA
ecological consultants who completed the EIS, who undertook site visits for the EB and authored
the habitat management plans. While the NTYC set up an offset search group (W.I.1; W.I.3) with
the aim to include council members and NGOs in offset design and delivery, as a means to try to
ensure that offset site selection was undertaken in an accountable and transparent manner
(W.I.4). The final offset was achieved through site purchase, with the developer undertaking the
main restoration works prior to finding a long term manager.
Table 7.4 Implementation and Delivery of Offsets in the Case Studies
In these two cases, the role of the EIA process and consultants in the delivery of offsets was
distinctly different. In the Glenkerie case, there was very little in terms of links back to the EIA
process. Instead, the offset delivery process was highly linear, with the responsibility for the
offset delivery passed from the developer to the council and then onto to the offset provider.
This meant that there was no further substantial involvement of the EIA consultants or EIA
findings in the offset delivery (G.I.2; G.I.1). This format resulted in considerable division between
the restoration methodologies outlined by EIA ecological consultants in the EIS (Glenkerie
Outline Landscape and Habitat Management Plan, 2008:25) and the methodology delivered by
the offset broker (Tweed Forum, 2011). Such difference between mitigation promises and
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construction realities is not unheard of and is referred to as part of the ‘mitigation myth’ (G.I.3).
However, for the offset provider this disconnect between condition and delivery was not ideal:
“I think it would be great if people like us could be more involved in the process,
perhaps the negotiation or perhaps telling the developer what we can offer” (G.I.2).
The offset provider emphasised the EIA conditions and mitigation promises might assure
planning permission but they are not necessarily feasible, or sufficiently flexible for practice. To
ensure feasible proposals come through the planning application process the offset provider
suggested the need for a closer connection between environmental restoration practitioners
and the EIA consultants and process. In comparison in the Whitehouse Farm case, EIA
consultants were much more involved in the offset design, actively taking part in surveying
prospective offsets sites and developing habitat management plans. However, the NTYC EO
questioned the appropriateness of the involvement of EIA consultants in offset delivery, and
whether the consultants were perversely benefiting from offsetting.
Therefore, who exactly should be involved in offsetting delivery and design, and to what extent,
is a key question for future offset delivery. In the Gateway case, initial offset proposals were
linked to two distinctly different design iterations, orientated towards quite different habitats
restoration objectives. This change in offset design was reported to reflect the influence of the
consultation with stakeholder leading to a switch in the habitat focus (GA.I.3). However, for the
Warwickshire project officer (PO) this was not ideal:
“The decision for the offset to be species rich grassland wasn’t made by me. Usually,
I get a copy of the calculator, talk to the ecologist who completed it and I can
interpret that. We haven’t been involving people like the wildlife trust because it’s
not their decision, it’s a planning decision. Offset designs go to the LPA for approval,
we might involve the WT but only for particular contentious sites” (GA.I.2).
The PO saw offset design as a ‘technical’ or ‘expert issue’. In fact, under the Warwickshire model
offset design is set to become progressively more calculative. Since the Gateway case, the WDC
team have developed an additional element in the metric calculation to automatically determine
the percentage loss of each habitat and, therefore, automate the design parameters of offset
delivery (GA.I.1; GA.I.2). In comparison, the NGOs interviewed highlighted that offset design
needs oversight, stressing that where there is compensation there should be some
consideration from the public. Therefore, as offsets are generally finalised after planning
permission there is currently a shortfall as the system does not really allow for a community
voice or consultant on offset design.
How decisions on offsetting design and delivery take place, and who is involved, also appears
likely to be heavily shaped by the dynamics of land ownership markets. In the Whitehouse Farm
case to ensure that site selection was transparent the local council set up an offset search group,
to ensure interest group and the council were involved in the implementation process. However,
when a favoured site was finally agreed upon by the search group, the land owner got wind of
that this was an offsetting scheme and quadrupled the price (W.I.1).
When the price went up on the favoured site nobody came and communicate that
to us. All these months of negotiation and scoring. The suddenly they went and just
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bought another site. It hadn’t even been on the list or approved by the group. Yes,
it met all of the criteria, so it was alright but the idea was that it was all supposed
to be above board, so there was a problem with process” (W.I.1).
Instead of moving back to the list of pre-agreed sites, the developer opted to buy a different the
site quickly to avoid the chance of another price hike by the land owner. For the rest of the
search group, this undermined their purpose and made the offset look like a handout. This
emphasised that the process was just as important as the outcome (W.I.1; W.I.3). One local NGO
remains unconvinced by the final offset site, as the speed at which the site came forward meant
that there was little opportunity for strategic consideration and since the site was purchased
there has already had a draft application for developments adjacent to the site which is thought
to erode its value for biodiversity.
Equally, in the Glenkerie case the offset provider highlighted that:
“It was difficult finding places to work with peat. We spent a long time, 18 months,
building up a Scottish Rural Development Programme plan working with a big
estate to restore 100 ha of peat– we worked very hard on that and it fell through”
(G.I.2).
In the Glenkerie case, site selection was further complicated by the land ownership market. After
original plans fell through, the offset providers found it impossible to achieve a like-for-like offset
within the project timescale, and instead shifted to a like-for-unlike approach and the offset
funds were largely used to contribute to an existing natural flood management scheme, along
with one smaller bog restoration site (4.5ha) (G.I.2). Therefore, land ownership dynamics can
prevent the achievement of an open and transparent offsetting process and moreover the
achievement of like-for-like offsetting. Furthermore, the Whitehouse Farm EO emphasised that
there are also potentially fundamental contradictions between offset site selection close to
development sites and the dynamics land ownership markets, as developments (particularly
residential developments) often result in land price rises in the surrounding areas. This dynamic
could cause the spatial expulsion of species from areas through offsets location being dictated
by rising land prices.
One of the final challenges for offset delivery was long term management. The offset for the
Whitehouse Farm case met all the required criteria and the LPA EO considered the site a good
or better replacement for the impacts at Whitehouse Farm (W.I.1). However, for the developer,
the ecological consultant reported that the process of delivering the offset has been long and
complex, and also potentially costly with one interest group speculating that the cost must have
reached £1 million (W.I.4). Furthermore, at the point of data collection the long-term
management of the offset had yet to be resolved (W.I.1; W.I.2; W.I.3; W.I.4). The developer
purchased the site to reportedly gain control over the initial start-up work and main components
of the ecological restoration but wanted to shed responsibility for long term management
(W.I.2). However, finding a partner to take on the long-term management of the schemes
proved difficult, particularly due to issues with land liability and access to long term funding
(W.I.1). The ecological consultant at one point even offered to set up their own management
company to administer the site, however, the LPA deemed it inappropriate that the consultancy
should benefit from the requirement to offset. Instead, the developer has reportedly ended up
leasing the site to the local council, with funds for upkeep (W.I.2). The in-perpetuity principle of
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offsetting has the potential to cause considerable problems during offset delivery. Despite, the
fact that developer originally thought offset would be a quicker, easier and cheaper option, in
hindsight the actual process was found to be long, expensive and laborious (W.I.2; W.I.1, W.I.3;
G.I.3), deemed off-putting by the EIA consultant.
7.5.2 The Challenge of Delivering and Implementing Offsets
Some degree of involvement of EIA in offset delivery was noted in the case studies, with EIA
consultants linked to offset site selection, surveys, and authoring site management plans and
design. However, the case studies do not indicate that the EIA process or consultants are
particularly central to offsets implementation or delivery. Furthermore, the appropriate level of
connection between EIA consultants and offset delivery is unclear. There are complaints of
overly strong connections between EIA consultants and offset delivery, linked to conflicts of
interest and perverse benefits. Conversely, there are also indications that the complete
separation of offset delivery and EIA was associated with the divorce of the mitigation conditions
and the final offset design. Therefore, there could be some value in maintaining a connection to
the EIA process and EIS as a means of maintaining the connection between the impact and the
offset. What was strongly suggested was that there needs to be a connection between offset
providers, offset brokers, or environmental restoration practitioners and the EIA
process/planning application. Connecting EIA consultants, offset brokers and restoration
practitioners was thought to be key to ensuring that realistic offsetting proposals were put
forwards for consideration in decision-making. Therefore, exactly, who is involved in the
offsetting process was found to be a tricky question, plagued by issues with transparency and
diverging ideas about whether offsetting design is a technical issue or a place for engagement,
debate, and multiple stakeholder steering groups. Two other aspects were also seen as
problematic for the future of offsetting delivery. Firstly, the tensions between site selection,
developer willingness to pay and land ownership dynamics, and secondly, finding long-term
management solutions for offset. The complexity of delivering offsetting could in some cases be
off-putting to future uptake of EIA developers. Furthermore, developers are often unwilling to
commit to resolving technical details prior to decision-making, but this means they are also open
to unknown costs and time constraints, a distinct contrast to the relatively rose-tinted narrative,
presented by Defra (2011; 2013), that offsets would be clearer and quicker ways to undertake
compensation.
7.6 Connections between EIA and Biodiversity Offsetting
Exploring emerging UK practice has provided an opportunity to critically investigate the
integration of EIA and offsets, to interrogate the utility and limitations of EIA in operationalising
offsetting, and explore the implications of the interaction of these two mechanisms.
Firstly, the case studies highlighted that quite different structural arrangements are occurring
between EIA and offsetting linked to EIA taking on quite different roles in the application of
offsetting in parallel around the UK. Looking at a sample of offsetting practice in the UK reveals
that, predominantly, EIA appears to work as an information trigger or input for offset, and/or an
analytical framework for offsetting calculations (see figure 7.7). Secondary roles, such as EIA
working as a forum for consultation on offset proposals, were also apparent but were more
incidental benefits than by design. In comparison, the substantive and delivery connections
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between EIA and offsetting were much less evident (See figure 7.7). For decision-making, EISs
can, in some cases, provide a means of incorporating offset commitments into decision-making
but the influence of offsetting on decision making was often unclear. However, there was much
less evidence of the EIA procedure or consultants playing a crucial role in offset delivery,
reflecting expectations that the decision-orientated nature of EIA would limit its usefulness as
an overall framework for offsetting. Therefore, EIA’s role as a holistic management tool is
potentially limited, but exactly who should be involved in offset delivery was uncertain, a point
for further discussion and debate. Offsets were also found to occur outside the EIA process, the
lack of connection between EIA and offset implementation was also found to be problematic
and resulted in conflict between the findings of EIA and offsetting assessments.
Figure 7.7 Comparison between Expectations and Practice
Information Source Management tool
Data Source Information
trigger
Analytical
tool
Discussion
Forum
Delivery and
management
Framework
Institutional
Building Block
1 2 3 4 5 6
Low Degree of Interaction High
Use Value of EIA EIA vs. Offset
Information
trigger
Analytical tool
Pathway to
decision
commitments
Offset introduced in
conflict with the
findings of EIS
However, the links between EIA and offsetting did not necessarily mean that offsets worked as
an easy subset of EIA. Although it was possible to identify that a number of instances where EIA
had a role in the application of offsetting, the extent to which EIA was aiding operationalisation
was questionable. The impacts that offsets were used to address were found to be
acknowledged in the EIA process and EIS, however, as anticipated, EIA often does not really
engage with this level of residual impacts and therefore no mitigation had been suggested.
Triggering offsetting was therefore often at the discretion of Ecology Officers (EOs). Moreover,
EIA consultants currently consider these impacts acceptable or unavoidable, based on the
historic focus on significant impacts in EIA, and therefore triggering offsetting required a
considerable change in perspective along with an EO willing to leverage offsets commitments
against planning permission. Furthermore, in project proposals and developments where the
application of offsets and EIA occurred separately this disconnection meant that the need for
offsets conflicted with the findings of the EIS. Therefore, EIA is linked to the operationalisation
of offsets but the different conceptual characteristics means that connections between these
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two mechanisms are challenging. Offset do not appear to always operate as a simple or
straightforward extension of the current EIA paradigm.
Exploring expectations of the possible outcomes of integrating EIA and offsetting in Chapter 6
portrayed contradictory perspectives; suggesting that the possibility for both adverse knock-on
effects of poor EIA practice to negatively affect offsetting performance and, simultaneously, an
appreciation that offsets could also work as a catalyst for change and even improve EIA
performance. Investigating the integration and interaction of offsetting in emerging UK practice
showed that there are two distinct interpretations of the primary purpose and value of adopting
offsetting in relation to EIA. Firstly, metric-based approaches where offsetting is applied
primarily based on the value of the metric as an additional analytical tool in EIA, and, secondly,
solution-based offsetting where offsets are used mainly based on their value as an off-site
compensation solution for unavoidable impacts. These diverging interpretations of the primary
value and purpose of offsetting in relation to EIA were clearly linked to different structural
connections and arrangements between these two mechanisms, and, broadly, can be seen to
result in different relationships, implications and knock-on effects.
The integration of offsetting metrics into EIA, as an additional analytical tool, rested on
expanding existing EIA practice by providing new measures for biodiversity losses and gains.
Where offsetting was valued for its analytical capacity the offsetting metric was applied early on
in the EIA process and fully integrated or subsumed into the EIA process. EIA then acted as an
analytical framework, and EIA consultants completed the metric alongside existing approaches.
The presence of offsetting metrics were linked to enhancing the technical scope of EIA,
reinforcing the mitigation hierarchy through providing a measure of on-site mitigation
(in)effectiveness and, therefore, holding developers to account for their mitigation proposals.
Similarly, offsetting metrics were thought to work to generate behavioural change and
incentivise more mitigation on-site. However, the presence of metrics in the EIA process also
appeared to challenge the place of subjective expert judgement and impact acceptability by
introducing a consistent quantitative measure (Chapter 7.3.2). Although the application of
offsetting metrics were associated with positive outcomes, there was also evidence from the
case studies that they can distract attention away from avoidance and led to a focus on on-site
compensation.
In comparison, where offsetting was applied much more for its value as an off-site physical
solution for unavoidable impacts, the nature of the relationship with EIA was much more mixed.
This interpretation of offsetting led to them being introduced much later in the EIA process and,
therefore, with a much lower degree of integration into the overall EIA process. Rather than
offsetting influencing the scope and nature of the EIA assessment the opposite appeared to
occur. The application of offsetting was bolted on to the EIA framework, a form of consecutive
intergration, and consequently much more dependent on existing subjective approaches to the
attribution of impact significance in EIA. Offsetting commitments can be included in EIA, but
often only to a limited degree and EIA works as a pathway for commitments rather than actively
engaging with offsetting. As a solution for unavoidable impacts, the application of offsetting
does appear to challenge existing ideas around the acceptability of unavoidable impacts and
provides additional mitigation. However, the use of offsetting as a solution also appeared to be
an ‘easy way out’ or ‘quick fix’ which enabled trade-offs under the premise that impacts are
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unavoidable. Furthermore, the late introduction of offsetting proposals can result in offsets
competing with the financial budgets for on-site mitigation, undermining the mitigation
hierarchy, and acting as an attempt to punish poor performance rather than engendering
change.
Through analysing the case studies this Chapter has shown how EIA and offsetting are beginning
to work operate together in practice and the early implications of their interaction, highlighting
two distinctly different interpretation of offsetting value and purpose resulting in two different
relationships and interactions with the EIA process. The remit of the next chapter is to critical
reflect on the implications of the empirical findings and the questions they raise both for future
EIA practice and the emergence and conceptual development of offsetting.
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8. Disentangling the Relationship between EIA and Biodiversity Offsetting
8.1 Introduction to the Discussion Chapter
This Chapter addresses the final research objective: to critically reflect on the integration of EIA
and offsetting, and outline the possible outcomes of their interaction. In order to reflect on the
integration of EIA and offsetting this Chapter has been split into three main sections. First,
section 8.2 provides a brief recap of the research premise and main empirical findings. In order
to critically reflect on the implications of integration, the two subsequent sections are then
devoted to exploring key issues raised by the empirical findings. Section 8.3 reflects on the
empirical findings in relation to the future direction of EIA as a tool for sustainable development,
discussing the implications of the inclusion of offsetting metric in the EIA process; the
disconnection between EIA and offsetting delivery; and the prospective wider ramification of
attempting to link EIA into strategic landscape-scale conservation planning and restoration.
Section 8.4 then reflects on the research findings in relation to broader debates on the uptake,
operation and conceptual development of offsetting as strategy for biodiversity conservation. A
summary of the Chapter is then given in section 8.5.
8.2 Reflecting on Integration and Key Points for Further Discussion
EIA is referred to as an obvious vehicle for the operationalisation of offsetting, an essential part
of the legal machinery and a means to trigger offsets, however, integration has been assumed
to be positive rather than actively investigated. Existing research on the integration of
environmental management assessment and tools highlights that the logic of combining tools
requires investigation. Figure 8.1 presents an overview of the integration of EIA and offsetting
developed from studying emerging UK offsetting projects. The integration framework (8.1)
illustrates that the two main forms of integration are found to occur in emerging practice,
analytical and consecutive integration. These two forms of integration are linked to two quite
different interpretations of the value and purpose of offsetting and with very different
implications for both EIA and offsetting practice. These different forms of integration not only
highlight that offsetting and EIA can interact in quite different ways but also suggest that we
need to be careful in the way that we connect these two mechanisms and to what end.
Integration needs to be based on a clear understanding of the prospective role for EIA, and a
consideration of how conceptual disconnections may limit this role or result in possible knock-
on effects, both positve and negative. Looking to future practice, these findings also raise
questions for both the process and purpose of EIA and the operationlisation of offsetting.
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Figure 8.1 The Integration of EIA and Offsetting in UK Practice
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8.3 Integration Outcomes: Question for Future EIA Purpose and Practice
The research findings suggest that the rhetoric of integration may be pervasive and EIA may be
an obvious vehicle for operationlising offsetting, however, offsets should not be considered as
a simple extension or subset of the paradigm of impact assessment. In the UK context, the
integration of offsetting and EIA has shown the potential to engender significant change in the
EIA process, and even challenge existing practice. The incorporation of offsetting into EIA
practice appears to bring into question some quite fundamental aspects around how ecological
impacts are dealt with in the EIA process, its substantive purpose and relationship to
environmental management and sustainable development. Faced with the question of what
offsetting means for future EIA practice this section focuses on three areas for further
discussion. Firstly, in relation to EIA practice, questions remain surrounding why the
incorporation of offsetting metrics into the EIA process was able to influence the outcomes of
EIA, to such a degree, and what might be the long-term implications (8.3.1). Secondly, the
evident disconnections between EIA and offset implementation is also a critical area for
discussion, with potential implications for the role of EIA as an environmental management tool
(8.3.2). Finally, offsetting is fundamentally based on moving beyond on-site and in-situ focus of
EIA, and therefore, also introduces broader questions about how EIA should connect to wider
landscape-scale biodiversity conservation targets (8.3.3).
8.3.1 Shifting from Qualitative to Quantitative: How Offsetting Metrics Influenced the EIA
Process
The analytical integration of offsetting metrics into the EIA process, explored in Chapter 7,
showed that offsetting metrics have the potential to shape EIA process and performance,
affecting impact identification, the attribution of impact significance and the adherence to the
mitigation hierarchy. In particular, offsetting metrics were linked to a more action-oriented and
decision-making EIA process. This sub-section discusses the characteristics of offsetting metrics
which were thought to have enabled them to positively influence the EIA process. These
perceived positive influences are then combined with existing academic critique of metrics to
explore the possible long-term ramifications of the incorporation of offsetting metrics into the
EIA process.
Three characteristics were linked to how offsetting metrics were able to influence the EIA
process in practice; their tangible, technical and targeted nature. The presence of an offsetting
metric for the first time established a clear figure for levels of overall or cumulative biodiversity
loss. The tangibility of numbers enabled impacts on general biodiversity loss to be visualised and
evaluated, indeed through making these impacts more tangible developers appeared to be less
able to dismiss or downplay impacts and LPA Ecology Officers had a clear position to negotiate
additional mitigation. Similarly, the calculation of biodiversity impact through offsetting metrics
was considered a more technical and scientific approach, and offset calculations were perceived
as more accurate, consistent, and systematic approach to impact prediction. The perceived
technical nature of metrics also appeared to emboldened EOs, who used metrics to strengthen
their position based on the notion that they were “doing it [compensation] properly” (GA.I.2)
and actively employed metrics to leverage more mitigation. Finally, offsetting metrics are built
around the aspiration of no net loss; this target-orientated approach clearly indicates
expectations regarding impact acceptability and incentivises movement motivated towards the
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goal of no net loss. These findings correspond with the broader findings of the pilot evaluation
(CEP and IEEP, 2016:4) which reported that in general “where the metric was used, stakeholders
felt that it was largely beneficial: providing a quantified, consistent, transparent and relatively
simple process that accounted for a wider range of biodiversity impacts than current practice”.
The language and arguments used by EOs are clearly linked to ideas that the numerical
communication of impacts renders them more governable, doable, manageable or actionable
(Fujimura, 1987). Furthermore, they highlighted that enumeration was linked to empowering
certain actors. The idea that quantitative figures are a more persuasive format for
environmental decision-making than qualitative statements is by no means new but represents
a core justification for the valuation of nature movement grounded in ideas that “we cannot
manage what we cannot measure” (Sukhdev, 2011:34).
However, the validity of many of the perceived benefits of offsetting metrics; our belief that the
numerical communication of impacts is more scientific, accurate and fixed (Porter, 1995), can
be questioned. The idea that metrics are a more scientific approach for EIA sits in stark contrast
with widespread complaints about the validity and capacity of biodiversity metrics to capture
biodiversity values, and concerns relating to the use of reductionist quantitative approaches to
capture the plural values of biodiversity (Chapter 2.5.3; Robertson, 2002, 2004, 2006; see also:
Apostolopoulou and Adams, 2015; Sullivan, 2013; Walker, et al., 2009; Büscher et al., 2014). The
Defra metric has been widely criticised as too simplistic (e.g. EAC, 2013; Defra, 2016; Mathiesen,
2013). Therefore, the use of metric-based approaches could be presenting biodiversity units and
conservation credits with a false perception of technoscientific authority. Furthermore, the use
of offsetting metrics was considered a consistent method to determine impacts; however,
metrics are potentially as susceptible to manipulation as the qualitative expression of
significance and expert judgments. Epseland and Stevens (1998:331) highlight that: “examples
of numbers malleable enough to conform to powerful interest are easy to find”. It was evident
from the case studies that an element of negotiation and flexibility remained in the application
of metrics, and at best they should be described as pseudo-quantitative in nature as they also
involve qualitative judgements through the scoring of habitat condition and distinctiveness.
Finally, offsetting metrics were considered beneficial based on their targeted nature. However,
the no net loss objective has been increasingly criticised as entrenching baseline decline in
biodiversity (Gordon et al., 2015; Maron et al., 2015). More seriously, the no net loss aspiration
has been criticised as ‘illusionary’, and there are arguments that it will enable developers to
neutralise environmental concerns and promote false environmental credentials (Walker et al.,
2009; Gordon et al., 2015). Therefore, clear questions persist about the technical credentials of
offsetting metrics, the appropriateness of the no net loss target of offsetting, and the
consistency of metrics as a tangible measure of biodiversity impacts.
Given these complaints it is difficult to understand the reasons for offsetting metrics being
considered to have such a beneficial effect on the EIA process. Within the EIA context, the
enumeration of biodiversity impacts appears to have been particularly persuasive in relation to
the nature of existing EIA practice. At present, biodiversity is often overshadowed and even
ignored in the EIA process (e.g. Byron and Treweek, 2005; Pritchard, 2005; Söderman, 2005;
Wale and Yalew, 2010). Therefore, despite issues with the scientific basis of offsetting metrics,
they still appear to capture an additional level of impact to that currently being addressed in
EIA, and under some offsetting systems “nearly every development is now coming out with a loss
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of biodiversity” (GA.I.2). This point was also highlighted by the CEP and IEEP (2016) pilot
evaluation which emphasised that stakeholders perceived the greatest benefits of the metric as
enabling the greater visibility of impacts. Consequently, the metric is considered an
improvement in comparison to the status quo, as one EO emphasised: “the metric may overstate
impacts, but qualitative impacts often understate them” (W.I.1).
Moreover, pre-existing approaches to determine compensation requirements have historically
been based on ‘rules of thumb’, and therefore the systematic approach taken by offsetting
metrics was considered to provide a fairer and more consistent deal for biodiversity. As
described in the CEP and IEEP (2016:32) pilot evaluation “Metric users noted that current
practice for determining biodiversity impacts was ad-hoc, inconsistent and reliant on the
enthusiasm and expertise of the individuals involved”. Defra also endorses one of the metrics
studied, and one EO highlighted that this endorsement makes the Defra metric difficult to
challenge and manipulate, thus empowering the position of the EO to require mitigation despite
complaints regarding its scientific validity (GA.I.1). Although concerns may continue about the
manipulability of metrics, Epseland and Stevens (1998) also acknowledge that those who believe
they can manipulate quantification process are often proved wrong in the long run. Likewise, as
outlined previously, there are considerable concerns about the reductive and simplistic nature
of offsetting metrics (ibid.), yet it is also apparent from this research that the commensuration
process once launched refracts power in many ways, which can both be manipulated by elites
and also limit their discretion (Epseland and Stevens 1998; Mackingtosh and Waugh, 2014).
The no net loss objective was also considered a problematic aspiration. However, at present,
the only obligation in EIA is to follow procedures, examine impacts impartially and provide
information for decision-makers (Jay et al., 2007; Cashmore et al., 2008). EIA has been criticised
for insufficient goal-setting as it does not define what is environmentally acceptable or how an
impact should be treated (Jay et al., 2007; Benson, 2003). Therefore, the no net loss objective
worked to set a bar, red-flag or establish a threshold for general biodiversity loss where
ecological performance had previously been open for interpretation. Similarly, pseudo-
quantitative estimations of biodiversity units provided ecological consultants with a means to
measure mitigation effectiveness, a way to compare and contrast the effectiveness of different
project designs and to incentivise changes to reduce the level of biodiversity loss. Furthermore,
having a clear goal meant that impact significance was a much more black-and-white issue,
rather than open to the interpretation and at the discretion of developers. Overall, the no net
loss goal appeared to make the EIA process less passive and more purposeful, which was seen
by EOs as an improvement for biodiversity. The idea that UK EIA systems could benefit from
being more goal-orientated is by no means new, both Jay et al. (2007) and Morrison-Saunders
and Fisher (2006) suggested the need for a reassertion of the environmental focus of EIA
potential through the introduction of a substantive mandate.
Furthermore, pre-existing concerns about manipulation, bias and EIA quality are linked to
behavioural issues such as the communicative distortion of qualitative impact statements (see
Chapter 6.4.1). The quantification of impacts through metrics, therefore, appears to produce
more practical, usable, and accessible forms of knowledge for EOs and NGOs in the context of
complaints about overloaded and ‘bloated’ EISs (see Chapter 6.4.1). Qualitative impact
prediction and impact significance are already regarded as a ‘black box’, and linked to complaints
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about a lack of transparency and precision (Badr et al., 2004). Therefore, the place of subjectivity
in EIA has always been somewhat controversial. Subjectivity has been portrayed as making the
EIA process, particularly decisions on the attribution of impact significance ‘manipulatable’
(Wood, 2008), open to ‘deliberate misrepresentation' (Lawrence, 1993), or liable to the ‘sugar
coating’ of impacts (Ehrilich and Ross, 2015). Subjectivity has also been viewed as a route that
unscrupulous developers can follow to make EIA an advocacy exercise, through communicative
distortion. Consequently, through subjectivity EIA has been seen as imprecise, context-
dependent, political and complex (Wood, 2008), and offsetting metrics are considered to be
more scientific in comparison to current issues with subjective methods. Therefore, despite
concerns about their scientific basis, in this context, quantitative biodiversity units appear
clearer, simpler and less malleable than text, and taking a calculated approach is considered to
provide more transparency and certainty.
The EIA context is, therefore, particularly receptive to the quantification of impacts due to issues
with current practice. In this way, offsetting metrics were perceived as having advantages over
the current system, even if it did not live up to aspirations of no net loss. The current context
and criticisms mean that EIA is tilted towards a positive reception for quantitative offsetting
metrics and the perception that quantification make biodiversity impacts more governable,
accountable, and manageable is already embedded in EIA practice. Furthermore, in the cases
under study, EOs were often found proactively using offsetting metrics to empower their
positions and request additional mitigation, therefore metrics were linked with attempts to re-
distribute power in the planning application process.
A key aspect of the value of offsetting metrics for EOs was clearly related to disillusionment with
the status quo and challenging the place of qualitative communication in regard to impacts and
subjective expert judgment in EIA. Indeed, subjectivity was a central point of contention.
However, EIA is, generally, considered both a science and an art (Wathern, 1988; Wood, 2003;
Morrison-Saunders and Sadler, 2010), and subjectivity has been acknowledged as an inherent
part of the EIA process. Lawrence (2007) highlights that as soon as the realm of interpreting the
meaning of an impact is introduced; the ‘so what' for human society, subjectivity becomes
inescapable in the EIA process. Furthermore, Briggs and Hudson (2008) link the loss of
subjectivity to EIA becoming too standardised and rigid, a loss of innovation, and ecosystem
complexity. In addition, there is acknowledgement that the loss of subjectivity could mean the
attribution of impact significance becomes more deterministic than dynamic (Wood, 2008), a
number punching exercise. Similarly, pivot thresholds, such as a no net loss, are thought to result
in the creation of critical dividing lines around impacts presenting them as sharp black and white
boundaries which filter out the fuzziness and ‘shades of grey’ in reality (Wood, 2008).
Subjectivity is also understood to be a key component of how EIA works as a forum for
discussion, participation, community engagement and social learning (Beattie, 1995: Morgan,
1998; Wilkins, 2003). Complaints of technological exclusion by stakeholders as a result of the
offsetting metric were previously reported in the case studies (see Chapter 7.5). Therefore, the
perceived beneficial effects of metrics also come at the cost of reducing spaces for discussion
and stakeholder engagement, and will potentially instil a more definitive balance sheet mind-
set.
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Cashmore (2004) emphasises a long-running debate has persisted over whether quantitative or
qualitative impact predictions are more effective for decision-makers. Neither quantitative nor
qualitative conceptions of impacts appear are likely be able to communicate biodiversity
impacts in a way that is satisfactory to all parties involved. The application of offsetting metrics
is part of a new wave of technical toolkits, calculative devices, and methodologies to measure
the biodiversity and ecosystem services impacts of projects (e.g. InVest by the Natural Capital
Project, 2016) in quantities, values or units, and even map their spatial distribution. At present
it appears that:
“The pendulum has swung too far from over-reliance on the quantitative and largely
objective (science) to over-reliance on the qualitative and more subjective (art)
needs in the EIA process” (Saidi, 2010:4)
This shift towards quantitative approaches, such as offsetting metrics and ecosystem services
valuations, can be seen as a return to rational, technocratic and positivist ideas. This move is
linked to confronting rather than embracing the subjective elements of EIA, based on the
perception that current UK EIA practice is too subjective and too open to communicative
distortion. A conviction whereby biodiversity often emerges as ‘the loser’ under qualitative
conceptualisation of impacts and without firm guidance on non-negotiables.
The move to embrace offsetting metrics appears to be linked to disillusionment and the
perception that developers are getting a free ride within the current system. Metrics were
connected to attempts to shift the balance of power in EIA away from Ecological Consultants
and developers through the adoption of approaches that are easier to substantiate and
evaluate. The use of metrics by EOs can be regarded as a rejection of EIA as a conciliatory
mechanism. These findings indicate that we may need to link EIA research much more into the
process of commensuration and how it empowers individual actors, the cognitive study of
numbers, and the ways in which they influence our perception and behaviour (Bagchi and Davis,
2012). The extent to which the metric can be manipulated is also a central question for its future
role as a measure to enhance accountability and combat subjectivity in EIA.
The adoption of offsetting metrics has clearly been encouraged by an existing bias towards the
technical, the quantitative and the positivistic. Inevitably this will result in the loss of qualitative
reasoning, contextual analysis, and public knowledge and engagement, thus pushing EIA away
from ideas that it can be a forum for discussion, participation in community engagement/self-
governance, and social justice. What is more, offsetting metrics could result in a shift towards
an environmental design role for EIA, and a pragmatic role for science in converting the ‘wicked’
nature of biodiversity issues and into ‘tame’ problems. Given complaints about offsetting
metrics, this suggests that generating action in EIA and behavioural change does not require
particularly precise or scientifically valid information, merely a consistent or systematic
approach. The rejection of the qualitative also appears to be an attempt to shift EIA away from
complaints that it is too long (Middle and Middle, 2010b), jargon-riddled (Lawrence, 2003), and
a “lifeless bureaucratic exercise” (Morrison-Saunders and Retief, 2012:8), and into a more
action-generating approach, orientated towards developers and decision-makers (Lion et al.,
2013). By privileging the quantitative over the qualitative, there is an attempt to render EIA more
decision-making than decision-informing in the future, as well as impacts more practical
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governable and actionable. Indeed, the use of metrics may result in a shift towards pragmatic
science, and usable or policy-relevant knowledge in EIA.
8.3.2 Delivering Green Gains: Mitigation, Implementation, and EIA
In contrast to the analytical connections between offsetting metrics and the EIA process a key
point of disconnection was predicted to be between EIA and offset design and delivery (Chapter
6.3). This predicted disconnection was by no means unexpected. Although, mitigation proposals
and their delivery are, ideally, a central part of the EIA process (Wood, 2003), implementation
has become a notoriously weak aspect of the EIA process in UK practice (Tinker et al., 2005;
Drayson and Thompson, 2013), cited as a major shortcoming (Sanchez and Hacking, 2002; 1999;
Morrison-Saunders. 1999). A key part of the premise behind offsetting is based on suggestions
that efficiency and compliance in implementing compensation could be improved by using a
third party (ten Kate et al, 2004; Latimer and Hill, 2007). Incidentially, a core idea within
offsetting is not only that offsets occur off-site but that implementation and delivery should be
isolated from EIA consultants and the EIA process to increase the chances of compliance by way
of transferring implementation into the hands of environmental restoration experts. This
predicted disconnection between offsets and EIA is, therefore, quite a change in perspective
regarding the theoretical remit of EIA and its relationship to mitigation, but is not unsurprising
considering complaints about current practice.
The findings from emerging UK practice, outlined in Chapter 7.5, suggest that the separation
between EIA and offsetting delivery occurs to different degrees in emerging practice, and
furthermore that degrees of (dis)connection between EIA and offsetting cause different
problems. The complete disconnect between EIA and offset delivery was found to be
problematic. Developers were clearly unwilling to develop detailed offsetting designs and site
commitments before decision-making, often only including brief statements or general
methodologies in EISs. The separation of initial proposals in the EIA and final offset design and
delivery meant that there was often a distinct division between original planning commitments,
ideas about the justification and broad remit for offsets in the Environmental Impact
Statements, and the final offset. Moreover, there is evidence that offset providers often do not
endorse the proposals included in EISs. However, offset providers and brokers, generally, do not
participate in public consultation and would therefore not be aware of particular public
perceptions or stakeholder priorities that led to the adoption of an appropriate management
measure. Furthermore, there was also evidence that offset providers, in some instances, do not
consider the need for consultation on offset proposals which they considered to be a technical
or expert planning issue. Therefore, decision-making on offsets is being undertaken based on
quite limited design and implementation proposals. In order to ensure that there are more
realistic outlines for offset proposals in EISs, there is need for a much closer relationship
between environmental restoration specialists, offset providers, and EIA consultants. Indeed,
connecting EIA and offset design should help to develop a much clearer understanding of what
can be achieved and delivered, improve the feasibility of proposals and ensure realistic
offsetting proposals are presented to stakeholders in EISs.
There were also instances where, developers chose to undertake offsets in-house and
maintained partnerships with the consultants from the EIA process. Although this set-up
maintained a connection between the impact and the offset, purchasing and restoring an offset
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site in-house was considered to be quite laborious, time-consuming, complicated, at a high cost
for the developer, and with additional issues around finding a long-term manager willing to take
on the land liability. Furthermore, the involvement of EIA consultants in the delivering the
offsets was controversial and understood in one case as the consultants perversely benefiting
from the requirement to offset.
Hence, the research findings suggest that although guidance and literature related to offsetting
promotes the use of a third parties to deliver offsets (e.g. ten Kate et al, 2004; Treweek et al,
2009; Briggs et al, 2009), there remain clear questions about the level of engagement between
EIA and offset delivery which is desirable and appropriate. Although the disengagement
between EIA and offset implementation was by no means unexpected, exploring practice, shows
that these ideas have been taken much further, and the inclusion of EIA consultants in offset
design and the implementation process were perceived as consultants unduly benefiting from
offsetting proposals. There are thus clear questions about who should be involved in offsetting
and uncertainty around how independent offset design and delivery needs to be from the actors
participating in the planning application process. However, some degree of interaction between
EIA and final proposal does appear to be necessary to ensure that offsets remain connected to
the original ideas around their application, and the impacts for which they are delivering
biodiversity gains. Furthermore, the inclusion of only limited or superficial offsetting plans in EIS
brings into question when consultation on offsetting proposals will take place and how
transparency will be assured for offset design and implementation. At present, offsetting
implementation and design appears to be considered more of an expert issue and technical
decision made by offset providers and brokers.
The appropriate relationship between EIA and offsetting delivery appears unclear. Analytical
integration of the offsetting metric and EIA could be used to enhance the position of EIA as a
tool for project design and mitigation plans. However, the separation of EIA from offset design
and implementation reinforces the idea that EIA is a tool for seeking project approval, rather
than a tool for adaptive environmental management. This separation could result in a decrease
in the significance of EIA results for developers, and increased divisions between developers and
environmental restoration efforts. This disconnection thus brings into question whether a
change in attitude is needed towards EIA and implementation. Indeed, greater inclusion of EIA
in offset delivery and design processes could be used as a means to engender a better
appreciation of the potential contributions that EIA could make to the ongoing management of
projects. If EIA was instead connected to delivery and implementation, then offsets could help
to move away from the perspective of EIA as solely concerned with seeking approval. Effectively,
to shift developers away from a ‘build it and forget it’ mentality and transform EIA into a more
effective exercise with links to the long-term management of offset sites.
8.3.3 Beyond the Site Boundary: Linking EIA and Landscape-Scale Conservation
Analysing the findings of a series of expert interviews in Chapter 6.3 highlighted a clear
consensus that offsets, ideally, need to be linked into strategic frameworks to ensure that they
are ecologically meaningful. This perspective was linked to concerns that if offset are only
planned and triggered through EIA they would simply work as an end-of-the-pipe measure. This
idea reflects the wider literature surrounding the prospective landscape-scale benefits of
offsetting:
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“Conservation organizations can use biodiversity offsets to move beyond piecemeal
mitigation, securing larger-scale, more effective conservation projects. Offsets can
also be a mechanism to ensure that regional conservation goals are integrated into
governmental and business planning” (Kiesecker et al., 2009:78).
A key benefit connected to moving beyond the site boundary is that offsetting can not only
provide an additional level of mitigation but also enable ‘smarter mitigation’. Through moving
off-site, offsets can be linked into landscape ecology principles and systematic landscape-scale
conservation planning which are argued to deliver generate greater benefits for biodiversity by
restoring ecological networks (Latimer and Hill, 2007; Kiesecker et al., 2009, 2010; Gardner et
al., 2013). Moving beyond piecemeal mitigation towards a landscape-scale approach implies a
planned, strategic or systematic mechanism for site selection, delivering offsets in the right
location for regional conservation goals rather than on an ad hoc, fragmented, site-by-site basis
(Kiesecker et al., 2009, 2010).
In this study, the option to offset impacts off-site did appear to provide an additional level of
mitigation for residual impacts that were considered likely to have otherwise remained
unmitigated. However, the extent to which offsets connected EIA to landscape-scale
conservation goals was much more debatable. In the emerging UK context of offsetting,
landscape-scale aspirations were not found to be extensively embedded in emerging offset
systems. Instead, landscape-scale aspirations had to compete with a primary focus on achieving
equivalence, or like-for-like offsets, and ensuring benefits accrued close to the impacted site.
Furthermore, achieving the prefered sites was also dependent on cost-barrier and therefore the
dynamics of land ownership markets. The use of offsets to contribute to landscape-scale
restoration did occur but it was very much a secondary option, adopted only when the offset
providers were unable to achieve a like-for-like offset. Hence, the conflicts between these
different principles reflect the ideas of Gardner et al. (2013) who suggest that consideration of
the landscape context means a move outside like-for-like. Offset site selection in the case studies
remained ad hoc, dominated by land market and ownership dynamics and steering groups which
attempted to best reconcile competing objectives.
Current literature advocates advanced mitigation planning to identify sites which will deliver the
greatest biodiversity benefits, rather than the minimum requirements (e.g., Kiesecker et al.,
2009, 2010). Efforts to mitigate development impacts on ecology in EIA have traditionally
focused within the site and its immediate surrounding, therefore landscape-scale connections
through offsetting could represents a clear break from the traditional realm of EIA and a move
towards considering how EIA can contribute to wider regional strategic conservation planning.
However, deprived of links into wider systematic conservation planning, project-based offsets
in the UK are likely to remain an extension of existing ad hoc approaches and a missed
opportunity for strategic contributions (e.g., Kiesecker et al., 2009; Wilkinson et al., 2009). In the
absence of wider strategic thinking, offsets appear to work as an end-of-pipe solution and
distract attention away from the mitigation hierarchy. Particularly, in situations where the
project application is conducted under tight timescales. Although the strategic element is
necessary to make offsetting more meaningful for biodiversity, this critical feature is not
sufficiently embedded in the UK biodiversity offsetting context.
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There is a need to reassert and discuss what the priorities are and the role of offsets; is it for
people or biodiversity, or both, and if it is how can we best achieve a compromise? Given that
offsetting systems in the UK are likely to remain informal practice, as existing offsetting policy
proposals have been put on hold (Chapter 5), there is also clear need for a basic framework
through which to help balance the competing objectives and dynamics of site selection for
offsetting, including land ownership dynamics and market, proximity to the impact sources,
bureaucratic boundaries, equivalence and landscape-scale benefits, in order to try to ensure
that even ad hoc offsetting makes some contribution to landscape-scale conservation
aspirations.
8.3.4 Summary: Offsetting and Future EIA Practice
The integration and interaction of EIA and offsetting occurs in different ways. In some cases
offsets were used as a quick fix for difficulties with on-site mitigation measures and effectively
bolted on to the EIA framework; in others cases, offsetting was much more analytically and
methodologically embedded in the EIA process. The commonality between these different
formats is that, fundamentally, the presence of offsetting showed the potential to challenge
existing ideas in EIA around impact acceptability and the nature of unavoidable impacts, the
attribution of impact significance and the place of subjective qualitative expert judgement, and
wider links between EIA, implementation, and long-term environmental management goals.
Furthermore, studying the engagement between EIA and offsetting revealed that there was
often a link between the application of offsetting and disillusionment with current EIA practice.
The relationship between the EIA process and offsetting metrics, in the UK, was found to be
particularly significant and highlights a resurgence in long-held debates around the best way to
communicate impacts to decision-makers. The presence of offsetting metrics was not only
linked to the communication of impacts for sound decision-making and the thematic expansion
of EIA but also appeared to be connected to the distribution of power between EOs, EIA
consultants and developers. The use of metrics in this manner was linked to disillusionment with
qualitative forms of impacts assessment and communicative distortion. Therefore, despite
complaints about the validity and reductionist nature of offsetting metrics, they have still been
found by EOs to have pragmatic value as a management and negotiation tool to engender
change and account for disillusionment with EIA performance. The use of metrics in this manner
suggests that although the commensuration of biodiversity losses and gains through offsetting
metric comes with considerable dangers, the process of commensuration studied in this
research does not always play into the hands of the elite but has some value in also limiting their
discretion.
For future EIA practice, the disconnections between the EIA process and arrangements around
offsetting delivery can also be linked to disillusionment with the implementation of mitigation
measures in EIA practice. Offsetting can effectively enforce a separation between EIA and the
implementation, monitoring and follow-up of impacts. The move to separate EIA and offset
delivery can be seen as a potentially critical tipping point which could reinforce ideas around EIA
as a tool solely for decision-making and project design, and challenges ideas about linking up EIA
and environmental management systems, thereby further reinforcing the mitigation myth. Even
if there are disconnections between EIA consultants and offset delivery, there is still a clear need
for better connections between offset providers, brokers, and ecological restoration efforts and
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the offsetting proposals outlined in EIA to ensure that consultation takes place on a realistic
basis regarding the parameters and possible dynamics of offset projects. Finally, offsets could
be an opportunity to link EIA to strategic goals, systematic conservation planning aspirations,
the blending of the mitigation hierarchy, and landscape-scale restoration aspirations (Kiesecker
et al., 2009). Without these strategic connections there are questions about whether the added
benefits of moving off-site are ecologically meaningful or whether offsets are just another end-
of-pipe solution to try to patch up poor EIA practice.
8.4 Integration and Operationalisation: Questions and Challenges for Offsetting
The literature review highlighted that the effectiveness of offsetting as a tool for biodiversity
conservation and the achievement of no net loss has divided opinions in policy, academic and
practce (e.g. Walker et al., 2009; Maron et al., 2012; 2016; Spash, 2015), and, moreover, there
questions surrounding the logic of using offsetting to try to achieve no net loss (e.g. Walker et
al., 2009; Burgin, 2008). Exploring integration not only raises questions for the future direction
of EIA practice and its substantive purpose but also for the conceptual development of offsetting
and emerging offsetting practice. The dynamics of integration and interaction between EIA and
offsetting, in the UK context, highlight fundamental questions still surround what offsetting
mechanisms are designed to achieve and the particular problems with the planning system we
are trying to resolve through offsets. Section 8.4.1 discusses the two different interpretions of
the value and purpose of offsetting, highlighted in the research findings, in more detail. In
addition, the research findings also highlight that embedding offsetting in existing regulatory
frameworks and tools is by no means simple. Section 8.4.2 then discusses three critical
challenges surrounding the integration of offsetting into the existing governance landscape and
environmental managment tools
8.4.1 Diverging Ideas on the Value and Purpose of Biodiversity Offsetting
Offsetting in many contexts is still in its infancy (Jenner and Howard, 2015). In the UK the
adoption of offsetting has very much been left open to interpretation with little specificity
around the exact dimensions of the relationship between offsets and planning system (Defra,
2013). Exploring the UK offsetting context shows that multiple agendas circulate around the
application of offsets, including green credentials, streamlining the planning system, as well as
specific pressures on biodiversity and the development of new business for the rural sector.
These different agendas have resulted in offsetting schemes which are connected to different
actors and operate under quite different institutional arrangements (Chapter 5). BBOP (2009b)
highlight that difference will always emerge from the setting in which offsets operate, the actors
involved, and ecological priorities; however, the degree of variability in the UK context also
corresponds with the findings of Lapeyre et al. (2015) and Hrabanski (2015) who suggest that
variability in the institutional arrangements which govern and implement offsets is “the rule
rather than the exception” Lapeyre et al. (2015:130).
In relation to EIA, variability in institutional arrangements reflects two quite different
interpretations of the value and primary purpose of offsetting (as highlighted earlier in section
8.2.2). One is primarily based on the application of offsetting metrics as a new methodology and
means to improve existing EIA practice through confronting subjectivity, to technically expand
the existing EIA remit. Another reflects more traditional conceptualisation of offsettng as
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predominatly an off-site compensation solution (ten Kate et al, 2004; BBOP, 2012a, 2009b) to
unavoidable impacts to patch up issues with practice. The interpretation and use of offsetting in
these distinct ways is significant as they appear to have quite different implications for practice,
with different outcomes for the mitigation hierarchy, impact significance, the result in different
relationships between consultants and EOs, and project management and design practitioners,
as outlined in 8.2.1 and 7.3. These findings suggest that in examining the implications of
offsetting we need to not only consider single idealised forms but also the variability of offsetting
practice, as advocated by Hrabanski (2015) and Lapeyre et al. (2015) who looked at the degree
of connection between offsets and the market. Furthermore, they highlight that not only are
there different ideas about why we should apply offsets, voluntary or mandatory (Doswald et
al, 2012), and restoration or averted risk, as outlined in Chapter 2, but also different
interpretations of the primary purpose of undertaking offsetting and what offsetting can achieve
as a tool to fix or improve planning systems.
These different interpretations of the value and purpose of offsetting suggest that in the UK
context, and in relation to EIA, the conceptual basis for the application of offsetting is by no
means fixed. Indeed, there has been a splintering of ideas of how offsetting should work in
practice, and metrics are considered to have independent value, separate from solely indicating
the necessity to offset (see also CEP and IEEP, 2016). The variability in offsetting practice
contrasts with offsetting literature which increasingly seeks to formalise and harmonize
offsetting metrics and practice (e.g., BBOP, 2012a; or Gonçalves et al., 2015) and to develop
strict criteria and principles concerning what counts as a ‘valid offset’. The growing exclusivity
around the term biodiversity offsetting clearly contrasts with emerging practice where the
operationalisation of offsetting often remains open to interpretation. Likewise, metric-based
offsetting has led some practitioners to suggest that the term biodiversity offsetting is a
‘misnomer’ (Lowe, 2014), a name that does not suit what it refers to, or the use of such a name,
based on the idea it misconstrues the value of offsetting metrics. This re-evaluation has led to a
renaming of offsetting metrics, such as Biodiversity Impact Assessments in Warwickshire (WDC,
2016), Habitat Evaluation Procedures in Somerset (SCC, 2014), and Biodiversity Accounting by
offset providers (Environment Bank, 2015) to distinguish their independent significance as
biodiversity valuation tools.
Therefore, offsetting is still also an evolving tool and the parameters of its application remains
open in many contexts. Hackett (2015) suggests that there has been an overt focus on certain
elements of ideal offsetting typologies, and Lapeyre et al. (2015) emphasise that there is a need
to understand the heterogeneity around each offsetting scheme, to try and disentangle its
institutional and economic characteristics as well as relations to market mechanisms. In
addition, to question on what basis and to what end offset is being used as a tool to fix or
improve planning systems and, how different interpretations of offsetting can link into the
various conceptual and practical challenges surrounding offsetting. Finally, an appreciation of
the variability in interpretations and outcomes of offsetting practice could also help to reconcile
different positions on offsetting, and an increasingly polarised debate on offsetting value and
effectiveness.
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8.4.2 Operational Issues for Emerging Offsetting Practice
Finally, literature and guidance surrounding the operationalisation offsetting highlights a wide
range of challenges in designing offsetting systems, such as ensuring compliance, adherence to
the mitigation hierarchy, uncertainty, and equivalence (e.g., McKenney and Kiesecker, 2010; Bull
et al., 2013; Gardner et al., 2013; Maron et al., 2016; CEP and IEEP, 2016). A number of these
issues are apparent in UK offsetting practice, most notably the adherence to the mitigation
hierarchy (7.3.1.3 and 7.3.2.3), spatially locating offsets (7.5), as well as biodiversity surrogates
and currencies (7.3.1.4). These different challenges for offsetting systems have been discussed
in considerable detail by authors such as Bull et al. (2013), Gardner et al. (2013) and Maron et
al. (2016). Rather than reviewing the many conceptual and practical challenges once again, this
research emphasises three critical sticking points as key considerations for future offsetting
practice: when offsets are introduced into the planning application process, why and on what
basis offsetting is triggered, and who gets a say in offsetting.
The research findings clearly illustrate a range of different structural arrangements for
biodiversity offsetting, with offsets introduced at different stages of the planning application
process, including pre-emptive application before the initiation of the EIA process, during
consultation, and at the appeal stage. Tisheew et al. (2015) highlight that the point of integration
of offsetting into the planning system is a critical issue. However, guidance on when offsetting
should be introduced wavers between advocating early application to ensure integration with
planning and management, and late application to ensure offsets are only used as a last resort
in relation to the mitigation hierarchy (e.g., ten Kate et al, 2004; Jenner and Howard, 2015;
Treweek et al, 2009; IUCN, 2014). In the case studies both these issues were found to occur. The
early introduction of offsets, often advocated by stakeholders and experts as key to ensuring
the metric was used (see CEP and IEEP, 2016), into the planning system resulted in offsetting
distracting attention away from avoidance, while the late unexpected application of offsets
undermining the mitigation hierarchy by way of reducing on-site mitigation budgets.
Furthermore, issues with timing and timescale also occurred through links between quick
turnaround times for projects and the use of offsetting to distract attention away from the
mitigation hierarchy, and also a reluctance of developers to develop detailed offsetting
proposals at the planning application stage, an issue also confirmed by CEP and IEEP (2016).
Kiesecker et al. (2010) advocate that these issues can be alleviated by moving to the strategic
level and advanced mitigation planning. However, in the absence of strategic planning, timing is
clearly critical for offsetting system design, and there is evidently a need for clearer guidance on
the possible outcomes and issues which arise from introducing offsetting at different stages of
the planning system for EOs and statutory authorities, to ensure better adherence to the
mitigation hierarchy.
Similarly, there is a widespread appreciation of the need to limit the application of offsets, and
offsetability is considered a key concern for the appropriateness and deliverability of offsets
(Pilgrim et al., 2013). A framework for offsetability has even been developed by Pilgrim et al.
(2013). In some cases, offsetting metrics were used to determine the need for offsets, a
calculative approach. In comparison, where EIA was used as an information trigger for offsets,
subjective decisions on impact significance were found to play a role in decisions around the
limits to the application of offsets. Looking at practice showed that, in the UK, context offsets
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were often linked to having the ‘right' kind of impacts by EOs. Nevertheless, having the right
kind of impacts was not solely related to technical considerations of offsetability, but due to the
voluntary nature of offsetting in the UK context and were also linked to having the right kind of
impact significance to leverage offsetting commitments from developers. Consequently, the
impacts linked to offsets need to be those which are not grounds for refusal yet are not too
insignificant to be able to leverage commitments from developers. These issues around impact
significance mean that to ensure commitment to offsets it was often necessary to leverage
offsets against planning permission, to ensure offsets were applied for impacts which had
previously been ignored or considered acceptable losses. Therefore, there are questions about
the subjective vs. expert approaches to triggering offsets, and how they are linked to
offsetability.
The impacts that offsets were used to address in the case studies were also generally labelled
‘unavoidable’. The association with unavoidable impacts on attempts to ensure that offsets are
only applied as a last resort in relation to the mitigation hierarchy (e.g., ten Kate et al., 2004;
Treweek et al., 2009). However, the unavoidable nature of impacts also presents offsets as
beneficial, the inescapable product of circumstance (e.g., topography, position of the habitat on
site, etc.). Unavoidable impacts were also associated with situations where on-site
compensation was particularly challenging or would require significant redesign when
mitigation came into conflict with profit margins and development choices which are
fundamentally at odds with the biodiversity currently present on site. Although these aspects
make impacts unavoidable from the perspective of the developer, by presenting impacts as
inescapable, the term unavoidable is somewhat misleading as in each case a choice has been
made. In using offset as a last resort these trade-offs made in offsetting should be
acknowledged, rather than submerged under the label of an unavoidable impact to ensure the
credibility of offsetting (e.g., Brownlie et al., 2012).
Alongside issues of when and on what basis offsets were required, exploring the relationship
between EIA and offsetting also highlighted questions about who is involved in offsetting and
the extent to which offset implementation and delivery is a technical expert issue or a collective
decision that should be open to consultation. This touches on emerging research undertaken by
Coggan et al (2013) related to the involvement of intermediaries in offsetting. There was
evidence of nervousness about connecting EIA consultants into offset delivery based on
perspectives of undue benefits (as outlined in 8.3.2). Equally, exploring offset practice revealed
contradictions around who gets to decide on offset delivery and design. In some instances, there
were clear attempts to include NGOs and other stakeholders in the process, to bring in a level
of oversight. While in others, the emphasis was on offset design and implementation as a
technical planning and expert issue which should be made progressive and more calculative. The
degree of independent oversight, who is involved in offsetting, and ensuring that offset delivery
is transparent and accountable are clear questions for the future of offset practice in the UK.
There are multiple conceptual, practical and ethical challenges which surround offsetting. This
research emphasises that in integrating offsetting into existing planning practice and EIA there
are particular issues surrounding when offsets are linked to project proposals, why and how
offsets are triggered (significance as well as the replicability of impacts), and who is involved in
triggering, designing and implementing offsets.
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8.4.3 Summary: Biodiversity Offsetting Conceptual and Operational Development
Exploring the interaction of EIA and offsetting emphasises that despite promotion of offsetting
as a tool to halt net loss of biodiversity, there are still fundamental questions about what we
want to achieve through offsetting in the UK. Specifically, there are split perspectives on the
value and purpose of undertaking offsetting in relation to EIA and therefore how offsetting
should work as a mitigation tool. Different forms of offsetting in UK practice show that offsets
can be used for multiple purposes, and different parts of the offsetting process are being used
to target different issues with practice, with very different results for biodiversity and society.
The variable interpretation of offsetting appears to contrast with attempts to formalise, critique
and evaluate a fixed perspective on offsetting in literature and guidance, which is increasingly
based around idealised characteristics and forms of offsetting. In particular, there is a clear need
to pay attention to the evolution of offsetting metrics in practice which have been found to have
value beyond simply identifying the need for offsets, not just in this study but also in the CEP
and IEEP (2016), and appear to be being used as a tool to confront subjective expert judgement
in EIA and to evidence under-mitigation. The independent value of the metric means that it is
being separated from offset delivery, renamed, and used as part of a wider wave of new
technical tools for impact assessment.
Different interpretations and formulations of offsetting can be linked into different implications
for project design, EIA and the treatment of biodiversity impacts. Therefore, variation in
offsetting practice not only shows that there is disparity between academic and practical
conceptualisation of how offsetting works, but offsetting effectiveness may also need to be
thought of differently in relation to different forms of offsetting and how they seek to intervene
in practice. Greater appreciation of variability is needed to account for current divisions between
how we think and write about offsetting and what is occurring in practice, as also advocated by
Hrabanski (2015) and Lapeyer et al. (2015). Furthermore, through exploring integration with
existing tools this research highlights that along with the range of different conceptual and
practical challenges identified in literature and guidance. There is a clear need to consider and
acknowledge fundamental aspects, such as the basis on which we are introducing offsetting, at
what stage in the planning application process, and who is involved, when undertaking
integration. Through appreciating and acknowledging the variability in the way offsetting is
being used as an environmental management tool, we can also better understand the polarized
perspectives around offsetting.
8.5 Chapter Conclusions
This chapter outlined the main research findings and key discussion points for the conceptual
development and operationlisation of biodiveristy offsetting mechanisms and future EIA
practice. The research findings highlight that rather than working as an easy subset of the EIA
paradigm, there are a number of different dynamics to their interaction, including multiple
prospective roles, conceptual disconnections, unintended consequences and opportunities..
This emphasises that the conceptual basis for adopting offsetting is clearly still emerging and
evolving in practice, and different components of offsetting can be linked to different mitigation
roles and outcomes. Keeping track of the variability in offsetting practice is, therefore, key for
studying offset effectiveness and developing key challenges and principles for operationlising
offsetting. In particular, the discussion highlighted that in relation to integrating and connecting
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offsetting to pre-existing tools, there needs to be careful consideration of three factors: when
integration takes place, on what basis and why offsetting is being applied, and who is involved.
For future EIA practice, this Chapter highlights that the inclusion of offsetting metrics in the EIA
process could lead to a resurgence not only in long-standing debates about the communication
of impacts to decision-makers but also the dynamics around the interaction of EOs and EIA
consultants. Despite issues with validty, offsetting metrics are clearly linked by EOs to
disillusionment with current qualitative communciation of impacts used to engender change
and inrease accountability. Given the raft of new quantitative tools for biodiversity valuation,
understanding the extent to which offsetting metrics can be maniputlated or impact on the
behaviour of EIA consultants and developers could be key for future offsetting practice.
Alongside these ideas, offsetting also raises pre-existing debates about the degree to which EIA
should be linked into environmental management and strategic connections to wider
sustainability aspirations.
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9. Conclusion: The Relationship between EIA and Biodiversity Offsetting
This thesis has critically investigated the use of EIA as a vehicle for the operationalisation of
biodiversity offsetting, effectively exploring how offsetting interacts with an existing component
of the regulatory framework in order to contribute to wider debates regarding its effectiveness
as a tool for biodiversity conservation. This final chapter draws together the different strands of
the research to provide a set of concluding points and reflections. Firstly, this chapter outlines
how the research has met the four main research objectives. Secondly, it delivers a broad
reflection on the overall research aim and on the key messages from the study. Thirdly, it clarifies
the main research contributions, which are theoretical, empirical, and practical, in nature.
Finally, it outlines the wider research implications, recommendations, and limitations.
9.1 Reflecting on the Research Aim and Objectives
Biodiversity offsetting is a controversial new conservation mechanism deemed by some as part
of the solution to the biodiversity crisis and written off by others as simply another licence to
trash biodiversity. Offsetting in many contexts is still in its infancy, but with rising application
worldwide the question of whether and how offsetting systems can be operationalised to best
achieve no net loss of biodiversity is a critical arena for research (e.g. Bull et al, 2013; Maron et
al, 2010; 2016; Gardner et al, 2013; Norton, 2008; Race and Fonesca, 1996). Offsetting is unlikely
ever to be used as a sole policy for biodiversity conservation, yet the interaction between
offsetting systems, existing regulatory frameworks and planning appraisal instruments, is
relatively unstudied and the implications for offset effectiveness remain largely unknown.
This research has tried to expand the scope of research on the operationalisation of biodiversity
offsetting by exploring the interaction and integration of offsetting with a key component of
regulatory frameworks for environmental standards - EIA. The focus on the relationship
between EIA and offsetting was based on an attempt to understand the effectiveness and
implications of offsetting in relation to the existing context for the treatment of biodiversity
impacts in UK planning systems, rather than as an isolated policy phenomenon.
The formal aim for this research was to:
To determine whether biodiversity offsetting can stem the decline of biodiversity as
a compensation tool in EIA
The research aim was intentionally kept relatively broad in nature due to the inductive and
emerging nature of this research sphere. To further clarify, through exploring whether
biodiversity offsetting could stem the decline of biodiversity as a compensation tool within EIA,
this research aimed to explore how the EIA and offsetting process would work together and
establish the implications of their interactions for the effectiveness of offsetting as a tool for
biodiversity conservation. To achieve this, the research was structured around a series of
research objectives.
Objective 1: To analyse the theoretical basis for, and the controversies surrounding, the
implementation of biodiversity offsetting to compensate for development impacts on
biodiversity, and identify the current place of EIA within the landscape of offsetting research.
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This first objective was fulfilled by Chapters 2 and 3 which mapped out the landscape of research
and debates related to offsetting theory and practice, and the place of EIA. Through the
Literature Review (Chapter 2) this research examined the main questions and debates around
the concept, ethics and effectiveness of offsetting, highlighting the many promises of offsetting
as a new tool for conservation and the many concerns surrounding the market based nature and
restoration focus of offsets. The multitude of concerns surrounding the introduction of
offsetting clearly contrasts with rising application in practice, this trend highlighted the criticality
of debates around whether and how offsetting schemes can best achieve no net loss of
biodiversity. The achievement of no net loss through offsetting was found to be increasingly
linked to the challenge of ‘getting the system right’, and a growing body of research concerned
with investigating the technical conditions which can facilitate the achievement of no net loss.
In this context, the use of EIA was promoted as a vehicle for offsetting in guidance and literature.
However, the relationship between these two mechanisms was found to have been largely
assumed to be positive rather than critically investigated. Exploring the notion of integration in
relation to environmental assessment and management tools, in Chapter 3, indicated that
integration is often assumed to be passive and positive but this can result in unwieldly tools and
the connection of mechanisms with highly different worldviews. Undertaking a preliminary
integration framework revealed that the conceptual compatibility of these two mechanisms is
far for clear cut and required further research. Integration was, therefore, adopted as the central
phenomenon under investigation.
Objective 2: To map out expectations around the integration of biodiversity offsets and EIA, and
the possible dynamics of their integration and interaction.
In order to more fully outline the possible dynamics of integration, the second objective for this
research was to establish the scope of theoretical expectations around the integration and
interaction of EIA and biodiversity offsetting. Exploring the UK offsetting context, in Chapter 5,
indicated that initial policy proposals had paid little explicit attention to the relationship
between EIA and offsetting. Therefore, to fully collate expectations around the integration and
interaction of biodiversity offsetting, a series of 23 semi-structured interviews were undertaken
with practitioners, consultants, policy makers and NGO members. The analysis of the interview
findings was presented in Chapter 6. The interviews confirmed that EIA was expected to play a
significant role in aiding the operationalisation of biodiversity offsetting, with multiple
prospective roles envisaged by interviewees. However, the practical utility of EIA in
operationalising offsetting was perceived to be potentially limited due to the conceptual
disconnections between these two mechanisms. Significantly, the interviews highlighted
considerable uncertainty around the implications of linking up EIA and offsetting, questioning
whether EIA quality could have adverse knock-on effects for offset quality or alternatively
whether offsetting would work as a catalyst for change in EIA performance. Therefore, EIA was
envisaged to play a significant role in aiding the operationalisation of offsetting. However, the
preferred role that EIA should play was undecided and predictions of the outcomes of their
interaction were found to be highly speculative. The interview findings provided a foundation
for an initial model of the possible dynamics of the interaction and integration of EIA and
offsetting to be developed, illustrating three different possible modes of interaction.
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Objective 3: To explore the connections between biodiversity offsetting and EIA in emerging
practice and identify any possible areas of interaction and evidence of implications.
The third objective was to explore how the dynamics of the relationship between EIA and
offsetting were beginning to play out in practice. Investigating the UK offsetting context, in
Chapter 5, showed that offsetting has emerged in a range of different ways, linked to different
actors and motivations for undertaking offsets. In order to capture and compare some of these
different approaches, and incidentally, capture any variation in the integration and interaction
of relationships between EIA and offsets, a comparative case study approach was undertaken.
The results of the cross case study analysis, presented in Chapter 7, showed that offsetting is
being used primarily as an information-trigger and/or analytical framework for EIA, whilst the
separation of these two mechanisms can lead to conflict between the findings of EIA and
offsetting metrics. In relation to EIA, offsetting was largely found to be interpreted to have two
distinct purposes. These purposes were, first, a traditional conceptualisation of offsetting as a
mechanism to facilitate off-site mitigation for unavoidable impacts, and, second, the application
of offsetting based primarily on the value of metrics as an additional methodology to measure
losses and gains in biodiversity in EIA.
These different interpretations of the primary value of offsetting were found to relate to
different degrees of integration between EIA and offsetting. These included analytical and more
bolted-on or consecutive approaches to integration, which led to different forms of interactions
and implications. The analytical integration of offsetting metrics was found to enable metrics to
considerably shape the EIA process, expanding impact identification, reinforcing on-site
mitigation and compensation stages of the mitigation hierarchy, and raising the bar for impact
significance. In comparison, where offsetting was interpreted as an off-site solution there was a
much lesser degree of integration. Under this interpretation, offsets were much more bolted on
to the EIA process and the application of offsets was much more dependent on the subjective
judgement on impact significance with existing EIA process, consequently offsets worked as a
‘quick fix’ or ‘end-of-the-pipe’ solution for existing issues in EIA. Notably, EIA’s role as a delivery
and implementation framework was absent and the extent to which it is appropriate to engage
EIA in delivering offsets was questioned.
Objective 4: To critically reflect on the outcomes of integrating EIA and biodiversity offsetting in
existing planning practice and the implications for the treatment and management of
biodiversity impacts.
The final objective was achieved through Chapter 8 which brought together the empirical
findings and outlined the key discussion points for both EIA and offsetting practice. Chapter 8
highlighted that EIA clearly has use value for operationalising offsetting, predominantly as a
trigger or analytical framework. However, the integration and interaction between EIA and
offsetting can by no means be assumed to be neutral, and brings into question a number of
issues for both the conceptual and practical development of EIA and offsetting.
For EIA practice the analytical integration of offsetting metrics into the EIA process was found
to be particularly significant. The integration of offsetting metrics into EIA was linked to
disillusionment with the status quo and what EIA currently delivers for biodiversity impacts and
management. In particular, analytical integration showed that offsetting metrics can potentially
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shape the EIA process, influencing impact identification, significance, and adherence to the
mitigation hierarchy, echoing the more general findings of the beneficial effects of the metric
for the planning application process by the CEP and IEEP (2016) pilot evaluation. The EIA context
appears to be tilted towards the acceptance of quantitative approaches. Despite complaints
about the validity and consistency of offsetting metrics, the application of offsetting metrics was
nevertheless seen as a tool for accountability because it challenges qualitative subjective
judgment. The broadly positive influence of offsetting metrics on EIA practice was attributed to
their technical, tangible and targeted nature. The influence of metrics highlights a move to
increase accountability through the adoption of technical tools, and redistribute power between
ecology officers and EIA consultants through using consistent quantitative approaches. The
implications of this are potentially a move away from the use of impact assessment as a pathway
for consensus, deliberation and debate for ecological impacts. Areas of disconnection also
highlighted debates for future EIA practice, primarily whether we want EIA to be solely a decision
informing tool or whether it should take a proactive role in long term environmental
management, and also questions about how we link up project-scale impacts to landscape scale
conservation objectives.
For biodiversity offsetting, exploring the relationship between EIA and offsetting highlights that
the integration of EIA and existing environmental management tools and approaches should not
be undertaken lightly. In addition to the many practical challenges and ecological contingency
factors which already surround the application of biodiversity offsetting, Chapter 8 emphasises
that for integration there is a need to pay particular attention to when integration takes place,
on what basis and why, and who is involved. Furthermore, on a more conceptual level, the
different interpretations of the value and purpose of offsetting in relation to EIA suggest that
exactly how offsetting works as a tool for mitigation and compensation, what it is designed to
achieve, and which parts of the offsetting process are by no means set in stone. In particular,
the perceived benefits of offsetting metrics means that they are increasingly being separated
from the offsetting process, renamed and used independently. Keeping track of the variability
in offsetting practice is, therefore, key to understanding different perspectives on offsetting, to
studying effectiveness, and to identifying the main challenges for the operationalisation of
offsetting.
Research Aim: To determine whether biodiversity offsetting can stem the decline of biodiversity
as a compensation tool in EIA.
This research had a broad remit: to explore how biodiversity offsetting could work with the pre-
existing EIA process, and how the interaction of these two mechanisms might shape the
effectiveness of offsetting. To achieve this aim, this research has employed multiple research
methods and explored policy developments, expert expectations along with emerging practice.
Through undertaking this research it is evident that EIA can work as a means to aid the
operationalisation of offsetting employed both as a trigger and analytical framework to help
facilitate offsetting process. More significantly, when EIA and offsetting occur together the
interaction between these two mechanisms was found to be a key determinant as to whether,
and in what way, offsetting works as a tool for biodiversity conservation. Specifically, when, how
and on what basis, the offsetting and EIA processes were linked together was found to shape
the scope and remit of offsetting as a mitigation tool. With two different interpretations of the
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value and purpose of undertaking offsetting in relation to EIA evident in the empirical findings,
with notably different outcomes for the treatment of biodiversity impacts. Therefore, the EIA
process can play a significant role in how the offsetting process operates as a compensation tool.
The inclusion of offsetting as a compensation tool within the EIA process, arguably, delivered
additional levels of mitigation, as they were used to account for impacts which were deemed
likely to have otherwise remained un-mitigated. However, they were also used to account for
situations where on-site mitigation was particularly difficult or conflicted with profit-margins.
Furthermore, the use of site based EIA as a means to facilitate offsetting was found to be
problematic in terms of linking up offsets with more strategic landscape scale conservation
plans. The ad-hoc and highly specific nature of the impacts generated by EIA led to conflicts
between equivalence and landscape scale aspirations. The application of offsets through EIA
therefore may deliver more mitigation, or simply mitigation in different locations, but the
potential to link up offsets with wider strategic goals has not yet been achieved in emerging UK
practice due to both a lack of strategic infrastructure and competing objectives around offset
site selection. In the absence of a wider strategic framework and aspiration, offsetting is
operating as a bolted on extension of the status quo, providing more mitigation but not
necessarily smarter mitigation for biodiversity impacts.
However, through studying the interaction of EIA and offsetting, it was evident that the
incorporation of offsetting metrics into the EIA process had not just been undertaken as means
to determine the need for an offset but also as a means to try to improve the EIA process. The
tangible, targeted and technical characteristics of offsetting metrics was reported to have had a
number of potential effects on the EIA process including expanding the technical scope of EIA,
incentivising more on-site mitigation and compensation, working as a design tool for projects,
enabling more transparent attribution of impact significance, and driving greater appreciation
of lower level impacts. Consequently, the incorporation of offsetting into the EIA process was
found to work as more than a compensation tool and also as a means to challenge the existing
parameters of EIA practice by those disillusion by the status quo and the treatment of
biodiversity impacts within EIA. These findings are supported by the Defra pilot evaluation (CEP
and IEEP, 2016:6) where participants were reported to have “considered the metric to be an
effective, efficient and transparent tool to quantify and communicate the impact of a
development on habitats”. Therefore, offsetting metrics were found to have independent value
in relation to the EIA process and were linked by participants to the generation of additional
beneficial effects and enhancing the environmental standards of the EIA process. Based on their
findings the CEP and IEEP (2016) evaluation recommends that the use of the Defra habitat metric
should be made mandatory within planning applications to support the implementation and
monitoring of current biodiversity policy. Through incorporating offsetting into the EIA process
the effects could, therefore, be much wider than solely working as a compensation mechanism.
Consequently, the outcomes of offsetting should not solely be discussed in terms of what it can
deliver in the form of off-site compensation but also how they shape and challenge existing
practice.
This research highlights that the integration of offsetting into existing components of practice
should not be assumed to be passive or neutral but will instead have considerable influence over
the scope and remit of offsetting practice. Furthermore, the act of integration has been found
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to bring into question the nature of offsetting practice, integration clearly asks fundamental
questions regarding the value and purpose of undertaking offsetting and how it operates to
achieve better results for biodiversity conservation. Therefore, integration has proved to be a
useful lens to understand the evolution and development of offsetting, and studying it can be a
key pathway to gain insight into different perspectives on offsetting and interpretations of its
value and purpose. The research findings highlight that the advent of offsetting could not only
raise significant questions for how we conserve biodiversity but also clashes with existing
approaches and strategies for managing environmental impacts.
9.2 Research Contributions
This research has sought to advance discussions around the effectiveness of biodiversity
offsetting as a mechanism for biodiversity conservation, by exploring the relationship between
offsetting and key components of the existing regulatory framework for assessing
environmental standards through EIA. The contribution of this research are conceptual,
empirical and practical in nature.
Conceptually, this research advances our understanding of how offsetting practice can operate.
This study has shown that two quite different interpretations of the value and purpose of
biodiversity offsetting are operating side by side through different forms of interaction with the
EIA process, with different implications and outcomes for project proposals and the treatment
of biodiversity impacts. Rather than solely focusing on formalising and consolidating offsetting
practice and principles, this research indicates a need to first acknowledge and conceptualise
the variability in offsetting in practice and the different ways offsetting can work as a tool for
mitigation. For EIA practice, this research, stresses a disillusionment with current practice for
biodiversity impacts, and a need to investigate what a new wave of technical tool could means
for conceptual development and debates around EIA practice.
Empirically, this research provides a critical account of the operation of offsetting at the
development scale. There is considerable academic discussion of how offsetting may operate
and the possible implications but a lack of detailed level systematic reviews of offsetting as part
of planning practice. This research contributes four in-depth case studies, illustrating the
different dynamics of project level offsetting and thereby contributes to wider debate and
understanding of how offsetting operates and the parameters which influence its effectiveness.
Practically, the results of this study can help guide the way that EIA and offsets are used
together. It is unlikely that offsetting and EIA will not come into contact, and therefore
practitioners and ecology officers need to be aware of the possible implication of connecting up
offsets and EIA in different ways, areas of connections, and possible outcomes of different
structural arrangements for the treatment of biodiversity.
9.3 Research Implications and Recommendations
The primary conclusion from this research is that the integration of EIA and offsets should not
be undertaken lightly, or assumed to be neutral. How offsets engage with existing practice was
found to be a key factor as to whether it works as a catalyst for change in the treatment of
biodiversity impacts or simply an end of the pipe measure, bolted on to existing practice and
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issues. This research does not suggest that EIA and offsets are incompatible, but, that the
uncritical combination of these two mechanisms should be avoided.
This research confirms that the EIA framework can be used to aid the operationalisation of
offsetting, most significantly though working as an information trigger for offsets and analytical
framework for offsetting metrics. However, due to conceptual disconnections between these
two mechanims the application of offsetting in the UK context challenges existing ideas in EIA
practice. Offsetting metrics conflict with existing ideas around impact acceptability and
significance in EIA and bring into question the place of EIA as a tool for consensus and
deliberation. While disconnections between EIA and offset delivery brings up questions for the
role of EIA in environmental management and how site based impacts contribute to wider
strategic landscape conservation goals. The contrasting nature of the remit and perspective of
EIA and offsetting need to be taken into account in integrating these two mechanisms.
Furthermore, there is also a need to explore the relationship between EIA and offsets on an
international scale, to understand whether these findings are generalizable to other contexts or
specific to the UK system.
EIA was portrayed as potential point of risk for the operationalisation of offsetting, and the
quality of the EIA process was found to have knock on effects for the quality of offset practice.
Equally, the use of offset brokers and providers highlight disillusionment with EIA
implementation, delivery and compliance efforts for mitigation measures, and attempt to move
compliance out of the hands of developers. The independent use of offsetting metrics is
particularly linked to disillusionment with current EIA practice and appears to be being applied
by EOs to challenge existing qualitative subjective judgements of impact significance and
mitigation effectiveness which are seen as enabling biodiversity loss through the distortion and
downplaying of impacts. The application of offsetting, in particular, metric-based offsetting,
highlights considerable disillusionment with the outcomes of current EIA practice for
biodiversity. How disillusionment with current UK EIA practice is playing out, and resulting in
attempts to change the EIA process is a key area for further research.
Metrics are part of a new wave of technical tools for biodiversity impact and ecosystem services,
this trend suggests a return to the rational and a switch to more quantitative communication of
impacts. Moreover, the independent application of offsetting metrics is even being used, in
some instances, to engender change in EIA practice, drive accountability and conflict with the
qualitative communication of impacts. With the advent of offsetting metrics there is a need to
re-engage with debates around how quantitative and qualitative forms of impacts influence
decision-makers, particularly how quantification and commensuration empower certain
actors and could affect relationships between competent bodies and EIA consultants.
For future EIA practice, the presence of offsetting and the conceptual disconnections between
EIA and offsets also brings into question how EIA should work as a tool for environmental
management and relate to decision-making. Interaction between offsetting metrics and EIA
questions the conciliatory role for EIA, and have been applied to try to make EIA more decision-
making, alter the power dynamics between consultant and ecology officers, and even convert
EIA into a more action orientated and decision-making tool. Offsetting metrics could displace
subjective expert judgement in the EIA process and, therefore, bring into question the nature of
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EIA as a both a science and an art. Equally, the move to use offset providers and brokers
questions whether EIA should become more decision orientated or be involved in offset design
and connected to long terms environmental management and strategic conservation goals. The
degree and form of connection between EIA and offsetting practice needs to be carefully
considered, as they will have different possible implications and challenges for the EIA process
and consultants.
For the conceptual development of biodiversity offsetting, the relationship between EIA and
offsets highlights that offsetting is being used in different ways to engender change in existing
practice. Therefore, this research highlights that we need to pay greater attention to the
variability in offsetting practice, to acknowledge different interpretations and understand
how offsetting can shape existing practice in some cases and operate as a licence to trash in
others.
In designing offsetting systems, a wide variety of technical and conceptual challenge have
already been highlighted in the literature. This research particularly emphasises that
consideration also needs to be given to how offsetting will interact with existing practice. In
undertaking the integration of offsetting and EIA this research highlights that there are three
critical questions: when, on what basis, and who is involved.
There is a need to acknowledge the possible implications of linking offsetting into different
points in the planning application process and different degrees of integration, and to develop
guidance on how offsets should operate when applied at different stages of the planning
process (e.g. under LPA led systems or in an ad-hoc manner). In general, the early application of
offsetting metrics should be sought, as also advocated by the pilot evaluation (CEP and IEEP,
2016) to generate the greatest benefits for EIA practice and ensure offsets do not undermine
on-site mitigation budgets. However, early adoption must only occur with a clear understanding
that offsetting metrics do not necessarily denote the requirement to offset, but can also simply
work as a measure of biodiversity loss. Furthermore, the early application of offsetting must be
scrutinised to ensure that attention is not distracted away from avoidance.
The rising application of offsetting and interaction with existing practice highlights questions
about who is involved with the development, design and implementation of offsetting. In the
UK, offsetting is increasingly seen as an expert issue, the domain of offset brokers and providers
rather than areas for debate and discussion. There is a need to return to debates about who
should be involved in offsetting design and implementation, what role there is for
stakeholders and independent bodies, and how transparent and open this process needs to
be.
Through exploring relationship between impacts and offsets it is also evident that there is a clear
need, under voluntary systems, to pay particularly attention to not only the offsetability of
impacts but also the level of significance required to leverage offset commitments. This research
brings into question the advisability of linking offsets to the label of unavoidable impacts, which
appears to be an avenue through which offsetting can be used to avoid particularly difficult
mitigation or mitigation that conflicts with profit margins. Offsets should be used as last resort
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but there needs to be greater transparency over the choices and trade-offs being made in
implementing offsets, which can be hidden under the label of unavoidable impacts.
Finally, this research highlights that the value and purpose of applying offsetting can be very
different for different actors and therefore the basis for the application of offsetting is a critical
area for continued discussion.
9.4 Research Limitations
This research has studied the interaction and integration of EIA and offsetting practice solely in
the UK context. EIA operates through a broadly similar set of stages worldwide but varies in
details and different issues with practice, performance and planning context. Therefore, the
generalisability of these findings is limited and future studies will be required to determine the
replicability of these findings on an international scale. Furthermore, offsetting in the UK context
is very much an emerging phenomenon this has allowed the investigation of a range of possible
relationship between EIA and offsetting, as set out in Chapter 4. However, exploring emerging
practice could also have biased the results towards more experimental or particularly forward
thinking practice, as also acknowledged by the CEP and IEEP (2016) in the pilot evaluation. The
Ecology Officers studied in this research were often referred to as particularly proactive and
assertive in their use of the offsetting metric as a tool to empower and ask for more mitigation,
effectively biodiversity champions. These aspects limit the generalisability of the findings.
Therefore, the results show the possible relationship between offsetting and EIA but not a
complete picture, nor do they suggest the greater likelihood of one model occurring over
another.
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Appendices
Appendix 1. Key Issues for the Operationalisation of Offsetting
Author Frame Advisors
Business and Biodiversity Offset (2009)
Principles Adherence to the mitigation hierarchy
Limits to what can be offset
Landscape context
No net loss
Additional conservation outcomes
Stakeholder participation
Equity
Long-term outcomes
Transparency
Science and traditional knowledge
McKenney and Kiesecker (2010)
6 key issues for implementing offsets
Key Issues:
Equivalence of project impacts with offset gains
Location of the offset relative to the impact site
“Additionality" (a new contribution to conservation) and acceptable types of offsets
Timing of project impacts versus offset benefits; (5) offset duration and compliance
"Currency" and mitigation replacement ratios
Issues requiring further guidance
Ensure conformance with the mitigation hierarchy
Identify the most environmentally preferable offsets within a landscape context
Determine appropriate mitigation replacement ratios
Maron et al (2016)
Controversies for biodiversity offsetting
Contested issues:
Like-for-like
Biodiversity metric
Offsetability
No net loss
Counterfactual scenario
Mitigation Hierarchy
Additionality
Technical challenges:
Applying the mitigation hierarchy
Surrogates for biodiversity
Offsets and counterfactual scenarios
Capturing uncertainty and time lags
Accounting approach
Governance
Agency problems
Trust fund models
Monitoring , evaluation and auditing
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Bull et al (2013)
Main theoretical challenges, with design recommendations, for biodiversity offsets.
Choosing the right currency
Defining no net loss
Demonstrating equivalence between biodiversity losses and gains
Defining how long offset schemes should endure in perpetuity
Deciding whether to allow a temporal gap between development and offset gains
Managing for uncertainties throughout the offset process
Defining how reversible development impact must be
Defining threshold biodiversity values beyond which offsets are not acceptable
Gardner et al (2013)
Conditions and considerations for no net loss
Offset-Related Design Decisions
Consideration of the landscape concept
Timing of offset delivery
Integrity of the offset accounting system
Ensuring offsets are appropriate and feasible
Rigorous application of the mitigation hierarchy
Long term monitoring and evaluation
Ecological conditions to achieve no net loss
Biodiversity loss and gain are comparable in type and amount
Biodiversity gains are additional
Biodiversity gains are lasting
Norton (2008)
6 principles for developing and approving offsets
Biodiversity offsets should only be used as part of the mitigation hierarchy
Needs to be a guarantee that offsets will occur
Biodiversity offset are inappropriate for certain types of ecosystems
Offset can involve restoration and protection, where there is currently no protection
A clear currency is required to allow transparent loss and gains calculations
Offsets must take into account uncertainty in the outcomes of restoration
Gardner and von Hase (2012)
Key ingredients for no net loss
Biodiversity losses and gains are comparable
Biodiversity gains are additional
Biodiversity gains are lasting
Considering the landscape context when planning for offsets
Considering the timing of offset delivery
Calculating biodiversity losses and gains
Defining the overall accounting system
227
Appendix 2. Example Participant Invite Email
Dear ,
RE: Biodiversity Offsetting – The transition from policy to planning practice
I am writing to invite you to participate in a PhD research project, assessing how biodiversity
offsets are being interpreted in the transition from policy innovation to practical application.
The emergence of new biodiversity offsetting in the UK presents an opportunity to evaluate how
the theory of biodiversity offsetting is being translated into planning practice.
By assessing how biodiversity offsetting has been applied in practice so far, this research is designed
to explore how the design, implementation and outcome of offsetting may be shaped by pre-
existing planning systems and international appraisal tools such as Environmental Impact
Assessment.
It is envisaged that this research will contribute to a better understanding of how offsets can be
designed and structured to achieve no net loss through the planning system, and the governance
realities which will influence the adoption of biodiversity offsetting in practice.
A key part of the research strategy is to engage with experts, to consider their opinions and
understanding of the application of biodiversity offsetting within the planning system. I was
recently given your >>>>> and I wanted to enquire whether you would be willing to participate
in a short interview discussing >>> the development of biodiversity offsetting.
I have included a participation information sheet which covers a number of frequently asked
questions regarding my research, and a provisional interview topic list. I’m conducting phone
interviews over the next few weeks so if you require any further information about your
potential involvement please don’t hesitate to call 07854373271 or email rachel.morrison-
I fully understand that your time is in high demand and if you feel unable to contribute to this
research I would be very grateful if you could recommend a colleague or answer a few questions
via email.
Kindest regards,
Rachel Morrison
228
Appendices 3. Consent Form for the Phase 2 Interview Participants
Appendix 4. All Possible Projects Considered as Options for the Case Studies
Lodge Hill, Residential Development, Land Securities and Medway Council Medway,
Kent, 500 Units
Thaxed Residential Development, Hoar, Essex, 47 units,
Whitehouse Farm, Residential Development, Bellway Homes, North Tyneside, 366 unit
Bardon Hill, Quarry Extension, Bardon Aggregates (Holcim Group), Leicestershire
Glenkerie Wind Farm, Infisis, Scottish Borders
Draycott Road, Residential Development, Southmoor, Taylor Wimpey Oxfordshire, , 98
Units
Rodborough Fields, Residential Development, Lioncourt Homes Gloucestershire, 100
units
Thames Link 2 Railway Enhancement, Brighton to Bedford, Infrastructure, Network
Rail
Cheddar Reservoir 2, Bristol Water, Cheddar, Somerset
Smithy Wood, Motorway Services Area, Extra Motorway Services, Sheffield
Old Park Farm, Residential Development, Exeter Phase 2,350 units
Participant Consent Form
PhD Study:
Biodiversity offset: Moving from policy to planning practice
If you are happy to participate please complete and sign the consent form below
229
Appendix 5. Documents Reviewed in Each Case Study
Glenkerie
Document Reference Full Reference
Glenkerie Environmental
Impact Statement (EIS)
(2007)
Novera Energy (2007) Glenkerie Wind Farm Environmental Statement
Volume 1, [Report] [Online] Available at:
http://www.eib.org/attachments/pipeline/20090382_nts2_en.pdf
[Accessed on: 30th September 2016]
Glenkerie Landscape and
Habitat Management Plan
(LHMP) (2008)
Novera Energy (2008) Glenkerie Outline Landscape and Habitats
Management Plan, Available at:
https://eplanning.scotborders.gov.uk/online-
applications/applicationDetails.do?activeTab=documents&keyVal=JUBK
O6NT00800 [Accessed on: 30th September 2015]
Glenkerie Supplementary
Environmental
Information (SEI) (2008)
Novera Energy, (2008) Glenkerie Supplementary Environmental
Information, [ONLINE] Available at:
https://eplanning.scotborders.gov.uk/online-
applications/files/07F7A4BC4588FE4553A4C035A0E11D8E/pdf/07_024
78_FUL-SUPPLEMENTAL_ENVIRONMENTAL_INFORMATION_-
_SECTION_1__INTRODUCTION-2185913.pdf [Accessed on: 30th
September 2016]
Glenkerie Consultation
Record (2008)
Scottish Border Council (SBC) (2008), Planning Application Decision:
07/02478/FUL; EO response dated 17 April 2008, [ONLINE] Available at:
https://eplanning.scotborders.gov.uk/online-
applications/applicationDetails.do?activeTab=documents&keyVal=JUBK
O6NT00800 [Accessed on: 30th September 2016)
Glenkerie Planning
Approval (2009)
Scottish Border Council (SBC), (2009) Decision no. 10/06/2009;
07/02478/FUL, Development Control Committee, 10th September 2009,
Melrose: Scottish Borders Council [ONLINE] Available at:
https://eplanning.scotborders.gov.uk/online-
applications/files/BB2F3008D76DA5523C3FB12C706D2CD2/pdf/07_024
78_FUL-APPROVED-2344160.pdf [Accessed on: 30th September 2016)
Scottish Border
Biodiversity Policy (2006)
Scottish Borders Council (SBC), (2006) Built and Natural Heritage -
Supplementary Planning Guidance on Biodiversity, [ONLINE] Available
at:
https://www.scotborders.gov.uk/directory_record/25242/supplementa
ry_planning_guidance_for_biodiversity [Accessed on: 30th September
2016]
Scottish Borders Council (SBC) (2016) Biodiversity. [ONLINE] Available
at:
http://www.scotborders.gov.uk/info/379/countryside_facilities_and_wi
ldlife/964/biodiversity/3http://www.scotborders.gov.uk/info/379/coun
tryside_facilities_and_wildlife/964/biodiversity/3. [Accessed 24
September 2016].
Offset Provider Proposals
(2011)
Tweed Forum, (2011) Glenkerie Wind Farm Habitat Compensation, A
proposal to Scottish Borders Council, (Unpublished Letter)
Offset Budget (2014) Tweed Forum (2014) Glenkerie Offset Budget, (Unpublished
Spreadsheet)
230
Scottish Border
Biodiversity Offsetting
Programme
Scottish Borders Council (SBC) (2014) Biodiversity [ONLINE] Available at:
http://www.scotborders.gov.uk/info/379/countryside_facilities_and_wi
ldlife/964/biodiversity/3 [Accessed on: 1st June 2014]
Tharme, A., and Aikman, I., (2012) Biodiversity Offsetting Schemes in
the Borders, Southern Upland Partnership South Scotland Planning
Event, Moffat, 29th February 2012, Moffat, Scottish Borders
Cheddar Reservoir 2 (CR2)
Cheddar Reservoir Two
(CR2) Environmental
Impact Statement (2013
Bristol Water (2013) Cheddar Reservoir Two Environment Impact
Statement Volume 1, [ONLINE] Available at:
http://www.sedgemoor.gov.uk/planning_online/(S(1rvfnghdiuhwzyb11
spvb0bl))/Details.aspx [Accessed on: 30th September 2016]
Cheddar Reservoir Two
(CR2) Habitats Regulation
Assessment (2014)
Sedgemoor District Council (2014) Bristol Water Cheddar Reservoir 2
(CR2), Sedgemoor District Council Planning Application 17/13/00080,
Habitats Regulation Assessment, [ONLINE] Available at: Available at:
http://www.sedgemoor.gov.uk/planning_online/(S(1rvfnghdiuhwzyb11
spvb0bl))/Details.aspx [Accessed on: 1st August 2014]
Cheddar Reservoir Two
(CR2) EIA Consultation
Record (2013)
Bristol Water (2013b) Cheddar Reservoir Two Environmental Impact
Statement Appendices, Appendix A1, CR2 Consultation Record,
meetings dated 14.08.13 and 22.10.13 with Somerset County Council
Ecology Officer; [ONLINE] Available at:
http://www.sedgemoor.gov.uk/planning_online/(S(1rvfnghdiuhwzyb11
spvb0bl))/Details.aspx [Accessed on: 1st August 2014]
Approval Sedgemoor
District Council (SDC)
(2014)
Sedgemoor District Council (SDC) (2014) Decision Number 17/13/0080,
Sedgemore District Council, June 2014, Cheddar, [ONLINE] Available at:
http://www.sedgemoor.gov.uk/planning_online/(S(1rvfnghdiuhwzyb11
spvb0bl))/Details.aspx [Accessed on: 1st August 2014]
Somerset Offsetting Policy Somerset County Council (SCC), (2014) Somerset Habitat Evaluation
Procedure Methodology, [ONLINE] Available at:
http://www.somerset.gov.uk/policies-and-plans/strategies/habitat-
evaluation-procedure/ [Accessed on: 1st August 2014]
Somerset Country Council (SCC) (2016) Biodiversity Offsetting [ONLINE],
Available at: http://www.somerset.gov.uk/policies-and-
plans/strategies/biodiversity-offsetting/ [Accessed 24th September
2016]
Mendip policy Mendip District Council, (2006) The Mendip District Council Local Plan
(2006-2029): strategies and policies, Available at:
http://www.mendip.gov.uk/CHttpHandler.ashx?id=9073&p=0
[Accessed on 30th September 2016]
Somerset Biodiversity
Policy
Somerset Country Council (SCC) (2008) Wild Somerset 2008-2018,
Somerset Biodiversity Strategy, Somerset Biodiversity Partnership,
[ONLINE] Available at:
http://southsomerset.gov.uk/media/10125/8B.pdf [Accessed on: 30th
September 2016]
231
Warwickshire and Coventry Gateway (The Gateway)
The Gateway
Environmental Statement,
Non Technical Summary
(NTS) (2012)
Coventry and Warwickshire Development Partnership (2012) Coventry
and Warwickshire Gateway Non-Technical Summary, Environmental
Impact Statement, [ONLINE] Available at:
http://planning.coventry.gov.uk/portal/servlets/AttachmentShowServle
t?ImageName=1037471 [Accessed on 30th September 2016]
The Gateway
Environmental Impact
Statement (EIS) (2012)
Coventry and Warwickshire Development Partnership (2012)
Environmental Impact Statement (EIS), Chapter 6 Ecology and Nature
Conservation, [ONLINE] Available at:
http://planning.coventry.gov.uk/portal/servlets/AttachmentShowServle
t?ImageName=1037619 [Accessed on: 30th September 2016]
The Gateway Local
Planning Authority
Approval (2012)
Coventry City Council (2012) Decision Letter on application reference
OUT/2012/1791, Decision Date 13th December 2012, [ONLINE] Available
at:
http://planning.coventry.gov.uk/portal/servlets/ApplicationSearchServl
et?PKID=741333 [Accessed on: 30th September 2016]
The Gateway Inspectors
Report and Decision
(2015)
Department for Communities and Local Government (DCLG) (2015),
Called-in Decision: Coventry and Warwickshire Gateway (refs: 2202736
and 2202738, 12 February 2015, Decision letter and Inspector’s Report
on application for planning permission; [ONLINE] Available at:
http://planning.coventry.gov.uk/portal/servlets/AttachmentShowServle
t?ImageName=1180209 [Accessed on: 30th September 2016]
Warwickshire District
Council Biodiversity
Offsetting Policy (2012)
Warwickshire District Council (WDC) (2016) Biodiversity Offsetting,
[ONLINE] Available at:
http://www.warwickshire.gov.uk/biodiversityoffsetting, {Accessed on:
8th September 2014]
Warwickshire District Council (2016), Biodiversity Offsetting [ONLINE]
Available at: http://www.warwickshire.gov.uk/biodiversityoffsetting,
[Accessed 24 September 2016]
The Gateway Biodiversity
Offsetting Report(s) (2012)
FCPR, (2012), Coventry and Warwickshire Development Partnership,
Biodiversity Off-setting Report, November 2012, [ONLINE] Available at:
http://planning.coventry.gov.uk/portal/servlets/AttachmentShowServle
t?ImageName=1048642 [Accessed on: 30th September 2016]
Coventry and Warwickshire Development Partnership, (2012), Coventry
and Warwickshire Gateway, Environmental Impact Statement Appendix
C, Biodiversity offsetting report, August 2012, [ONLINE] Available at:
http://planning.coventry.gov.uk/portal/servlets/ApplicationSearchServl
et?PKID=741333 [Accessed on: 30th September 2016]
Whitehouse Farm
Whitehouse Farm Non-
Technical for the
Environmental Impact
Statement (2011)
Signet Planning (2011) Non-Technical Summary of Environmental
Statement in relation to Hybrid Planning application on the Land at
Whitehouse Farm, Killingworth, Bellway Homes (North East), [ONLINE]
Available at: http://idoxpublicaccess.northtyneside.gov.uk/online-
applications/files/E4FF84B8BBA1AC6A2D592799918D3491/pdf/11_023
37_FUL-NON_TECHNICAL_SUMMARY-282905.pdf [Accessed on 30th
September 2016]
232
Whitehouse Farm
Environmental Impact
Statement (EIS) (2011)
Signet Planning (2011) Whitehouse Farm Environmental Statement,
Chapter 6 Ecology, prepared by E3 Ecology, [ONLINE] Available at:
http://idoxpublicaccess.northtyneside.gov.uk/online-
applications/files/BED21EF92CDFA1DB1826427D77213B06/pdf/11_023
37_FUL-ES_-_CHAPTER_6-282911.pdf [Accessed on: 30th September
2016]
Whitehouse Farm Local
Planning Refusal Letter
(2012)
North Tyneside Council (2012) Decision no 11/02337/FUL, Refusal
Letter, North Tyneside Council Planning Committee, 2th April 2012,
[ONLINE] Available at:
http://idoxpublicaccess.northtyneside.gov.uk/online-
applications/files/D210C0554869DEDDB271E897AFBBCBCA/pdf/11_02
337_FUL-
REFUSAL_OF_OUTLINE_PLANNING_PERMISSION_11_00226_OUT-
321132.pdf [Accessed on 30th September 2016]
Appeal Reports and
Statement of Evidence
(2013)
Department for Communities and Local Government (2013)
Whitehouse Farm Inspectors Report and Decision, Application Ref:
11/02337/Ful Our Ref: APP/W4515/A/12/2175554, December 2012,
[ONLINE] available at:
http://idoxpublicaccess.northtyneside.gov.uk/online-
applications/files/614F2FFB185F2BD29602AF9A74840EA5/pdf/11_0233
7_FUL-APPEAL_DECISION-353251.pdf [Accessed on: 30th September
2016]
Signet Planning (2012) Appeal against North Tyneside Councils refusal
of Hybrid Planning application for Whitehouse Farm, [ONLINE] Available
at: http://idoxpublicaccess.northtyneside.gov.uk/online-
applications/files/2A2F10FA0CCCDAC01CDA892F24561C5E/pdf/11_023
37_FUL-BH_6-1_SANDRA_MANSON_PROOF_OF_EVIDENCE_-
_FINAL_25.09.12-321219.pdf [Accessed on: 30th September 2016]
Biodiversity Offsetting
Report
Environment Bank (2012) Offset Search for Whitehouse Farm,
Killingworth, September 2012, [ONLINE] Available at:
http://idoxpublicaccess.northtyneside.gov.uk/online-
applications/files/4794DC1083DDF1B0D857E292C12EA764/pdf/11_023
37_FUL-OFFSET_SEARCH_FOR_WHITE_HOUSE_FARM_-321164.pdf
[Accessed on: 30th September 2016]
Environment Bank (2014) Biodiversity Offsetting Scheme, Whitehouse
Farm, Killingworth, (Unpublished report)
E3Ecology, (2014) Habitat Management and Maintenance Plan Land Off
Mare’s Close, Seghill, (Unpublished report)
North Tyneside Council
Local Plan
North Tyneside Council (2002) North Tyneside Unitary Development
Plan, e12/6, e12/2, [ONLINE] Available at:
https://www.northtyneside.gov.uk/browse.shtml?p_subjectCategory=7
75 [Accessed at: 30th September 2016]
233
Appendix 6. Example Document review process for an Environmental Statement in a Case
Study
(1) Overview: A swift look through to identify documents available, there type and
context, and collect together the often multiple documents that constitute an EIS.
(2) Contents: A look at the contents, identify the sections which need to be read in
detail, particularly those sections relation to ecological impacts, natural resources
or biodiversity impacts.
(3) Introduction, Context and Non-Technical-Summary: Read the introductory
chapter, identify generic methods used, guidance, gain an understanding of the
environment, planning and development context, and the main impacts.
(4) Ecology and Biodiversity: An in-depth reading of all sections relevant to ecology
and biodiversity impacts, paying particular attention, to the treatment of impacts,
methods used, attribution of significance and link to mitigation, compensation and
offset measures
(5) Biodiversity offsetting: Any sections discussing the application of biodiversity
offsetting, or biodiversity offsetting management plans (BOMPS) or calculation
reports.
(6) Concluding chapters: review concluding chapters, in particular those comparing
impacts or proposing mitigation
Appendix 7. Interviews for the Case Studies
Case Study Interviewees
Interviewee Position Interview code
Glenkerie Local Planning Authority Ecology Officer G.I.1
Glenkerie Offset Broker G.I.2
Glenkerie Ecological Consultant G.I.3
CR2 Local Planning Authority Ecology Officer C.I.1
CR2 Ecological Consultant C.I.2
CR2 Local NGO Member C.I.3
CR2 National NGO Member C.I.4
CR2 Statutory Consultee C.I.5
Gateway Local Planning Authority Ecology Officer GA.I.1
Gateway LPA Offset Project Officer GA.I.2
Gateway Local NGO Member GA.I.3
Whitehouse Farm Local Planning Authority Ecology Officer W.I.1
Whitehouse Farm Offset Project Officer W.I.2
Whitehouse Farm Local NGO member W.I.3
Whitehouse Farm Local Interest Group Member W.I.4
234
Appendix 8. Example Interview Questions for the Case Studies
(1) Offset Design and Implementation:
Is the project embedded within a wider LPA policy on Biodiversity Offsetting?
What triggered the application of biodiversity offsetting for this project?
How was the need for offsets established, and what or who was the driving force?
What was the rational for applying offsetting instead of onsite mitigation?
How were the impacts determined to be appropriate for offsetting?
How, who and when was the offset designed?
What delivery mechanism was used to implement the offset?
(2) EIA in the Offset process:
What role, if any, is attributed to EIA within this offsetting project?
To what extent were offsets triggered by the EIA process?
How did the results of the metric compare to the EIA results/ Significance?
Was EIA an influential factor in triggering offsets?
How was the information from the EIA process used in the offset process, if at all?
Did EIA contribute to the design and implementation of biodiversity offsetting
235
Appendix 9. Framework for the Case Study Review
CASE STUDY X: - BASIC INFORMATION
Case Study Dates
Type of development
Brief Planning History
Planning Permission
Site Location
Offset Location
LPA Developer
Consultants
Consutlees
Offset Provider Offset Broker
Documents and websites reviewed
Interviewees Organisation Role Transcription
1.
2.
CASE STUDY: ECOLOGICAL IMPACTS IDENTIFIED AND MITIGATION PROPOSED
Development Components
Baseline Site Description
Ecological receptors identified in the ES
Environmental statement: Main Ecological Impacts and mitigation measures undertaken
Mitigation proposals in the ES
Residual Impacts On-site
Consultation on the ES
236
OFFSET POLICY REVIEW
Origins of the scheme
Reasoning for the scheme
Interpretation of Biodiversity Offsetting and No Net Loss
Overarching offset policy
LPA
Company
National pilot
Metric – species or habitat
Principles of the scheme
Process
Trigger
Metric
Role of EIA
Delivery mechanism
Framework to enforce offsets or voluntary
Strategic framework for offset
Key Partner or Actors
OFFSET PROCESS AND DELIVERY:
Rational or Trigger for Introducing Offsetting
Impact was the offset used to address
Significance and value and magnitude of the impact
Overview of the Offset process
Metric and Methodology
Offset Design and Delivery
Final Offset Site and Plan
Long Term Management Arrangements
Planning Condition
Reflections and connection to the EIA process
