Of apples, oranges and offsets

And the importance of scientific advocacy in shaping long-term policy

Everyone wants to influence policy to protect those values they care most about. However, everyone goes about ‘influencing’ in different ways. So far in this series on ‘influencing policy’ we have heard views from a psychology researcher, a research policy officer, an NGO science manager and a conservation scientist. In this instalment we hear a perspective from James Trezise, a policy coordinator with the Australian Conservation Foundation. James works on issues from across the conservation spectrum but has a particular interest in biodiversity offsets. Prior to joining ACF, James worked in public policy on offsets, engaging with, among others, researchers from the Environmental Decision Group. Through his work on policy development and conservation he has developed a strong commitment to the input of good science into policy. Here he asks what are the conditions necessary for this to occur.

There has been much written about bridging the science-policy divide – often referred to as the implementation gap. Books, journals and conferences have been devoted to figuring out the social, institutional and political structures needed to ensure decision making is based on sound science. Given this, why is it we seem to miss the evidence-led policy boat so often, particularly when it comes to environmental problems? What are the key elements that need to be in place for science to inform and drive policy? Where has it worked (and where is the evidence for this)? The answers to these questions, like most things, depend almost entirely on context.

In his recent speech to the Academy of Science, the Secretary of the Australian Government Department of the Environment, Dr Gordon De Brouwer, outlined how science informs the work of his Department in numerous ways. One of the topics Gordon De Brouwer touched on was that of biodiversity offsets.

Apples aren’t oranges. And there is no room for flexibility when species are faced with extinction. If a proponent cannot find an offset and cannot restore a site to an equivalent level, surely this is the market telling us that we should not be losing any more of that species or its habitat.

James Trezise out in the field. This field, however, is part a paddock providing habitat for the threatened legless lizard - and it’s up for proposed development. James (on the right) is explaining to a group of biodiversity-conservation students from the Australian National University how the EPBC Offsets mechanism deals with this type of proposal

James Trezise out in the field. This field, however, is part a paddock providing habitat for the threatened legless lizard – and it’s up for proposed development. James (on the right) is explaining to a group of biodiversity-conservation students from the Australian National University how the EPBC
Offsets mechanism deals with this type of proposal.

Science and offsets

The development of the Australian offsets policy is a good example of science-led policy. The approach was consulted on widely, scientific input was incorporated into the policy design and was used to develop a ‘calculator’ to estimate future offsets (See Decision Point #69, page 10). The calculator and policy principles were put to peer review.

But it isn’t all good news. Whilst the process in developing the policy was one that relied on the science, the twist in the tale of biodiversity offsets comes in the implementation.

The EPBC Act offsets policy was designed to bring decision making ‘out of the black box’, increasing transparency and accountability, giving business certainty whilst delivering environmental outcomes. Unfortunately many of these aims remain unrealised and after 15 years of implementing offsets at the federal level (almost 3 under a formal policy framework), the environmental gains being delivered are still uncertain. A Senate references inquiry released in 2014 probed many of these issues. The 160-page report is a good read for those who wish to wrap their head around the issue of offsets.

To give just a taste of the conundrum with biodiversity offsets, a quick scan of the limited information available shows that we are still seeing extensive loss of habitat for species like the endangered Carnaby’s black-cockatoo. Analysis of 18 months’ worth of approval data shows that we lost 3,340 ha of habitat, with replanting of 1,100 ha and protection of an additional 8,612 ha (read more).

In and of itself, this seems rather straightforward. Offsets have traditionally relied on protecting habitat to avert a future loss. But we need to look at where these offsets are, what value they provide, the future loss they avoid, the ability to improve the carrying capacity of the site, the time over which this will all occur and the certainty that this will happen. Thinking about these questions we should then turn our mind to any scientific advice provided for the species in question, in this case the recovery plan, which states that “if additional clearing of large areas of habitat critical to survival is continued and if there is not significant success in replacing important habitat approved for development it is likely there will be further reductions in the population.”

If science is to better inform environmental policy, both in development and also in implementation, there are a few key elements for it to work effectively: trust, transparency, resourcing, access, opportunity and advocacy.

The science is telling us, clearly and unambiguously, that we should not be losing any more habitat for the species unless we commit to replacing it. To do so entrenches its decline. But, replanting habitat is exceptionally expensive. In situ conservation on the other hand, is comparatively cheap. Business, obviously, has an express preference for the least cost model. Like water, it seeks the path of least resistance.

Implementation in a contested arena

Enter the government as a regulator. While it is equipped with scientifically robust tools to inform decisions, it is often swayed by other forces. Where decisions are not necessarily based on science or where there are significant departures from policy or practice, the justification is often that the social and economic benefits far outweigh the environmental harm. The opportunity cost of altering or constraining development is politically unappetising. The problem of the future extinction of species is deferred to the next government.

One only needs to look at the reporting of the over-estimation of the jobs and economic benefits purported to be associated with Adani’s Carmichael coal mine in Queensland to get a sense of how flawed these ‘economic benefit’ escape clauses are when stepping away from science-based decision making.

Shifting policy approaches: apples and oranges

The new dimension in the policy discussion around biodiversity offsets is focussed on establishing markets, creating greater liquidity and improving flexibility. Under these banners there is a general trend toward relaxing policy requirements, opting for models that channel funds into some form of offsets trust and relaxing ‘like-for-like’ provisions, which mean proponents don’t have to target the species or ecosystem subject to an impact.

But moving to greater flexibility could be jumping the gun. Biodiversity offsets are as much an economic instrument as they are a biodiversity conservation tool. Normally they operate like a barter system. Someone will take an apple, provided that they give you an apple or plant some apple trees in return.

Offsets enable the market to put a value on biodiversity. This is usually determined based on its rarity and the likelihood it will be impacted. Scarcity is central to economic theory – the more difficult an offset is to find, such as for endangered species, the more expensive it is likely to be. Relaxing like-for-like provisions (where you can offset your apple by providing some much cheaper, or easier to find oranges) is often driven by proponents frustrated by a lack of available options in the market place.

But here is the case for like-for-like offsets – and it is a very simple one. Apples aren’t oranges. And there is no room for flexibility when species are faced with extinction. If a proponent cannot find an offset and cannot restore a site to an equivalent level, surely this is the market telling us that we should not be losing any more of that species or its habitat.

Who speaks for the long term?

Election cycles at our national level run in three year increments – it is well-known and often lamented that long-term policy thinking gets sucked in to the triennial campaigning cycle. Throw into the mix powerful and vested lobbying groups and you see distortion of policy agendas, short-termism and polling that dictate policy direction rather than science and evidence.

If science is to better inform environmental policy, both in development and also in implementation, there are a few key elements for it to work effectively: trust, transparency, resourcing, access, opportunity and advocacy.

Relationships matter and trust is critical, across individuals and institutions in the public and scientific sectors. Transparency and accountability of our public sector is also vital, it counters the make-it-up-as-you-go-along approach to policy that is easily driven by the political cycle.

Advocacy and scientific expertise

There also needs to be opportunity and resources to support science-led policy, continual improvement cycles and open access to data. Programs like the National Environmental Science Programme (NESP) are vital for creating a reactive and engaged scientific community, building relationships and establishing trust. Publications like Decision Point and The Conversation play their part too, distilling complex research into easy-to-understand policy language. Alongside all of this there needs to be freedom of expression, but this is where we are starting to get a little unstuck.

Positive environmental policies have often come on the back of high profile environmental campaigns (see Martin Taylor’s editorial on NGOs influencing policy). Many of which have been fought on the basis of scientific rigour and a vocal scientific community.

Unfortunately, advocacy is a dangerous word in Canberra at the moment. The right to publically advocate for the environment is being scrutinised by a House of Representatives Inquiry into environmental organisations, its intentions are questionable and its outcomes should be a concern for anyone interested in the protection of our environment. It is imperative that such forces do not stifle or stymie debate and public advocacy for the environment, both by institutions and individuals.

The role of the scientific community should be a positive and a vocal one in guiding long-term policy thinking in Australia. There must be sufficient appetite within government at the highest of levels to support this role, provide open and transparent administration and accept those inconvenient truths that science often tells us.

Offsets are not saving critical habitat for the Carnaby’s black-cockatoo. See page 16 for more details on this story. (Photo by Leonie Valentine)

Offsets are not saving critical habitat for the Carnaby’s black-cockatoo.  (Photo by Leonie Valentine)


More info: James Trezise J.Trezise@acfonline.org.au

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