The True Loss Caused by Biodiversity Offsets. Moreno-Mateos, D.; Maris, V.; Béchet, A.; and Curran, M. Biological Conservation, 192:552–559, December, 2015.
doi  abstract   bibtex   
Biodiversity offsets aim to achieve a ''no-net-loss'' of biodiversity, ecosystem functions and services due to development. The '' no-net-less'' objective assumes that the multi-dimensional values of biodiversity in complex ecosystems can be isolated from their spatial, evolutionary, historical, social, and moral context. We examine the irreplaceability of ecosystems, the limits of restoration, and the environmental values that claim to be compensated through ecosystem restoration. We discuss multiple ecological, instrumental, and non-instrumental values of ecosystems that should be considered in offsetting calculations. Considering this range of values, we summarize the multiple ecological, regulatory, and ethical losses that are often dismissed when evaluating offsets and the '' no-net-loss'' objective. Given the risks that biodiversity offsets pose in bypassing strict regulations, eroding our moral responsibility to protect nature, and embracing misplaced technological optimism relating to ecosystem restoration, we argue that offsets cannot fulfil their promise to resolve the trade-off between development and conservation. If compensation for biodiversity loss is unavoidable, as it may well be, these losses must be made transparent and adequate reparation must embrace socio-ecological uncertainty, for example through a Multi-Criteria Evaluation framework. Above all, strict protection legislation should be strengthened rather than watered down as is the current trend. [Excerpt: Conservation implications] We have argued that the values of ecosystems are heterogeneous, plural, and potentially contentious (i.e. incommensurable). Because of the immense complexity of socio-ecological systems, the direct gains of offset are highly uncertain, and the possible indirect losses (ecological, social, and moral) are too great to adopt without criticism. A large body of work has already investigated the theoretical and practical shortcomings of offsets (e.g. Walker et al., 2009, Bull et al., 2012, Maron et al., 2012, Gardner et al., 2013, Clare and Krogman, 2013 and Spash, 2015-in this issue) and our work builds upon these efforts to provide a more comprehensive account of what is at stake. Considering the multiple dimensions of the problem, achieving '' no-net-loss'' appears impossible in practice. Proponents of offsets largely accept this fact (e.g. Gardner et al., 2013), and might object to our critique that (1) offsets are '' better than nothing'' in an era of failing conservation policy, and (2) we do not propose concrete alternatives. We address both points below. [::'Don't let the perfect be the enemy of the good'] A common defence of offsets is that some compensations are better than none. However, this is far too simplistic a view of the social and political context in which offset policies are implemented. First, offset policies arise as both additions and modifications of wider policies, and have led to the weakening of existing, stronger regulation. This includes the mitigation provision under section 404 of the US Clean Water Act (Hough and Robertson, 2009), the '' no take'' provision of the US Endangered Species Act (Ruhl, 1999) and an offset provision introduced as part of Brazil's revised forest code (Soares-Filho et al., 2014). Granted, these policies encountered compliance issues, resistance from interest groups, and are often perceived as ineffective in addressing biodiversity loss. However, in modifying or improving them there is no a priori reason to favour offsets over other options that may be less fallible to regulatory failure (Walker et al., 2009, Clare and Krogman, 2013 and Curran et al., 2015). Perverse incentives linked to offsets mean they may also worsen biodiversity outcomes even if purely additional to existing policies and applied using '' best practice'' guidelines (Gordon et al., 2015). These include entrenching or worsening biodiversity loss baselines (see Maron et al., 2015-in this issue), draining non-offset conservation funding, crowding out other motivations for conservation, and misrepresenting no-net-loss as a '' gain'' for conservation (Gordon et al., 2015). Finally, the introduction of offset legislation is a policy response to demand for better biodiversity conservation. In their absence, other policies would emerge to meet this demand. Thus, the '' offsets or nothing'' argument presents a false dichotomy that lacks any counterfactual validity (Curran et al., 2015). [::Suggested alternatives and improvements] Offsets operate in the context of development decisions where facts are highly uncertain; values are plural, contestable and heterogeneous across social actors; and risks are high with potentially irreversible consequences (e.g. loss of old-growth habitat, species or core socio-cultural values). The current emphasis on top-down, expert assessment to make '' necessary simplifications'' to produce highly contrived metrics of ecological value represents a naïve response to this complexity and uncertainty. One way to tackle both socio-ecological uncertainties and the pluralities of values attached to socio-ecological systems could be to adopt a (Social) Multi-Criteria Evaluation (MCE) framework that combines top-down and bottom-up knowledge through stakeholder participation to arrive at transparent and accountable '' compromise solutions'' (Martinez-Alier et al., 1998 and Munda, 2004). MCE is a decision-support approach to deal with technical incommensurability (i.e. measurable properties of a system that can be observed and weakly compared, but not combined in a single metric) and social incommensurability (i.e. higher-level perceptions and values that differ across social groups and are influenced by politics, participation, ethics, or power; Munda, 2004). The interaction of the technical and social means expert recommendations cannot be taken at face value, and should undergo an '' extended peer review'' process with key stakeholders (e.g. focus groups, deliberation workshops). Rather than presenting a single optimized solution, MCE makes conflicts transparent in an attempt to promote compromise through stakeholder exchange and deliberation. It involves using participation to define a set of policy options (e.g. different development or compensation options) ranked along a range of criteria, both informal and expert-based (Martinez-Alier et al., 1998). Such an approach could be integrated into the offset planning framework (or vice-versa), but implies a major expansion of the role of public participation in determining alternative scenarios, identifying values, establishing metrics, setting offset ratios, identifying '' no go'' options, etc. MCE is also the only one possible approach that should be investigated alongside alternatives. [\n] In essence, our main argument is that, with present knowledge, compensation is not achievable and that using offsets as a trading tool for both tangible and intangible ecosystem values results in the loss of biodiversity and ecosystem benefits to societies. Human agency cannot replace or manipulate nature as a technical exercise through restoration. Thus, the unseen loss will continue for the foreseeable future or until the false goal of no-net-loss is replaced by no-loss. This scenario will be characterized by further destruction of natural habitats, increasing inequity in the distribution of environmental services and values, the strengthening of power asymmetries in development and conservation decisions, and the negation of the intrinsic value of nature. An exception may be when major benefits to society at large (e.g. essential infrastructure or public services) depend on that loss, but demonstrating this requires forms of decision making that fully embrace participation, transparency, fairness and legitimacy.
@article{moreno-mateosTrueLossCaused2015,
  title = {The True Loss Caused by Biodiversity Offsets},
  author = {{Moreno-Mateos}, David and Maris, Virginie and B{\'e}chet, Arnaud and Curran, Michael},
  year = {2015},
  month = dec,
  volume = {192},
  pages = {552--559},
  issn = {0006-3207},
  doi = {10.1016/j.biocon.2015.08.016},
  abstract = {Biodiversity offsets aim to achieve a ''no-net-loss'' of biodiversity, ecosystem functions and services due to development. The '' no-net-less'' objective assumes that the multi-dimensional values of biodiversity in complex ecosystems can be isolated from their spatial, evolutionary, historical, social, and moral context. We examine the irreplaceability of ecosystems, the limits of restoration, and the environmental values that claim to be compensated through ecosystem restoration. We discuss multiple ecological, instrumental, and non-instrumental values of ecosystems that should be considered in offsetting calculations. Considering this range of values, we summarize the multiple ecological, regulatory, and ethical losses that are often dismissed when evaluating offsets and the '' no-net-loss'' objective. Given the risks that biodiversity offsets pose in bypassing strict regulations, eroding our moral responsibility to protect nature, and embracing misplaced technological optimism relating to ecosystem restoration, we argue that offsets cannot fulfil their promise to resolve the trade-off between development and conservation. If compensation for biodiversity loss is unavoidable, as it may well be, these losses must be made transparent and adequate reparation must embrace socio-ecological uncertainty, for example through a Multi-Criteria Evaluation framework. Above all, strict protection legislation should be strengthened rather than watered down as is the current trend.

[Excerpt: Conservation implications]

We have argued that the values of ecosystems are heterogeneous, plural, and potentially contentious (i.e. incommensurable). Because of the immense complexity of socio-ecological systems, the direct gains of offset are highly uncertain, and the possible indirect losses (ecological, social, and moral) are too great to adopt without criticism. A large body of work has already investigated the theoretical and practical shortcomings of offsets (e.g. Walker et al., 2009, Bull et al., 2012, Maron et al., 2012, Gardner et al., 2013, Clare and Krogman, 2013 and Spash, 2015-in this issue) and our work builds upon these efforts to provide a more comprehensive account of what is at stake. Considering the multiple dimensions of the problem, achieving '' no-net-loss'' appears impossible in practice. Proponents of offsets largely accept this fact (e.g. Gardner et al., 2013), and might object to our critique that (1) offsets are '' better than nothing'' in an era of failing conservation policy, and (2) we do not propose concrete alternatives. We address both points below.

[::'Don't let the perfect be the enemy of the good'] A common defence of offsets is that some compensations are better than none. However, this is far too simplistic a view of the social and political context in which offset policies are implemented. First, offset policies arise as both additions and modifications of wider policies, and have led to the weakening of existing, stronger regulation. This includes the mitigation provision under section 404 of the US Clean Water Act (Hough and Robertson, 2009), the '' no take'' provision of the US Endangered Species Act (Ruhl, 1999) and an offset provision introduced as part of Brazil's revised forest code (Soares-Filho et al., 2014). Granted, these policies encountered compliance issues, resistance from interest groups, and are often perceived as ineffective in addressing biodiversity loss. However, in modifying or improving them there is no a priori reason to favour offsets over other options that may be less fallible to regulatory failure (Walker et al., 2009, Clare and Krogman, 2013 and Curran et al., 2015). Perverse incentives linked to offsets mean they may also worsen biodiversity outcomes even if purely additional to existing policies and applied using '' best practice'' guidelines (Gordon et al., 2015). These include entrenching or worsening biodiversity loss baselines (see Maron et al., 2015-in this issue), draining non-offset conservation funding, crowding out other motivations for conservation, and misrepresenting no-net-loss as a '' gain'' for conservation (Gordon et al., 2015). Finally, the introduction of offset legislation is a policy response to demand for better biodiversity conservation. In their absence, other policies would emerge to meet this demand. Thus, the '' offsets or nothing'' argument presents a false dichotomy that lacks any counterfactual validity (Curran et al., 2015).

[::Suggested alternatives and improvements]

Offsets operate in the context of development decisions where facts are highly uncertain; values are plural, contestable and heterogeneous across social actors; and risks are high with potentially irreversible consequences (e.g. loss of old-growth habitat, species or core socio-cultural values). The current emphasis on top-down, expert assessment to make '' necessary simplifications'' to produce highly contrived metrics of ecological value represents a na\"ive response to this complexity and uncertainty. One way to tackle both socio-ecological uncertainties and the pluralities of values attached to socio-ecological systems could be to adopt a (Social) Multi-Criteria Evaluation (MCE) framework that combines top-down and bottom-up knowledge through stakeholder participation to arrive at transparent and accountable '' compromise solutions'' (Martinez-Alier et al., 1998 and Munda, 2004). MCE is a decision-support approach to deal with technical incommensurability (i.e. measurable properties of a system that can be observed and weakly compared, but not combined in a single metric) and social incommensurability (i.e. higher-level perceptions and values that differ across social groups and are influenced by politics, participation, ethics, or power; Munda, 2004). The interaction of the technical and social means expert recommendations cannot be taken at face value, and should undergo an '' extended peer review'' process with key stakeholders (e.g. focus groups, deliberation workshops). Rather than presenting a single optimized solution, MCE makes conflicts transparent in an attempt to promote compromise through stakeholder exchange and deliberation. It involves using participation to define a set of policy options (e.g. different development or compensation options) ranked along a range of criteria, both informal and expert-based (Martinez-Alier et al., 1998). Such an approach could be integrated into the offset planning framework (or vice-versa), but implies a major expansion of the role of public participation in determining alternative scenarios, identifying values, establishing metrics, setting offset ratios, identifying '' no go'' options, etc. MCE is also the only one possible approach that should be investigated alongside alternatives.

[\textbackslash n] In essence, our main argument is that, with present knowledge, compensation is not achievable and that using offsets as a trading tool for both tangible and intangible ecosystem values results in the loss of biodiversity and ecosystem benefits to societies. Human agency cannot replace or manipulate nature as a technical exercise through restoration. Thus, the unseen loss will continue for the foreseeable future or until the false goal of no-net-loss is replaced by no-loss. This scenario will be characterized by further destruction of natural habitats, increasing inequity in the distribution of environmental services and values, the strengthening of power asymmetries in development and conservation decisions, and the negation of the intrinsic value of nature. An exception may be when major benefits to society at large (e.g. essential infrastructure or public services) depend on that loss, but demonstrating this requires forms of decision making that fully embrace participation, transparency, fairness and legitimacy.},
  journal = {Biological Conservation},
  keywords = {*imported-from-citeulike-INRMM,~INRMM-MiD:c-13911605,~to-add-doi-URL,anthropogenic-changes,biodiversity,biodiversity-offsets,conflicts,conservation,controversial-monetarisation,ecosystem,ecosystem-functions,ecosystem-services,hidden-knowledge,integration-techniques,knowledge-integration,mitigation,modelling-uncertainty,multi-criteria-decision-analysis,multi-stakeholder-decision-making,participation,science-policy-interface,science-society-interface,technocracy,trade-offs,transparency,unknown},
  lccn = {INRMM-MiD:c-13911605}
}
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