In an earlier blog I summarised the ambit of Bucks Council's proposed planning policy on biodiversity offsetting and said I would provide a suggested response. You can respond by 19th March by using their on-line form: (https://yourvoicebucks.citizenspace.com/planning/biodiversity-spd-2021/)
Or just send an email to planningpolicyteam.bc@buckinghamshire.gov.uk
Here is my suggested response:
The risks posed to biodiversity by the SPD are so high that the “Mitigation Hierarchy” should not allow offsetting to occur at all. If the first and second stages of the hierarchy cannot be achieved (namely avoid and minimise), development should not be permitted due to the high the risks posed by an offsetting policy such as:
1. The process will be seen as a quick tick box exercise for developers to get down to the offsetting element, stage 4, and lead to lip service being paid to more important stages of the hierarchy matrix.
2. Viability being used to avoid compliance. In areas of high land value, the viability loophole could be exploited.
3. Why exclude nationally significant infrastructure projects, which could be some of the worst offenders, e.g. HS2.
4. Land offered as compensation may not be accessible by the community losing a site.
5. There will exist the potential to lower the bar to approve developments that would otherwise be refused because of impact on local biodiversity.
6. More often than not offsetting will mean that the activities to replace environments will be located on new sites some distance away from the development site - which in fact increases the initial size of the development area, rather than imposing environmental protection on site.
7. It becomes acceptable practice to look at how to deal with adverse impacts from development as a financial package rather than preventing projects that cause environmental damage.
8. It treats nature as a commodity – it puts a £ value on the price of nature, rather than valuing its intrinsic value in its natural location.
9. Not all biodiversity elements are measurable. The methodology ignores the other important factors such as location, social and health aspects to green space, soil sinks and habitat connectivity. These cannot be replicated in a space elsewhere to deliver a net gain and in fact will perpetuate biodiversity loss.
10. Nature just gets moved around to support development. There is no guarantee that new sites would flourish and no penalty if they fail.
11. Direct conservation should be prioritised, offsetting may not be a gain.
12. Does the Council have the right capacity and capability, land availability, finance and staffing to ensure that offset sites can be acquired and managed effectively in perpetuity?
13. What ecology expertise is available to the Council to ensure that stages 1 and 2 do occur on site? Negative planning applications should simply be refused.
14. Bucks Council has an opportunity to act as a role model on how to manage this, by setting out a clear statement on how this will operate and we call on them to do so.
15. Biodiversity is simply valuable where it is.
16. Who will pay if the offset site fails?
17. The focus should be on reversing decline.
18. All new development should respect existing nature in addition to improving it.
19. The SPD does not address the issue of rapid biodiversity loss.
20. It takes many, many years between destruction of one site and the establishment of a new site. Replacement of a mature tree by a small sapling, or replacement of a mature eco-system by an infant one, is not “offsetting” in any real sense.
In summary, the Mitigation Hierarchy is fundamentally flawed in allowing “offsetting” to occur at all, with the risks highlighted above.
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