BEAG comments on the Government’s Environmental Bill and the biodiversity net gain concept
There hardly seems to be a day that goes by without another report on the on the sharp decline of nature in the UK. We are, we are told, one of the most nature-depleted countries in the world. For those who love the natural world, the loss of biodiversity in the UK (and globally) is in itself deeply saddening. But given that we all depend on nature for our survival, biodiversity loss should be disturbing news to every one of us.
The Government’s Environment Bill, likely to be given Royal Assent and pass into law this year, promises to transform the UK environment. However, we have serious concerns about the Government’s objectives and its approach to achieving them.
New developments, the Bill states, “will happen in the right places, delivering maximum economic benefit while taking into account the need to avoid environmental damage.” In the context of eco-collapse, we must do more than take environmental harm “into account” in the relentless drive for economic growth.
What does “taking account” of environmental harm actually mean?
In requiring (currently in limited instances) “biodiversity net gain”, the Environmental Bill appears to apply a literal interpretation of the phrase. Using the Government’s biodiversity net-gain tool (some) developers will be required to determine the number of baseline “natural capital” units within the area of proposed development and to show how this baseline can be increased, either on site, or elsewhere, by 10%. This is a highly reductive way of treating non-human organisms – as units of exchange rather than as unique living things, with intrinsic value, and living in complex relationships with other organisms both within the area of proposed development and beyond it. And, of course, the net gain tool cannot “take account” of animal suffering.
Leaving this objection aside, while the net gain tool gives the appearance of rigorous and objective, there is a worrying element of subjectivity involved. Where questions on the condition and classification of a habitat arise, assessments will often be a matter of judgement. The way the measuring system is structured means that small variations in assessments can massively change the final result. With consultants potentially under pressure to cut developer costs, the system is vulnerable to exploitation.
But an even more glaring problem is that it has not yet been demonstrated that “net-gain” works. There are a number of major issues here. One is that, where on-site net gain can’t be demonstrated, developers will have to find offsetting land elsewhere. Land available for nature will be built on and reduced. At the same time, land available for offsetting will also diminish. This is not difficult to understand.
Another crucial issue is the maintenance of net-gain habitats. Setting up bat boxes and bee bricks, planting trees and creating hedgehog highways, ponds and wetland certainly ticks net gain boxes. But some habitats could take at least thirty years to establish.
- Who maintains them, and who checks biodiversity against those original baselines?
- What happens to displaced wildlife in the meantime?
- Decades after profits have been made, how will local authorities hold to account those developers who breach the mandatory 10% biodiversity increase?
With these questions unanswered, it is alarming that nature conservation trusts are also promoting a magic formula for nature, setting up shop to offer net-gain services, and effectively being absorbed into the development sector.
We would ask them to think again because: what if biodiversity net gain doesn’t work?
If the UK Government is sincere about increasing biodiversity in order to avoid a catastrophe, it should not posit developers as the saviours of the natural world, pinning its hopes on uncertain gains. There is another option, one that doesn’t suggest that development and biodiversity increase can go hand in hand, that it’s possible to destroy nature and enhance it too. Instead, there is the option of avoiding harm to the environment in the first place – to protect and enhance what we already have, not to “build, build, build” on it.
Nothing less than our survival is at stake!
- A study on early adopters of biodiversity net gain finds alarming shortcomings.
- A video by Professor David Rogers (Stop the Arc) explains why biodiversity net gain can only fail.
- Friends of the Earth describes biodiversity net gain as a licence to trash nature.
- A discussion around the serious problems with the biodiversity algorithm.