The OEP has written to the Rt Honourable Lord Benyon, Minister for Rural Affairs, Access to Nature and Biosecurity, in response to Defra’s consultation on the Principles of Marine Net Gain.
The OEP stated it welcomed the overall ambition of the proposed programme to halt and reverse the decline of marine biodiversity and identify a number of key areas for consideration as the policy is progressed.
Chair of the OEP, Dame Glenys Stacey, said:
“The situation in our oceans is urgent and there is no time to lose. This programme is being consulted upon against a backdrop of risks of species extinction, ongoing degradation to the marine environment, and failure to achieve Government targets.”
“While we fully appreciate the significant challenges that will need to be overcome to implement such a programme, the introduction of marine net gain could become a significant and much needed new policy initiative that delivers measurable benefits for nature, supporting the delivery of the 25 Year Environment Plan and legally binding targets.”
The key areas the OEP identify for consideration include:
Marine Net Gain needs to include fisheries – Ensuring nature recovery at sea will require a focus on the most significant pressures on marine ecosystems. This means not only ensuring sustainable exploitation of fisheries, but also protecting the wider marine ecosystem from the impacts of destructive activities like bottom trawling. Marine net gain can be a major mechanism for delivering such recovery, and as such we (the OEP) consider that its scope should include fisheries.
The importance of good governance – good governance, including effective arrangements for the implementation, monitoring, reporting and enforcement of the scheme, will be key to its success. Sufficient resources will be required to set it up well and ensure its long-term success.
The environmental net gain approach to marine net gain is a positive step – We (the OEP) welcome Defra’s commitment to a ‘nature first’ approach, whereby wider environmental benefits, such as from low carbon power generation, would not be considered as a positive impact that contributes to achieving net gain at the expense of marine biodiversity. Ensuring that non-biodiversity environmental gains are not considered when assessing loss to biodiversity and calculating the associated net gain obligations is a critical foundational policy design principle.
There is a need to develop a robust approach to quantifying marine net gain so that progress can be assessed – Without an adequate assessment process, it will be difficult to demonstrate that the proposed net gain obligations can have the predicted impacts or to monitor progress.
Marine net gain and additionality – Clearly defined guidance that ensures additionality will be important for the development of a comprehensive marine net gain programme. The assurance that any proposed net gain activity is additional to existing obligations is a key foundational principle of any net gain policy.