Building the foundations of a Restoration Economy - raising investment for habitat banks - Prof David Hill CBE Chairman, Environment Bank
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Building the foundations of a Restoration Economy – raising investment for habitat banks Prof David Hill CBE Chairman, Environment Bank
Policy background • 25-year Environment Plan and National Planning Policy Framework • Restore 500,000ha of land for ecosystem benefits - Nature Recovery Network • Mandatory biodiversity net gain consultation – out now • New approaches to funding needed - both public and private sector. Basic payment scheme (CAP subsidy) to end • 75% of land in the UK is farmed and farming intensification has inflicted greatest impacts on wider-countryside biodiversity • Target funding at interventions in the farmed environment that can deliver large-scale significant improvements within as relatively a short a time period as possible
The Restoration Economy Policy Framework Value Action needed Sector Mandatory on Planning Authorities to require development to deliver net gain much of which would be off-site. Investment in Habitat Banks (potential Development National Planning tax incentivisation for investors). Biodiversity offsetting/ net Policy Framework and £1.2bn p.a gain delivery, including local plans; newts/European Protected supplementary Species planning documents Environmental land management contracts (Market-based commissioning of contracts with land managers). Paid for efficiencies of Agriculture 25-year Environment £3.2bn p.a production and environmental goods Improving environmental Plan and services – aggregate value not mutually exclusive. performance of farming Tax incentives (?) Credit trading scheme – standard needed. Corporate business Corporate natural capital ONS/NAO. Metrics. accounting – offset £3bn p.a Financial annual Offset business impacts on natural business impacts on reporting capital throughout supply chain. natural capital Demonstrate responsibility – measure requirement increased investment value of company; Biodiversity Disclosure Initiatives; licence to operate. Credit trading scheme – standard needed.
Biodiversity net gain • The most significant conservation policy development for the wider terrestrial environment in the past decade. Included in NPPF and 25-year Environment Plan • LPAs have duty to protect biodiversity in planning system – NPPF • Most are not delivering on their legal responsibility • A mandatory system would signal investment opportunities which would facilitate scale-up and create, enhance and manage large areas of habitat for biodiversity conservation • – MHCLG Garden Towns and Villages prospectus – includes BNG as a requirement
Map of LPAs engaged with Environment Bank 77 LPAs in 34 Counties have engaged with Environment Bank as at 2018
Recent & forthcoming sales Credits Location Development Compensation required Type Location Coventry Business development 4 0.5ha grassland restoration Within 2km York, North Yorkshire Large residential 1152 On-site grassland/birds On-site/adjacent Medway, Kent Large residential ~ 850 Bird compensation Within County Wet grassland - indirect impacts to NE Lincolnshire Industrial zone regeneration 711 SPA On-site/adjacent 3 ha lake restoration + woodland Rochford, Essex c. 600 houses + school 14 creation Within 2 km 32 ha arable margins and grassland Cambridge, Cambridgeshire Large residential 211 Within 1 km restoration Rugby, Warwickshire c.100 houses 19 5 ha grassland restoration Within 4 km Rugby, Warwickshire c. 860 houses + school 13 3 ha grassland restoration Within 1 km Thundersley, Essex c. 7 houses 30 6 ha woodland restoration Within 2 km Wheatley, Oxfordshire c. 50 houses 8 1 ha Grassland creation Within 7 km Warwick, Warwickshire c. 60 houses 5 1 ha grassland restoration Within 3 km Southam, Warwickshire c. 240 houses + sports facilities 11 2 ha grassland restoration Within 6 km
How to make net gain work • LPA requires application of biodiversity impact accounting metric on ALL development to deliver net gain • Impact of development assessed – 80% of gain should be off-site; 20% on-site. Net gain is not about ‘prettifying’ development • Developer purchases conservation credits from broker of strategically located ‘habitat bank’ which yields the credits based on a Biodiversity Management Plan • Environment Bank (EB) brokers deal - signs legal agreements to purchase the credits with developer, and to manage receptor site with land manager • Money paid by EB under a contract with land manager against specific conservation management delivery • Monitoring and reporting to LPAs
Case study example - development • Biodiversity value of existing 12.96ha site = 48.68 units • Biodiversity value of the proposed development = 16.78 units • Biodiversity Offset units = -31.90 units • Large areas of low value habitats, but significant impact due to small areas of mitigation to allow development to meet housing need.
What is a habitat bank? • Area of land restored for biodiversity at scale – 40-100ha in size • Value added by being linked to existing sites of conservation value - spatial plans for conservation – bigger, better, joined • Delivery agent : Landowner/farmer; wildlife trust; other conservation NGO; Community Benefit Society (not-for- profit) • Brokers used to raise and validate conservation credits from the land management interventions – use existing and agreed metric so standardised assessment.
Benefits of habitat banking (1) • Developers o Clarity and certainty o Increased net developable area o No long-term on-site liabilities or costs o Developer knows price beforehand o Allows immediate purchase • Planning Authorities o Transparent, consistent, auditable (eg per NPPF, 25 yr Environment Plan) o LPA already signed-up to assured gains and knows the net gains will be delivered o New secured wildlife habitat, easy
Benefits of habitat banking (2) • Biodiversity Conservation o Proper funding of biodiversity – not just landscaping o Financial disincentives for habitat destruction o Enables long-term and large-scale habitat conservation o Biodiversity is a material benefit in planning • Landowners o Restoration economy o Provides a realistic income with long-term funding o Land status not affected
Setting up a habitat bank • Locate landowner(s), identify area, identify habitat type to be delivered • Survey receptor site • Calculate biodiversity units created, convert to conservation credits to be sold to developers • Produce Biodiversity Management Plan with objectives, measurable deliverables, outcomes focused, timescales set, payment regime (payment by results) • Implement governance documents • Implement monitoring and reporting regime
Habitat bank NE Lincs
Governance • Conservation Credit Purchase Agreement – between Environment Bank and the developer purchasing conservation credits • Letter of Sale provided by Environment Bank to the developer • Conservation Credit Certificate – presented to the developer by Environment Bank on purchase of the credits (before development starts), which in turn is presented to the local authority to demonstrate the discharge of their biodiversity liabilities • Conservation Bank Agreement between Environment Bank and the landowner of the habitat bank • Biodiversity compensation management plan between Environment Bank and offset provider
Habitat bank costs Eg for a lowland grassland habitat bank: • Uses Environment Bank costing model • To create/restore and manage 2 habitat banks in each LPA area • 40ha each in size; yields 240 grassland credits • 30 years duration, inflation proofed • Total cost for capitalisation and long-term management = £1.58m; £3.16m for 2 banks for 30 years • Delivery agent gets capital establishment costs plus £600 per ha per year • Credit price to developer = £6-8,000 per credit
Financing (1) • Upfront funding of the habitat bank is best - provides instant, predictable, cost-effective supply of conservation credits – third party investors/ LPAs (?) • BUT relies on certainty of market – mandatory BNG in planning would provide this • Habitat banks can also be funded ‘incrementally’ as credits are sold to developers • Provides clarity to landowner and >25 year revenue stream to create eg wildflower meadows, wetlands, woodlands etc.
Financing (2) • Regulatory framework – case law has confirmed habitat banks are fully compliant with planning legislation using Section 106 or planning conditions BUT CIL is not an appropriate mechanism to use. • Development is therefore not permitted until such time as conservation credits have been purchased • These factors mean limited exposure (low risk) for investors
Example demand analysis Parameter Data No. houses in development 220,000/yr to year 2030 allocation No. houses per year 11,000 5-year period 55,000 Housing build density (mean) 35 units/ha Area of land-take 1,571 ha No. biodiversity units lost on 6648 average No. conservation credits to be 7313 purchased (10% net gain) Potential area of habitat banks 1463 ha required
Example demand analysis cont… Parameter Data No. 40ha habitat banks to 37 establish Approx. cost of a conservation £7,900 credit Cost of 1463ha of habitat banks £57.8m Average house price £210,000 Total sales income £11.55bn Profitability applied 23% Net profit for 55,000 houses £2.657bn Cost of habitat banking as % of 0.5% of gross income income and profit 2.1% of net profit
Estimates of value of UK biodiversity net gain market Estimate Source £54m p.a Defra (2011) for White Paper £500m - £1.2bn p.a Ecosystem Markets Taskforce (2013) report £700 - £800m p.a Vivid Economics and Environmental Finance, Natural capital finance model – Strategic Outline Case, Defra, March 2018
Third party investment • Habitat banks provide more cost-effective solutions for developers • Bespoke offset site conservation credits cost c. £9k - £20k depending on habitat and length of term. Habitat bank credits c.£6k - £8k. • Proposal to set up 20 habitat banks (800ha) for 30 years in first instance. • Investment sought of £31.7m over a 5 year period • Sale of 4800 credits at £7.5k per credit • Yields return of £4.19m over the 5 years
Opportunities and barriers Opportunities • Ability to make a transformational change to the countryside and its biodiversity • Attract in third party investors and recycle that investment • Transparency, LPA complying with their duties Barriers • Need a mandatory regime with an effective regulatory framework • Some LPAs won’t prioritize or care – so mandatory is essential • Too much emphasis on delivering ‘biodiversity conservation’ within development site boundary – evidence is that this does not provide value for money • Lack of mandatory regime and regulatory framework means investors don’t engage
Net gain and habitat banking for Great Crested Newts • Moved to system based on status of populations rather than individuals • Implementing habitat bank model for newts with agreed species offsetting metrics • Newt habitat created in advance in key areas, credits purchased by developers as needed • Natural England provides District organisational licence to LPAs via NatureSpace Partnership
Scheme coverage 2018-20 • South Midlands now • Expansion into the other regions 2019 onwards
Income and costs £1.2m investment raised to set up South Midlands and secure District Licence Allocation of scheme income • 20% SMNCP Habitat creation • 20% SMNCP Endowment fund • 20% SMNCP operational costs • 40% NatureSpace operational & monitoring costs
Investment vehicle – Green Bonds Bloomberg Barclays MSCI Global Green Bond Index; 2017 c.£200bn
Investment vehicle : Impact investments and environmental credits • £117bn of impact investments globally • Address worlds most challenging problems eg conservation and biodiversity loss • Who? High net worth and Foundations • ?In UK - impact to be addressed is deterioration of biodiversity and natural capital as a result of intensive farming and development • eg restore biodiversity through land sparing – capitalise schemes with returns paid by Government ELM funds – farmer clusters and Community Benefit Society structure
What the Restoration Economy could achieve for the Nature Recovery Network Cost of 40ha high quality mosaic grassland habitat bank – £1.585m creation and 30yr management Value of fund from Environmental Land Management contracts £3.6bn Value of fund from net gain/offsetting (NG) £1.2bn Value of fund from corporate natural capital accounting (CNCA) £3.0bn Area of land restored through habitat banking (exc. CNCA and 90,850 ha/yr NG) Time to deliver Nature Recovery Network (exc. CNCA and NG) 5.5 years Area of land restored through habitat banking (inc. CNCA and 196,845 ha/yr NG) Time to deliver Nature Recovery Network (inc. CNCA and NG) 2.5 years
Summary Mechanism Habitat bank solution Action Biodiversity net gain/habitat Habitat banks – • Mandate net gain – clarity offsetting conservation credits yielded and consistency across by creation and planning authorities management interventions • LPAs will then deliver their Value potentially £1.2bn/yr biodiversity duties from development • Accredit brokers and Conservation credits, locally biodiversity compensation raised and delivered, far (offset) sites better than a general tariff – more fine-scale, relevant • Provides better regulatory and proportionate to impact framework for LPAs Major contributor to the • Bring forward third party Restoration Economy and investors to capitalise Nature Recovery Network habitat banks • Tax incentives for investors
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