England will soon introduce one of the world’s most ambitious biodiversity policies in “Biodiversity Net Gain”.
This policy effectively mandates that any new development leaves biodiversity in a better state than before it was constructed. It was initially meant to go into effect in November, but the government has pushed back its implementation until 2024.
In order to understand the potential impacts of the Biodiversity Net Gain, our team has been tracking development projects approved over the last three years in six councils across England that were early adopters of the policy.
Our latest paper, published this month, reveals several fundamental challenges that threaten the integrity of the policy’s environmental and economic outcomes.
We find that the oversight, monitoring and enforcement of biodiversity improvements supposedly delivered under the policy need urgent attention.
For example, there is a clear “governance gap”, where the system for monitoring biodiversity gains delivered on the site of new developments is weaker than for gains purchased from elsewhere. The process is overseen by local planning departments, which are typically lacking in capacity and ecological expertise.
Biodiversity Net Gain is an essential pillar of the country’s plans for attracting private finance into nature conservation to achieve its overarching environmental objectives.
Ultimately, the challenges we identify threaten the integrity of one of England’s most important environmental markets – and with it, the environmental outcomes of the government’s nature markets strategy.
Biodiversity Net Gain
Under the Biodiversity Net Gain policy, developers have three ways to offset their “biodiversity liability” – the damage their project does to nature. Biodiversity Net Gain applies to most developments, such as housing and smaller infrastructure projects. The policy will apply to major infrastructure projects from 2025 onwards.
First, they can enhance biodiversity somewhere within the development – so-called “on-site” gains. These on-site gains can take the form of, for example, sowing wildflowers along road verges or managing some of the grassland within a housing development to promote wildlife, rather than for traditional landscaping.
If developers can’t meet their liabilities on-site, their second option is to use biodiversity “units” from ecological improvements elsewhere. Under the policy, these units are supposed to mirror the habitat that is impacted by the development, so that when developers damage habitats, they must replace them with habitats that are at least as valuable, from a conservation perspective, as those lost.
Some of these units might come from the new “net-gain market”. Land managers create these units by implementing conservation actions on their land, such as converting low-productivity pasture into a field managed for wildflowers. Then, they sell these units to developers.
Alternatively, some developers are developing their own habitat banks, creating biodiversity units in one place to offset the impacts of their developments elsewhere.
Last, if no units are available through either of these pathways, developers can buy “statutory biodiversity credits” directly from the national government.
These credits loosely resemble the units sold via the market. The government holds a stock of these units as a last resort for developers who cannot offset their damage in other ways. For example, they may offset damage to particularly rare types of habitat for which there may not be suitable credits available on the standard market.
Importantly, the price levels for these statutory units have been set deliberately high, in an attempt to disincentivise developers from relying on these credits.
The ‘governance gap’
Our dataset spans around 1,600 hectares of development footprint that have been submitted or approved for development over the last three years in these six early-adopter councils: West and South Oxfordshire, Vale of White Horse, Cornwall, Leeds City and Tunbridge Wells.
Our team has been collating and analysing the biodiversity assessments submitted to these authorities for each project.
We’ve analysed the trades occurring under the policy and the rules that govern them. Additionally, we have quantified any errors embedded in the developers’ biodiversity assessments. Our research has identified several shortfalls that need addressing for this nature market to be able to deliver on its goals.
Our first key finding is that around one-quarter of all the biodiversity units delivered under the policy so far fall within a “governance gap” – meaning that they are likely to go unmonitored, and may even be legally unenforceable.
As a result, there is a very high probability that regulators will not be able to take any action if these promised gains are not delivered.
This will likely translate into a large chunk of these units not materialising in reality, as there is little incentive for developers to deliver these units in full if there is no credible enforcement mechanism.
The problem is that the standards and regulations of the three offset pathways vary considerably.
There is reasonably stringent governance to ensure that biodiversity units purchased on the offsetting market are delivered in reality. Sellers will have to submit their offsets to a national database, monitor biodiversity changes and report on the ecological development of the site at regular intervals.
Contrary to these standards, the system for monitoring, reporting and enforcing units delivered “on-site” is much weaker. The government has suggested that the existing planning enforcement system can be used to oversee on-site units.
The planning enforcement system was never designed for such a task, and in its current form, is unsuitable for fulfilling this role.
Under the current system, local authorities are explicitly advised to only take enforcement action, such as warnings or fines, if a developer’s violation of a planning condition results in “serious harm to a local public amenity”. Although it is unclear how this will apply to the Biodiversity Net Gain policy, the failure to deliver a habitat that a developer promised in a planning application a few years prior is extremely unlikely to trigger this threshold.
Developers also do not have to log their on-site gains on the national Biodiversity Net Gain register, which means that many of these projects are likely to go unmonitored. Even if they underperform relative to the original promise in the planning application, there is no credible system in place to hold developers to account for such non-delivery.
Risk of non-delivery
In our research, we have found that around one-quarter of all the units delivered under the policy are at a high risk of non-delivery because of this governance gap.
While the regulation of a specific kind of biodiversity unit within a single policy might sound unimportant, this actually has serious implications for how England’s nature markets function.
The core pillar of England’s ambitions for drawing private finance into nature conservation is the Biodiversity Net Gain market. Any biodiversity units that are delivered on-site by developers are units they will not need to purchase from the off-site market. So the less stringent the standards in the on-site system, the more this will drain demand for units from the off-site market, which is relatively more ecologically robust.
Although we recognise our data is preliminary, we estimate that if these under-regulated biodiversity units were to be delivered via the off-site market instead, the demand for biodiversity units could rise by a factor of four.
This could significantly increase the amount of conservation implemented on private land and, therefore, the amount of private finance flowing into conservation projects on private land.
There is precedent for this. The English scheme was partially informed by the US wetland mitigation markets. In 2008, those markets underwent reform to address a similar governance gap.
In the US case, the standards applied to developer-led and third-party projects diverged enormously, meaning a range of low-quality mitigation projects were being implemented by developers. The 2008 compensation rule in the US wetland mitigation system addressed this disparity by ensuring that the same standards were applied across all forms of compensation.
Lacking capacity
Our research also reveals other interesting, consequential patterns. Perhaps the most important to the integrity of this emerging market is the current lack of capacity in local authorities to be able to deliver on the Biodiversity Net Gain policy.
Local authorities do the best they can with the resources they have, but they have undergone stringent funding cuts since 2008.
At the last count, around 60% of local planning authorities have no in-house ecological expertise – which is essential for delivering biodiversity gains effectively.
In our study, we evaluated how many of the applications contained a basic error in their calculations: we checked to see if the area of the site before and after development added up to the same amount.
We found that the areas did not add up in around one-fifth of all projects. Of these, around half had already been accepted by the local planning authorities. One explanation for this oversight could be that planners were so rushed they did not have time to examine the calculations included with the application.
This suggests we have not yet addressed the serious capacity shortages in the councils – who are ultimately going to be the public bodies overseeing the delivery of Biodiversity Net Gain at local scales. This is clear evidence that further investment in local planning capacity is required.
Environmental markets have the potential to be powerful mechanisms for improving nature, but one of the fundamental features of biodiversity compensation markets is that they deliver biodiversity gains that make up for an equal and opposite loss elsewhere.
This means that every biodiversity unit that is promised by developers in order to secure planning permission, but then not delivered in reality, has legitimised the loss of biodiversity elsewhere.
Making sure that these policies lead to direct, robust gains in the quality of nature is therefore absolutely essential to ensure that the markets-focused approach to drawing private finance into nature recovery in England leaves the environment better, rather than worse, off.
The post Guest post: Fixing the gaps in England’s ‘biodiversity net-gain’ policy appeared first on Carbon Brief.
Guest post: Fixing the gaps in England’s ‘biodiversity net-gain’ policy
Climate Change
At Rallies in Utah and Wyoming, PacifiCorp Customers Urge the Utility to Pursue Renewables
Residents of both states fear increased pollution and higher bills if the company does not ramp up its investments in wind, solar and batteries.
Activists in Utah and Wyoming held rallies this week urging state regulators to scrutinize a document they believe will raise energy bills for hundreds of thousands of Westerners, and worsen air pollution across the northern Rockies.
At Rallies in Utah and Wyoming, PacifiCorp Customers Urge the Utility to Pursue Renewables
Brazil’s environment minister Marina Silva said she hopes for heads of state arriving in Belém next week for COP30 to send a clear message on the energy transition in their speeches, and particularly on the transition away from fossil fuels.
“Our heads of state must think of sending a message on topics that are certainly the causes for climate change, which are: can we supply the planet with more renewable energy and can we have a just, planned, gradual and long-term decommissioning of fossil fuels,” said Silva during a press briefing on Friday.
At COP28 in Dubai, countries agreed on a landmark deal to transition away from fossil fuels in energy systems. But at last year’s COP29, governments failed to address this pledge after oil-producing nations blocked all mentions to fossil fuels.
The minister, a close ally of Brazilian president Lula da Silva, noted that this was the language agreed at COP, adding that “this should be for the ending of fossil fuels and deforestation.” “But,” she added, “this needs investment and planning. Things do not happen with magical thinking.”
Fossil fuel-producing countries – among them Brazil – still plan to produce more than double the amount of oil, gas and coal by 2030 than would be consistent with the 1.5C temperature goal of the Paris Agreement, according to a 2025 Production Gap report by a group of think tanks.
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Morocco sets date for coal phase-out for the first time in climate plan
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The Brazilian COP30 presidency also reported that 57 heads of state are expected to participate in the leaders’ summit, a high-level section where countries send political guidelines for negotiators. This year, the summit will take place on November 6 and 7, days before formal talks begin on November 10.
In total, 143 delegations are expected to send representatives to the summit, according to the Brazilian government. Some delegations like the US and Argentina – both with anti-climate presidents – have not yet confirmed participation at COP30, they added.
Silva added that heads of state joining the Belém Climate Summit should set an early tone for negotiations on gender and climate adaptation, both of which are set to deliver outcomes at this COP. On adaptation, the Brazilian minister said messaging should include finance for developing countries and a key list of indicators to measure resilience to climate impacts known as the Global Goal on Adaptation (GGA).
“If there is no global support for local responses to the impacts of climate change, the most vulnerable countries will keep paying the biggest costs,” said the Brazilian minister.
New fund set to be launched
On November 6, Brazilian president Lula da Silva is expected to host a launch event for the Tropical Forest Forever Facility (TFFF), a new fund that would leverage public and private investments in financial markets and use the returns to pay tropical countries protecting rainforests.
The World Bank was recently confirmed as the interim host and trustee for the TFFF, which Brazilian officials said transforms the fund “from an idea into a fully operational reality”. Brazilian officials tried to appease concerns from developing coutnries, which have been critical of the bank’s role in the Fund for Responding to Loss and Damage.
“The World Bank will not set the priorities (for the fund). It is an operator,” Silva told journalists at the briefing. “The TFFF does not lose any controls from donor and recipient countries because it is being operated by the World Bank. The advantage is that the World Bank operates with AAA titles, which makes the TFFF structure viable.”
So far, Brazil and Indonesia have announced the first contributions to the TFFF, both with a $1 billion investment. The fund’s concept note says that the fund should ideally have a startup capital of $25 billion in public funds and $100 in private investments. Brazilian officials say this figure does not need to be met at COP30, but that the fund must receive political backing.
Donor countries, who are expected to pledge new funds at the leaders’ summit, have posed “tough questions”, a Brazilian TFFF official told a panel hosted by Climate Home News. “It seems Ethiopia may be more willing to commit to this than the UK and France,” he joked.
Mauricio Carvalho Lyrio, secretary for Climate, Energy and Environment at the Brazilian Foreign Relations Ministry, said at the press briefing this Friday that “we have very positive expectations that Brazil will have good company in terms of new announcements.”
The post Brazil’s environment minister urges heads of state to address fossil fuels at COP30 appeared first on Climate Home News.
Brazil’s environment minister urges heads of state to address fossil fuels at COP30
Climate Change
DeBriefed 31 October 2025: Hurricane Melissa strikes Jamaica; Climate plans overshoot 1.5C; Protest crackdowns
Welcome to Carbon Brief’s DeBriefed.
An essential guide to the week’s key developments relating to climate change.
This week
Hurricane Melissa
‘TOTAL DEVASTATION’: Hurricane Melissa has killed at least 49 people after sweeping through the Caribbean islands of Jamaica, Cuba, Haiti and Bermuda, reported Independent. Jamaica’s prime minister Andrew Holness said the storm left “total devastation”, destroying homes and infrastructure and leaving people “stranded on roofs and without power”, said BBC News. In Haiti, at least 30 people were killed in floods, Reuters added.
WARM WATERS: Melissa is tied as the strongest Atlantic hurricane to ever hit land, slamming Jamaica with winds of 185mph and fuelled by anomalously warm waters, reported the Associated Press. Fossil-fuelled climate change made the storm “four times more likely”, according to analysis cited by Agence France-Presse. Early estimates suggest infrastructure damage alone could amount to 40% of Jamaica’s gross domestic product, said the newswire.
RECORD RAINS: Elsewhere, Al Jazeera reported on major floods in central Vietnam, where the former imperial city of Huế saw record rainfall of more than 1,000mm over a 24-hour period, according to the country’s weather agency. The Associated Press reported that climate change is “driving more intense winds, heavier rainfall and shifting precipitation patterns across East Asia”.
Climate plans off track for 1.5C
‘DRASTICALLY SHORT’: The latest national climate plans will cause global emissions to drop 10% by 2035 from 2019 levels, “bending the emissions curve downwards for the first time”, but falling “drastically short” of the 60% cut needed to keep 1.5C in sight, said the Guardian. The plans – known as nationally determined contributions (NDCs) under the Paris Agreement – were assessed by the UN in a synthesis report ahead of COP30, the publication said. The 10% cut reflects plans announced by China and the EU, in addition to formal submissions from 64 countries, according to Reuters.
OVERSHOOT ‘INEVITABLE’: UN secretary-general António Guterres said in a joint interview with the Guardian and the Amazonian publication Sumaúma that overshooting 1.5C of global warming was now “inevitable” and would have “devastating consequences”. Guterres “did not give up on the [1.5C] target”, but urged world leaders to “change course” during COP30 to ensure the “overshoot is as short as possible and as low in intensity as possible to avoid tipping points like the Amazon”.
Around the world
- DELIVERY: The UK government published its “carbon budget and growth delivery” plan, outlining policies to meet its mid-2030s climate targets. Read more in Carbon Brief’s in-depth coverage of the plan.
- DEAL UNEARTHED: Donald Trump and Xi Jinping have settled a dispute over rare-earth mineral supplies during trade talks, said the Guardian. Trump described the talks as “amazing” and agreed to reduce tariffs on Chinese goods by 10%, it added.
- AVOIDABLE DEATHS: Climate change and policy “failures” are leading to “millions” of avoidable deaths each year, according to Le Monde’s coverage of the latest Lancet Countdown report on health and climate change.
- DEFORESTATION DOWN: On the eve of hosting COP30, Brazil’s government announced an 11% drop in annual deforestation in the Brazilian Amazon, the fourth consecutive annual fall and lowest deforestation rate since 2014, reported Agence France-Presse.
- DUTCH ELECTION: Democrats 66 (D66), the centrist party led by former climate minister Rob Jetten, narrowly won a snap general election in the Netherlands, said Brussels Signal.
- EU FLEXIBILITY: As the EU continues to negotiate 2040 emissions targets, the bloc is considering a “more flexible path” for industries to meet the goals, reported Reuters.
12 times
The extent to which current finance flows would have to increase to meet developing countries’ adaptation finance needs in 2035, according to the latest UN adaptation gap report covered by Carbon Brief.
Latest climate research
- Young children in sub-Saharan Africa are 77% more at risk from malaria for every 1C temperature increase | PLOS One
- Social media use is linked to “climate anxiety, climate doom and support for radical action” | Climatic Change
- Future droughts could weaken peatlands’ ability to store carbon, creating a positive feedback cycle for climate change | Science
(For more, see Carbon Brief’s in-depth daily summaries of the top climate news stories on Monday, Tuesday, Wednesday, Thursday and Friday.)
Captured
Carbon Brief explored the importance of soil health for food security and climate change in a new Q&A. As the diagram above illustrates, agricultural soil is composed of four layers – known as soil horizons – containing varying quantities of minerals, organic matter, living organisms, air and water. The world’s soils have lost 133bn tonnes of carbon since the advent of agriculture around 12,000 years ago, with crop production and cattle grazing responsible in equal part.
Spotlight
Crackdowns on climate and environmental activism
This week, Carbon Brief speaks to Mary Lawlor, UN special rapporteur on human rights defenders, who led a recent report highlighting crackdowns on the rights of climate and environmental activists around the world.
Carbon Brief: Why do you see climate change as a human-rights issue?
Mary Lawlor: I don’t think there’s any doubt about climate change being a human-rights issue nowadays, because everyone can see it. It interferes with so many rights. The right to food, for example. We’ve seen the situation where drought, storms and floods interfere with food production. And then if you look at the right to life – according to the WHO, we’re currently seeing an average of 175,000 heat-related deaths per year around the world, and those numbers will increase. But we now also have advisory opinions of the ICJ, the Inter-American Court of Human Rights, the International Tribunal for the Law of the Sea, all of which state clearly that climate change is a reality. They see it as a human-rights crisis.
CB: What human-rights violations are being faced by climate and environmental activists around the world right now?
ML: We went to a lot of Indigenous communities in the Amazon and we saw firsthand the threats against Indigenous defenders in Brazil who are opposing carbon-credit projects in their territories, where they themselves have been reducing deforestation with success for years. Then, for example, there were smears against a lawyer in Argentina who was supporting communities in their legal fight against the extraction of lithium from their territories without their consent. And, then, you have surveillance of climate activists organising peaceful protests against new fossil-fuel projects, for example, in the Philippines. So it’s kind of like an octopus, the tentacles are reaching out.
In some of the more developed countries, like France and Spain, you have accusations of terrorism against peaceful climate-justice movements. In Germany, you had the investigation and prosecution of a climate-justice group for alleged organised crime based solely on their peaceful protests that put no human being in danger and did no harm to anyone.
CB: What are some examples that you’ve seen of good practice by governments in relation to the work of climate and environmental activists?
ML: My favourite is Brazil and MST [Landless Workers’ Movement]. They were aided in their tree-planting programme by the federal authorities, who provided helicopters and the federal highway police piloted these helicopters. Seeds of the endangered juçara palm and araucaria trees could be air-dropped over land in Paraná, after the devastating fires that took place. So that’s my absolute favourite, because it showed how a state and defenders can work together as allies to prevent destruction and even worse climate change.
CB: According to Global Witness, 413 land and environmental defenders were killed in Brazil during 2012-2024. What is the current situation for environmental defenders in Brazil going into COP30?
[Brazil] are really making efforts, as far as I can see, to address the root causes – and this is really why human-rights defenders are in such danger – that is, land is at the heart of all the problems there. But progress is still very slow. At the moment, only 16 territories have been demarcated by [Brazilian president] Lula and that is hugely important because, as I said, it’s at the root of pretty much all the attacks and killings by either the thugs associated with the companies, or the big landowners, the illegal logging, and all the stuff that is happening there. So that is something that we really need a speed up of – the demarcation of Indigenous lands.
When it comes to COP30, they’ve put some effort into making it more inclusive, especially when it comes to bringing the voices and experiences of Indigenous defenders into the negotiations. Now we’ll see what will happen in November and what the negotiations bring.
This interview has been edited for length.
Watch, read, listen
‘GOD’S WILL’: Samaa TV followed four street workers across Pakistan, exploring their views on climate change through the lens of faith.
COP EXPECTATIONS: Down to Earth unpacked what to expect from COP30 from a global-south perspective in their Carbon Politics podcast.
1.5C ALIGNED: Scientist and former UN climate lead Ploy Achakulwisut grappled via a LinkedIn post with the challenges of assessing whether national targets are aligned with a 1.5C world.
Coming up
- 4 November: UN emissions gap 2025 report launch
- 4 November: International Energy Agency (IEA) world energy outlook 2025 report launch
- 6-7 November: COP30 leaders summit, Belém, Brazil
Pick of the jobs
- International Institute for Sustainable Development, head of secretariat, national adaptation plan global network | Salary: CA$129,000-CA$161,000. Location: Ottawa or Toronto, Canada (hybrid)
- SRM360, lead writer/editor | Salary: $100,000-$120,000. Location: Remote
- Project Drawdown, senior analyst, climate philanthropy and investing | Salary: $120,000-$160,000. Location: US
- Climate News Tracker, journalism insights analyst | Salary: Unknown. Location: London (hybrid)
- University of Birmingham, climate and public health policy impact fellow | Salary: £36,636-£46,049. Location: Birmingham, UK
DeBriefed is edited by Daisy Dunne. Please send any tips or feedback to debriefed@carbonbrief.org.
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The post DeBriefed 31 October 2025: Hurricane Melissa strikes Jamaica; Climate plans overshoot 1.5C; Protest crackdowns appeared first on Carbon Brief.
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