1
00:00:16,680 --> 00:00:19,920
Hi, I'm Helen Avery with the 
Green Finance Institute and 

2
00:00:19,920 --> 00:00:21,760
you're listening to Financing 
Nature. 

3
00:00:22,640 --> 00:00:25,960
In this episode, I'm joined by 
Thomas Pickford at The Nature 

4
00:00:25,960 --> 00:00:30,320
Conservancy and Glen Anderson of
landscape project Wendling Back 

5
00:00:30,480 --> 00:00:33,560
to talk about biodiversity, net 
gain in England and the 

6
00:00:33,560 --> 00:00:37,360
implications for the EU. 
I think we all need to be saying

7
00:00:37,360 --> 00:00:40,080
that it's public funding plus 
private markets all the other 

8
00:00:40,080 --> 00:00:41,760
way around. 
You know, they, they both need 

9
00:00:41,760 --> 00:00:44,400
to be in the game and both need 
to be scaling up at the same 

10
00:00:44,400 --> 00:00:47,040
time. 
And I think we're starting to 

11
00:00:47,040 --> 00:00:50,040
see that heading in the right 
direction with the messaging 

12
00:00:50,040 --> 00:00:54,120
that we're seeing from the EU 
framework and the IAPD. 

13
00:00:54,640 --> 00:00:58,760
We see the nature markets. 
It should be a triple win 

14
00:00:58,760 --> 00:01:00,920
basically. 
So, you know, you can grow a 

15
00:01:00,920 --> 00:01:05,440
whole green economy off the back
of compliance markets, which 

16
00:01:05,440 --> 00:01:08,800
also enhance your underlying 
natural capital. 

17
00:01:08,920 --> 00:01:13,520
So to kind of deregulate that 
process and destroy nature as, 

18
00:01:13,520 --> 00:01:16,800
as, as part of development, you 
know, it's just ludicrous 

19
00:01:16,800 --> 00:01:18,960
because you're, you're 
destroying your natural capital 

20
00:01:18,960 --> 00:01:22,160
which sits on the the Treasury's
balance sheet as opposed to 

21
00:01:22,160 --> 00:01:23,840
enhance it. 
So you should have a kind of a 

22
00:01:23,840 --> 00:01:27,280
triple fiscal win as part of 
these nature market framework. 

23
00:01:34,160 --> 00:01:37,120
Hello, I hope you're enjoying 
the summer. 

24
00:01:37,120 --> 00:01:40,520
If that is the season you are 
indeed in, it's something to be 

25
00:01:40,520 --> 00:01:42,960
back. 
Today we have a bit of a bumper 

26
00:01:42,960 --> 00:01:47,160
episode in that I'm going to be 
joined by two guests, Thomas 

27
00:01:47,160 --> 00:01:50,240
Pickford, who is the Nature 
Conservancy's engagements and 

28
00:01:50,240 --> 00:01:54,800
relationships lead in the UK and
Glenn Anderson, who is a 

29
00:01:54,800 --> 00:01:58,680
founding partner of a landscape 
scale project called Wendling 

30
00:01:58,680 --> 00:02:02,880
Beck, which has been selling 
biodiversity net gain units. 

31
00:02:03,240 --> 00:02:06,080
And the two have worked really 
closely together on biodiversity

32
00:02:06,080 --> 00:02:09,960
net gain since early days, sort 
of longer than five years. 

33
00:02:10,199 --> 00:02:12,480
And that is really what we're 
going to be talking about today,

34
00:02:12,480 --> 00:02:16,520
England's biodiversity net gain 
market or BNG as we we love to 

35
00:02:16,520 --> 00:02:19,080
call it and what is it, how does
it work? 

36
00:02:19,440 --> 00:02:22,280
And then Glenn's going to give 
us some real colour and depth of

37
00:02:22,280 --> 00:02:26,560
what it looks like for a farmer 
or land manager to be engaged in

38
00:02:26,560 --> 00:02:30,160
BNG and offering those units up.
And Thomas is also going to 

39
00:02:30,160 --> 00:02:35,160
share more with us about BNG in 
the so various movements 

40
00:02:35,160 --> 00:02:39,360
happening in the EU lately, most
notably the EU road map for 

41
00:02:39,360 --> 00:02:41,520
nature markets that launched in 
July. 

42
00:02:41,800 --> 00:02:54,560
So buckle up for our BNG ride. 
So hi, Thomas, thank you so much

43
00:02:54,560 --> 00:02:57,920
for joining us today. 
And well, firstly, how are you? 

44
00:02:58,320 --> 00:03:00,480
I'm very well, Thank you. 
Yeah, all going well. 

45
00:03:00,480 --> 00:03:02,200
How are you? 
Yeah, I'm well, thank you very 

46
00:03:02,200 --> 00:03:05,800
much. 
And so I hope that TNC doesn't 

47
00:03:05,800 --> 00:03:09,040
really need an introduction. 
So I think we're just going to 

48
00:03:09,040 --> 00:03:12,240
dive straight in to biodiversity
net gain in England. 

49
00:03:12,600 --> 00:03:16,000
And I just wondered if you could
start by sharing with those who 

50
00:03:16,000 --> 00:03:20,840
aren't as familiar as us with 
BNG of what is it of? 

51
00:03:21,000 --> 00:03:24,280
Course, yes, it is a a 
complicated concept, so it's 

52
00:03:24,280 --> 00:03:27,760
good to get the basics right. 
So biodiversity net gain is a 

53
00:03:27,760 --> 00:03:30,760
policy that applies in England, 
which requires that all new 

54
00:03:30,760 --> 00:03:33,720
developments achieve a 
measurable increase of at least 

55
00:03:33,720 --> 00:03:37,240
10% in biodiversity when 
compared to pre development 

56
00:03:37,280 --> 00:03:40,080
site. 
It's a pioneering policy really 

57
00:03:40,080 --> 00:03:43,280
it's, it's, it's first of its 
kind and it really has that 

58
00:03:43,280 --> 00:03:46,360
potential to channel private 
finance towards nature right 

59
00:03:46,360 --> 00:03:48,640
across England and integrate 
biodiversity into planning 

60
00:03:48,640 --> 00:03:51,080
processes. 
The concept actually emerged in 

61
00:03:51,080 --> 00:03:54,840
the 2021 Environment Act, 
although the regulations didn't 

62
00:03:54,840 --> 00:03:57,840
come into force until February 
2024, so last year. 

63
00:03:58,400 --> 00:04:00,800
And it's, as I said, a mandatory
requirement for all major 

64
00:04:00,800 --> 00:04:02,840
developments to achieve 10% net 
gain. 

65
00:04:02,840 --> 00:04:05,360
And it actually comes into force
under the Town and Country 

66
00:04:05,360 --> 00:04:08,160
Planning Act, which sounds like 
a technicality, but I think 

67
00:04:08,160 --> 00:04:10,400
that's important for us to 
understand that first and 

68
00:04:10,400 --> 00:04:12,640
foremost, this is a planning 
tool. 

69
00:04:12,880 --> 00:04:16,160
It's a way for the planning 
system to contribute to our 

70
00:04:16,279 --> 00:04:21,200
nature goals as a as a country. 
But what does net gain mean? 

71
00:04:21,200 --> 00:04:24,120
I mean, for a lot of people, it 
doesn't mean much beyond the 

72
00:04:24,120 --> 00:04:27,600
gym. 
So it it means that developers 

73
00:04:27,680 --> 00:04:30,400
have to go beyond just 
compensating for the impacts of 

74
00:04:30,400 --> 00:04:32,960
their development on 
biodiversity and actually 

75
00:04:33,040 --> 00:04:36,600
achieve an increase as compared 
to the biodiversity on that site

76
00:04:36,600 --> 00:04:38,080
before the development was 
built. 

77
00:04:38,720 --> 00:04:42,080
So listeners may or may not be 
familiar with the concept of the

78
00:04:42,080 --> 00:04:46,520
mitigation hierarchy. 
That's basically a system that 

79
00:04:46,520 --> 00:04:50,760
says that developers must first 
avoid any negative impacts and 

80
00:04:50,760 --> 00:04:53,280
then those that they can't avoid
need to be minimised and 

81
00:04:53,280 --> 00:04:56,360
mitigated. 
And then those that you can't 

82
00:04:56,440 --> 00:04:59,280
minimise or mitigate, you then 
restore or rehabilitate. 

83
00:04:59,480 --> 00:05:03,640
So basically compensate and then
you only then use offsets to 

84
00:05:03,640 --> 00:05:07,120
achieve no net loss. 
While the concept of net gain 

85
00:05:07,120 --> 00:05:09,320
requires that developers do all 
of the above. 

86
00:05:09,480 --> 00:05:12,520
So minimise, mitigate, 
compensate and then go even 

87
00:05:12,520 --> 00:05:16,640
further and enhance biodiversity
beyond what was already there. 

88
00:05:17,560 --> 00:05:21,280
Now not all developers will be 
able to achieve 10% increase on 

89
00:05:21,280 --> 00:05:23,280
the site, right? 
It might not just be possible 

90
00:05:23,280 --> 00:05:25,320
space wise or what the 
development is going to be 

91
00:05:25,320 --> 00:05:27,560
doing. 
And that's where the concept of 

92
00:05:27,560 --> 00:05:30,440
biodiversity units or credits 
comes into play. 

93
00:05:31,000 --> 00:05:34,840
If a developer can't achieve a 
10% uplift on site, then they 

94
00:05:34,840 --> 00:05:38,800
can buy biodiversity units off 
the market, essentially paying 

95
00:05:38,800 --> 00:05:41,720
someone else who's restoring and
protecting nature elsewhere. 

96
00:05:42,080 --> 00:05:45,160
And this is usually done in the 
guise of buying units from what 

97
00:05:45,160 --> 00:05:48,920
are called habitat banks, which 
is basically an area of land 

98
00:05:48,920 --> 00:05:52,000
that's been set aside by a land 
manager for nature restoration 

99
00:05:52,000 --> 00:05:54,800
for the long term. 
And then finally, if a developer

100
00:05:54,800 --> 00:05:59,280
can't find offsite biodiversity 
units which are appropriate or 

101
00:05:59,280 --> 00:06:02,240
suitable for their needs, then 
they can buy what are called 

102
00:06:02,240 --> 00:06:05,560
statutory credits, which are a 
last resort option. 

103
00:06:05,560 --> 00:06:08,640
It's the most expensive option 
and that's essentially a 

104
00:06:08,640 --> 00:06:11,120
government backed credit. 
So you're essentially paying the

105
00:06:11,120 --> 00:06:13,640
government to do nature 
restoration somewhere in 

106
00:06:13,640 --> 00:06:17,680
England, a more strategic level.
So essentially what this policy 

107
00:06:17,680 --> 00:06:20,680
has done is create a government 
regulated compliance market for 

108
00:06:20,680 --> 00:06:24,320
biodiversity credits in England,
which is, as I said, pretty 

109
00:06:24,320 --> 00:06:26,600
pioneering. 
And the reason why TNC has been 

110
00:06:26,600 --> 00:06:29,920
so interested in it is because 
we believe it's only through 

111
00:06:29,920 --> 00:06:32,120
such government regulated 
markets that you can actually 

112
00:06:32,120 --> 00:06:35,600
achieve true integrity in 
biodiversity or nature markets 

113
00:06:35,600 --> 00:06:37,160
and actually achieve scale as 
well. 

114
00:06:38,560 --> 00:06:40,440
Thank you. 
That was an absolutely brilliant

115
00:06:40,440 --> 00:06:45,840
and concise explanation of BNG. 
So amazing and sort of coming 

116
00:06:45,840 --> 00:06:47,120
down into the weeds a little 
bit. 

117
00:06:47,120 --> 00:06:49,960
And I know we'll get even more 
into the weeds when Glenn joins 

118
00:06:50,000 --> 00:06:52,920
us. 
So how does it work if you could

119
00:06:52,920 --> 00:06:54,520
explain that? 
I know there's a spatial 

120
00:06:54,520 --> 00:06:57,400
element, a temporal element, and
then of course there's the Defra

121
00:06:57,400 --> 00:06:58,920
metric. 
Yes. 

122
00:06:58,920 --> 00:07:00,960
So maybe starts with the metric 
then. 

123
00:07:01,160 --> 00:07:04,760
So Defra developed a 
standardised metric which uses 

124
00:07:05,080 --> 00:07:07,640
habitat as a proxy for measuring
biodiversity. 

125
00:07:08,160 --> 00:07:10,560
And it allows developers to 
measure the level of 

126
00:07:10,560 --> 00:07:14,000
biodiversity on a site before 
the development and then how 

127
00:07:14,000 --> 00:07:16,760
much of the habitat that they 
will need to restore, either on 

128
00:07:16,760 --> 00:07:19,880
site or offsite to achieve net 
gain after development has been 

129
00:07:19,880 --> 00:07:23,000
has taken place. 
And developers can only actually

130
00:07:23,200 --> 00:07:25,640
achieve planning permission if 
they've conducted this 

131
00:07:25,640 --> 00:07:29,640
calculation and come up with a 
net gain plan for biodiversity 

132
00:07:29,640 --> 00:07:31,680
on their site. 
So that's where that planning 

133
00:07:31,680 --> 00:07:34,640
element comes in. 
So the the metric assessors 

134
00:07:34,640 --> 00:07:40,080
habitat type, distinctiveness, 
condition, size and strategic 

135
00:07:40,080 --> 00:07:43,040
significance. 
So how it fits into the broader 

136
00:07:43,080 --> 00:07:45,120
landscape or ecosystem 
essentially. 

137
00:07:45,600 --> 00:07:48,960
And again, it does use habitat's
proxy, which obviously has its 

138
00:07:48,960 --> 00:07:51,840
limitations. 
There is a spatial multiplier 

139
00:07:51,880 --> 00:07:54,400
built into the metric which 
intends to promote that 

140
00:07:54,400 --> 00:07:56,400
mitigation hierarchy we were 
talking about. 

141
00:07:56,400 --> 00:08:00,560
So it encourages on site 1st and
then it encourages local 

142
00:08:00,560 --> 00:08:04,880
compensation within the boundary
of a local planning authority or

143
00:08:04,880 --> 00:08:08,000
what we call national character 
areas, which are basically just 

144
00:08:08,000 --> 00:08:12,000
landscapes of the same type. 
And essentially if you buy an 

145
00:08:12,000 --> 00:08:17,120
offsite unit from a habit bank 
beyond that specific that local 

146
00:08:17,120 --> 00:08:19,320
area, you have to buy more 
units. 

147
00:08:19,320 --> 00:08:20,800
So it's it's more expensive to 
do. 

148
00:08:21,120 --> 00:08:24,120
So that's what the the kind of 
incentive is to be local. 

149
00:08:24,560 --> 00:08:27,040
Right. 
And then any habitat improvement

150
00:08:27,480 --> 00:08:29,960
has been maintained for 30 
years. 

151
00:08:30,440 --> 00:08:33,000
So that requires the developers 
to have in place a plan for 

152
00:08:33,000 --> 00:08:36,080
maintaining on site habitats for
that period of time. 

153
00:08:36,440 --> 00:08:38,360
So with their planning 
permission, they'll have to 

154
00:08:38,360 --> 00:08:40,559
submit that plan for how it's 
going to be managed for 30 

155
00:08:40,559 --> 00:08:44,880
years, quite a long time. 
And then any offset biodiversity

156
00:08:44,880 --> 00:08:48,480
units, they have to be secured 
and managed for 30 years and 

157
00:08:48,480 --> 00:08:51,200
through legal agreements like 
conservation covenants or 

158
00:08:51,200 --> 00:08:53,520
Section One O 6 agreements with 
local authorities. 

159
00:08:54,240 --> 00:08:56,800
There's also the complexity of 
irreplaceable habitats. 

160
00:08:56,800 --> 00:09:00,800
So that's things like ancient 
Woodlands and blanket bogs and 

161
00:09:00,800 --> 00:09:04,280
basically BNG is not really 
applicable in those 

162
00:09:04,280 --> 00:09:06,320
circumstances. 
Recognising that development 

163
00:09:06,320 --> 00:09:08,240
shouldn't be impacting those 
areas at all. 

164
00:09:08,480 --> 00:09:10,880
And you actually have to have a 
full compensation strategy 

165
00:09:10,880 --> 00:09:14,600
required if you are impacting on
irreplaceable habitats, which 

166
00:09:14,600 --> 00:09:17,400
you shouldn't be anyway. 
And of course there's like 

167
00:09:17,440 --> 00:09:19,880
there's a lot of limitations, 
which I'm sure you know, Glenn 

168
00:09:19,880 --> 00:09:23,080
can also speak to later. 
But you know, habitats to proxy 

169
00:09:23,480 --> 00:09:26,480
does mean that specific 
considerations for species left 

170
00:09:26,480 --> 00:09:30,760
out or ecological functionality 
isn't really accounted for, but 

171
00:09:30,760 --> 00:09:34,160
it does give us that common, 
consistent, standardised science

172
00:09:34,160 --> 00:09:37,720
based framework for nature 
credits, which is that basis for

173
00:09:37,720 --> 00:09:40,200
integrity. 
And it's a means of getting 

174
00:09:40,200 --> 00:09:43,200
payments into farmers and any 
land managers, isn't it, to 

175
00:09:43,200 --> 00:09:45,920
develop these habitat banks? 
Yeah, that's right. 

176
00:09:45,920 --> 00:09:48,960
So we've seen farmers like Glenn
who we'll hear from later, you 

177
00:09:48,960 --> 00:09:51,840
know, putting aside their land 
and there was a lag time between

178
00:09:51,840 --> 00:09:55,520
the investment in the nature 
restoration and potentially the 

179
00:09:55,680 --> 00:09:59,240
the income lost if it was 
productive land beforehand and 

180
00:09:59,240 --> 00:10:01,520
the lifetime between that and 
then any biodiversity credits 

181
00:10:01,520 --> 00:10:04,000
being produced. 
And So what we are starting to 

182
00:10:04,000 --> 00:10:06,600
see is, you know, investment in 
those habitat banks. 

183
00:10:06,600 --> 00:10:08,920
It's kind of a long term 
investment strategy which is 

184
00:10:09,320 --> 00:10:12,920
which is really exciting to see.
We have Vanessa Garcia on a 

185
00:10:12,920 --> 00:10:16,600
couple of weeks ago who was 
talking through mitigation 

186
00:10:16,600 --> 00:10:19,160
banking and sort of this 
biodiversity credit market 

187
00:10:19,160 --> 00:10:21,640
that's under development in 
Colombia as well, which is not 

188
00:10:21,640 --> 00:10:23,520
dissimilar. 
And also a net game was built in

189
00:10:23,520 --> 00:10:25,760
there. 
And you know, the reason we're 

190
00:10:25,880 --> 00:10:28,160
again, we're talking about this 
today is very much in the 

191
00:10:28,160 --> 00:10:32,760
context of B&G is, is this model
that can potentially mobilise 

192
00:10:32,760 --> 00:10:36,960
private investment into nature 
restoration, not just like this 

193
00:10:36,960 --> 00:10:42,600
net net that we've seen before. 
But honestly, I know it's early 

194
00:10:42,600 --> 00:10:45,440
days, but what sort of amounts 
are we looking at here that can 

195
00:10:45,440 --> 00:10:48,720
be can be invested? 
It's a, it's a really good 

196
00:10:48,720 --> 00:10:51,400
question and the figures are 
hard to come by partly because 

197
00:10:51,400 --> 00:10:54,720
it's still such early days. 
You know, the policy has only 

198
00:10:54,720 --> 00:10:58,480
been in effect for what 18 
months and it's a complicated 1.

199
00:10:58,480 --> 00:11:01,040
So it does take time for the 
market to embed from for our 

200
00:11:01,040 --> 00:11:02,840
market actors to get up and 
running. 

201
00:11:03,400 --> 00:11:06,520
We've seen 3000 hectares of land
go on the register in the 1st 16

202
00:11:06,520 --> 00:11:08,240
months, which isn't a bad start 
at all. 

203
00:11:08,280 --> 00:11:09,560
You know that that's 
significant. 

204
00:11:10,080 --> 00:11:12,400
But less than 2% of that has 
actually been sold. 

205
00:11:12,720 --> 00:11:17,600
So it's actually very small 
amount which is suggests that 

206
00:11:17,600 --> 00:11:20,200
that demand is low. 
But that kind of points towards 

207
00:11:20,200 --> 00:11:23,800
some underlying factors which 
are kind of some of the reforms 

208
00:11:23,800 --> 00:11:26,640
that some organisations are 
calling for with biodiversity 

209
00:11:26,640 --> 00:11:29,400
net gains. 
So it does insinuate that most 

210
00:11:29,400 --> 00:11:33,000
developers are choosing to 
achieve 10% BNG on site. 

211
00:11:33,880 --> 00:11:35,280
There are various issues with 
that. 

212
00:11:35,680 --> 00:11:37,800
I mean, one of the main 
criticisms is that they're not 

213
00:11:37,800 --> 00:11:40,120
necessarily the highest 
integrity when developed on site

214
00:11:40,120 --> 00:11:42,800
and there isn't really a 
monitoring framework in place to

215
00:11:42,800 --> 00:11:46,600
keep track of whether they are 
actually achieved in that gain, 

216
00:11:46,600 --> 00:11:48,200
especially over the whole 30 
years. 

217
00:11:48,480 --> 00:11:50,320
You know, local planning 
authorities often just don't 

218
00:11:50,320 --> 00:11:53,120
have the capacity to be checking
up on on these various different

219
00:11:53,120 --> 00:11:56,560
on site. 
And there has also been a report

220
00:11:56,600 --> 00:11:59,680
from F Tech which was 
commissioned by Wildlife Trusts,

221
00:11:59,680 --> 00:12:02,440
Wildlife and French Side Link 
and the Lifescape project which 

222
00:12:02,440 --> 00:12:06,120
came out just this month 
actually, which found that 86% 

223
00:12:06,120 --> 00:12:08,240
of all approved planning 
applications in the first year 

224
00:12:08,240 --> 00:12:12,880
of BNG actually achieved 
exemptions from BNG, which is 

225
00:12:12,880 --> 00:12:16,240
concerning. 
And you know, that is obviously 

226
00:12:16,240 --> 00:12:19,520
limiting demand in terms of 
what's actually been achieved so

227
00:12:19,520 --> 00:12:21,880
far. 
So the best data available is I 

228
00:12:21,880 --> 00:12:26,640
think what I can see from WCL 
Link which found that 680 

229
00:12:26,640 --> 00:12:29,360
hectares of land has been 
secured for off site habitat 

230
00:12:29,360 --> 00:12:32,920
creation enhancement and a 
further 95 hectares on site. 

231
00:12:33,440 --> 00:12:38,280
So it's about 773 hectares 
overall, which is quite a 

232
00:12:38,280 --> 00:12:42,080
shortfall on what Defra 
predicted would be generated 

233
00:12:42,080 --> 00:12:45,160
annually, which is about 5000 
hectares annually. 

234
00:12:45,240 --> 00:12:51,120
So demand just isn't quite there
yet, but we are starting to see 

235
00:12:51,120 --> 00:12:54,240
that tick up gradually and I'm 
sure you'll hear from Glenn 

236
00:12:54,240 --> 00:12:55,840
shortly. 
You know he's had a lot of 

237
00:12:55,840 --> 00:12:58,480
demand for his credits for 
starters. 

238
00:12:58,960 --> 00:13:02,120
We're also going to see and it's
been proposed recently by 

239
00:13:02,120 --> 00:13:04,920
government the integration 
nationally significant 

240
00:13:04,920 --> 00:13:08,880
infrastructure projects into BNG
regulations as of May next year 

241
00:13:08,880 --> 00:13:13,120
2026, which could unlock a lot 
of more demand for biodiversity 

242
00:13:13,120 --> 00:13:15,640
units. 
So watch this space there. 

243
00:13:16,320 --> 00:13:17,960
At the same time as that 
proposal there, we're also 

244
00:13:17,960 --> 00:13:22,240
seeing proposals to remove small
sites from biodiversity net gain

245
00:13:23,000 --> 00:13:27,080
and we what we think is about 
70% of developments purchasing 

246
00:13:27,080 --> 00:13:30,680
off site units at the moment are
those small developments. 

247
00:13:30,680 --> 00:13:34,840
So less than 10 houses, which is
about 38% of the demand so far. 

248
00:13:34,840 --> 00:13:38,600
So that would undermine demand 
even further if we saw those 

249
00:13:38,600 --> 00:13:41,840
proposals goes forward. 
So there's quite a lot isn't 

250
00:13:41,840 --> 00:13:45,560
there to you sort out in these 
early years while it's being 

251
00:13:45,560 --> 00:13:49,120
embedded as you would expect in 
any kind of new policy. 

252
00:13:49,640 --> 00:13:51,800
Because I remember initially 
some of the numbers we saw were 

253
00:13:51,800 --> 00:13:56,720
like 200 million unlocked 
annually into nature restoration

254
00:13:56,720 --> 00:13:59,160
because the assumption was a lot
of it was going to be going into

255
00:13:59,160 --> 00:14:01,880
habitat banks. 
And I know that hasn't been 

256
00:14:01,880 --> 00:14:04,480
quite the case and there's a few
leading issues with it. 

257
00:14:04,480 --> 00:14:06,440
Well, this is that's super 
helpful. 

258
00:14:06,440 --> 00:14:09,080
And thanks for this sort of 
discussion on BNG. 

259
00:14:09,240 --> 00:14:12,000
It's really helpful. 
But, and I know we'll get into 

260
00:14:12,000 --> 00:14:14,200
say more bit more technical 
detail on some of the challenges

261
00:14:14,200 --> 00:14:17,000
when Glenn comes on in a bit, 
but I didn't want to waste this 

262
00:14:17,000 --> 00:14:21,640
opportunity while you're here, 
given how much TNC and the work 

263
00:14:21,640 --> 00:14:23,560
you've been doing. 
Thomas has been looking at 

264
00:14:23,560 --> 00:14:31,720
Europe so far beyond little old 
England and how you could have 

265
00:14:31,720 --> 00:14:33,920
approaches there that would 
unlock private sector 

266
00:14:33,920 --> 00:14:38,120
investment, particularly through
perhaps biodiversity credits or 

267
00:14:38,120 --> 00:14:39,840
mitigation banking, those kinds 
of things. 

268
00:14:40,120 --> 00:14:42,560
So would you be able to sort of 
share with us kind of what is 

269
00:14:42,560 --> 00:14:46,240
the state of play across Europe 
at the moment in terms of do you

270
00:14:46,240 --> 00:14:49,520
see a role for BNG, Is there 
already mitigation banking if 

271
00:14:49,520 --> 00:14:53,360
not with a net gain happening? 
Yeah, of course, it's a really 

272
00:14:53,360 --> 00:14:54,800
exciting field in Europe at the 
moment. 

273
00:14:54,800 --> 00:14:57,800
There's a lot going on. 
There isn't a huge history of 

274
00:14:57,800 --> 00:15:01,480
mitigation banking in Europe. 
We don't see it formally, you 

275
00:15:01,480 --> 00:15:03,680
know, integrated any government 
schemes. 

276
00:15:03,680 --> 00:15:06,440
Currently we are seeing some 
nascent voluntary biodiversity 

277
00:15:06,440 --> 00:15:10,040
credit initiatives being piloted
in places like France, Ireland 

278
00:15:10,040 --> 00:15:12,840
and, and Italy. 
And and because of that, but 

279
00:15:12,840 --> 00:15:16,040
also because of the kind of the 
the extensive policy framework 

280
00:15:16,040 --> 00:15:18,160
that already exists at the EU 
level. 

281
00:15:18,160 --> 00:15:22,320
So the nature restoration 
regulations, the CSRD and all 

282
00:15:22,320 --> 00:15:24,080
the rest. 
Because of that, we actually saw

283
00:15:24,080 --> 00:15:26,760
that there was a real 
opportunity to think about how 

284
00:15:26,760 --> 00:15:30,160
nature credits could be a tool 
in a toolbox to be stimulating 

285
00:15:30,160 --> 00:15:32,960
the finance needed for Europe to
meet its nature goals. 

286
00:15:32,960 --> 00:15:35,960
And you know, we all need Europe
to be meeting its nature goals, 

287
00:15:36,320 --> 00:15:39,920
even how large it is. 
And also, you know, many other 

288
00:15:39,920 --> 00:15:42,400
regions look towards Europe as a
leader. 

289
00:15:42,800 --> 00:15:46,240
And so earlier this year The 
Nature Conservancy published a 

290
00:15:46,240 --> 00:15:50,560
report which sets out the case 
for an EU wide common framework 

291
00:15:50,560 --> 00:15:54,600
to enable the development of 
credible, effective, regulated 

292
00:15:54,680 --> 00:15:57,560
nature markets. 
You know, this is all as I was 

293
00:15:57,560 --> 00:16:00,920
saying, it's the context of that
gaping biodiversity funding gap 

294
00:16:00,920 --> 00:16:04,720
for nature in in Europe, but 
also the the many different 

295
00:16:04,720 --> 00:16:07,640
frameworks and regulations that 
already exist which need 

296
00:16:07,640 --> 00:16:10,520
mechanisms to fund them like 
nature restoration regulation. 

297
00:16:11,280 --> 00:16:16,880
So what we set out in that paper
is various use cases for 

298
00:16:16,880 --> 00:16:20,960
credits, both voluntary and 
compliance, but really centering

299
00:16:20,960 --> 00:16:23,240
the essential role of the 
European Commission in setting a

300
00:16:23,240 --> 00:16:27,640
common science based framework 
of principles, you know, 

301
00:16:27,680 --> 00:16:31,280
protocols for certification, 
verification, enforcement, 

302
00:16:31,280 --> 00:16:34,440
monitoring, governance. 
What we're trying to make the 

303
00:16:34,440 --> 00:16:37,520
case for is that that's the role
of the European Commission to 

304
00:16:37,520 --> 00:16:41,120
set out that framework, which 
the member states can then pull 

305
00:16:41,120 --> 00:16:43,840
from to develop their own 
national schemes in the 

306
00:16:43,840 --> 00:16:47,520
confidence and trust that the 
the scientific rigour exists 

307
00:16:47,520 --> 00:16:51,640
behind that framework already. 
And make sure that we don't see 

308
00:16:51,640 --> 00:16:54,960
this fragmentation of many 
different schemes across the 

309
00:16:54,960 --> 00:16:58,760
different nation member states. 
Which would, you know, possibly 

310
00:16:58,760 --> 00:17:01,960
disincentivize private sector 
investment in these nascent 

311
00:17:01,960 --> 00:17:04,760
markets, but also would 
undermine attempts for, you 

312
00:17:04,760 --> 00:17:08,280
know, trans boundary where 
appropriate trans boundary 

313
00:17:08,800 --> 00:17:11,119
landscapes acknowledging that 
nature doesn't end at the 

314
00:17:11,119 --> 00:17:14,960
border. 
So, you know, we're quite clear 

315
00:17:15,040 --> 00:17:18,680
that we don't see any nature 
market that is not government 

316
00:17:18,680 --> 00:17:22,160
regulated by the voluntary or 
compliance reaching scale 

317
00:17:22,160 --> 00:17:25,560
integrity needed. 
But what we do see is that real 

318
00:17:25,560 --> 00:17:28,079
potential for the European 
Commission to take a step 

319
00:17:28,079 --> 00:17:31,040
forwards. 
You know, excitingly, just this 

320
00:17:31,040 --> 00:17:33,880
month we have seen that with the
the publication of the the Road 

321
00:17:33,880 --> 00:17:37,680
Map towards Nature credits. 
Yes, and I'm sure your paper was

322
00:17:37,680 --> 00:17:40,600
hugely influential in that road 
map development. 

323
00:17:40,600 --> 00:17:43,640
So on that, could you just walk 
us through what that road map 

324
00:17:43,640 --> 00:17:46,120
lays out? 
So it's important to say that, 

325
00:17:46,240 --> 00:17:48,520
as we were talking about 
earlier, the EU road map is a 

326
00:17:48,520 --> 00:17:51,080
voluntary scheme. 
So it's government regulated but

327
00:17:51,080 --> 00:17:54,160
voluntary, and the suggestion is
to create what are called 

328
00:17:54,160 --> 00:17:58,040
certificates, which recognise 
nature positive actions beyond 

329
00:17:58,360 --> 00:18:02,680
individual legal obligations and
mandatory mitigation hierarchy. 

330
00:18:03,480 --> 00:18:06,320
So it's actions that go beyond 
what we already have to be doing

331
00:18:06,320 --> 00:18:09,880
in the EU for instance. 
So a nature credit in this case 

332
00:18:09,880 --> 00:18:13,000
would be considered as a unit 
that represents a nature 

333
00:18:13,000 --> 00:18:17,440
positive outcome derived from a 
certified independently verified

334
00:18:17,480 --> 00:18:20,800
action, which is quantified 
using a recognised metric or 

335
00:18:20,800 --> 00:18:22,840
indicator. 
And that's what we're hoping 

336
00:18:22,840 --> 00:18:26,120
would be designated by this EU 
wide framework. 

337
00:18:26,960 --> 00:18:29,400
And So what it's actually 
proposing is a 2 step model of 

338
00:18:29,400 --> 00:18:31,560
certification going into 
crediting. 

339
00:18:31,880 --> 00:18:35,320
So essentially I would propose A
conservation or restoration 

340
00:18:35,320 --> 00:18:39,560
plan, which I would then take to
a third party independent 

341
00:18:39,560 --> 00:18:43,400
verifier who would then verify 
it based on the criteria which 

342
00:18:43,400 --> 00:18:46,560
is set out in the EU framework. 
So that there is that that 

343
00:18:46,560 --> 00:18:50,560
credibility and confidence that 
what I'm doing is high integrity

344
00:18:50,920 --> 00:18:53,360
for both people and nature, 
importantly. 

345
00:18:53,880 --> 00:18:56,080
And then based on that 
verification, I will be given a 

346
00:18:56,080 --> 00:18:58,840
certificate. 
I can use that certificate to 

347
00:18:58,920 --> 00:19:02,840
help attract, you know, upfront 
investment, but it also gives 

348
00:19:03,040 --> 00:19:05,640
other stakeholders that trust 
that what I'm doing is, as I was

349
00:19:05,640 --> 00:19:08,960
saying, high integrity and then 
credits will be progressively 

350
00:19:09,440 --> 00:19:13,280
issued as the results from that 
plan are achieved. 

351
00:19:13,880 --> 00:19:16,960
So the the road map then sets 
out how we're going to get to 

352
00:19:16,960 --> 00:19:19,720
that endpoint, which is 
essentially the creation of an 

353
00:19:19,720 --> 00:19:23,120
expert body, which is going to 
develop those high integrity and

354
00:19:23,120 --> 00:19:26,000
transparent methodologies. 
And they say they want to focus 

355
00:19:26,000 --> 00:19:29,720
on simplicity and usability, but
also governance and safeguards. 

356
00:19:30,200 --> 00:19:32,840
And, and they also want to try 
to do some work around 

357
00:19:32,840 --> 00:19:35,800
identifying what the key drivers
of supply and demand will be 

358
00:19:35,800 --> 00:19:38,640
within the EU. 
And they also, you know, quite 

359
00:19:38,640 --> 00:19:42,040
importantly, recognise the need 
for public seed funding to kick 

360
00:19:42,040 --> 00:19:45,040
start the market. 
And so that's things like de 

361
00:19:45,040 --> 00:19:48,640
risking finance, maybe blended 
finance vehicles and technical 

362
00:19:48,640 --> 00:19:52,480
assistance so that we can help 
plug the gap between the upfront

363
00:19:52,480 --> 00:19:56,200
investment and the sale of the 
credits later on, which we know 

364
00:19:56,200 --> 00:19:59,080
has been, you know, one of the 
the challenges in BNG, for 

365
00:19:59,080 --> 00:20:00,840
instance, in trying to get the 
market off the ground. 

366
00:20:01,480 --> 00:20:05,240
So overall, we're moving towards
development of this credible, 

367
00:20:05,240 --> 00:20:08,080
consistent framework. 
And we look forward to kind of 

368
00:20:08,080 --> 00:20:12,560
contributing to that process. 
So just to clarify, Thomas, BNG 

369
00:20:12,560 --> 00:20:14,800
is obviously a regulated 
compliance market. 

370
00:20:15,000 --> 00:20:18,640
What the EU road map seems to 
lay out is a framework for the 

371
00:20:18,640 --> 00:20:21,360
development of a voluntary 
market. 

372
00:20:21,360 --> 00:20:24,840
However, is that how you see it?
Yes, that's right. 

373
00:20:24,840 --> 00:20:28,360
So BNG is a regulated compliance
market in the sense that you 

374
00:20:28,360 --> 00:20:31,240
have to achieve 10% uplift. 
If you can't do that on site, 

375
00:20:31,240 --> 00:20:32,720
you'll have to buy a credit, 
right? 

376
00:20:33,040 --> 00:20:36,400
Whereas what the EU road map is 
suggesting is a regulated 

377
00:20:36,520 --> 00:20:39,360
voluntary market. 
There doesn't seem to be a 

378
00:20:39,360 --> 00:20:42,680
compliance mechanism in there 
yet, but that's not to say that 

379
00:20:42,680 --> 00:20:45,560
it might not be developed or 
that member states might not 

380
00:20:45,560 --> 00:20:48,520
choose to use that EU wide 
framework and then create 

381
00:20:48,520 --> 00:20:51,440
compliance mechanisms for their 
own country. 

382
00:20:51,800 --> 00:20:54,560
So it remains to be seen how it 
will actually pan out and. 

383
00:20:55,280 --> 00:20:58,200
When we say regulated voluntary 
market, we mean sort of 

384
00:20:58,200 --> 00:21:01,960
regulated at the level of what 
the methodologies need to be in 

385
00:21:01,960 --> 00:21:04,600
the standards, right? 
That's brilliant. 

386
00:21:06,080 --> 00:21:09,960
So Glenn's going to come on 
imminently and just before he 

387
00:21:09,960 --> 00:21:13,200
does, just so listeners 
understand the connection 

388
00:21:13,200 --> 00:21:15,440
between you and Glenn and why 
you're both here together, Could

389
00:21:15,440 --> 00:21:17,880
you just briefly tell us how 
you've been working with 

390
00:21:17,880 --> 00:21:20,400
Wendling Beck? 
Yeah, of course. 

391
00:21:20,400 --> 00:21:23,480
So the partnership with Wendling
Beck began before my time at 

392
00:21:23,480 --> 00:21:25,680
TNCI. 
Think it's at least 5 or 6 years

393
00:21:25,680 --> 00:21:28,000
actually. 
Well, TNC actually published a 

394
00:21:28,000 --> 00:21:31,200
paper on best practise for 
biodiversity net game even 

395
00:21:31,200 --> 00:21:34,240
before the regulations came out,
setting out what we thought a 

396
00:21:34,240 --> 00:21:37,560
good scheme would look like. 
And then we were connected with 

397
00:21:37,560 --> 00:21:41,760
Glenn who was really interested 
in what the modelling and the 

398
00:21:41,760 --> 00:21:44,680
business case for this might be.
And we, we struck up the 

399
00:21:44,680 --> 00:21:48,000
partnership and Glenn and the 
other land owners within the 

400
00:21:48,000 --> 00:21:49,640
Gwendolyn Bet scheme are 
fantastic. 

401
00:21:49,640 --> 00:21:51,920
They're, you know, really 
pioneering and it's really 

402
00:21:51,920 --> 00:21:53,560
exciting to see what's going on 
there. 

403
00:21:53,560 --> 00:21:57,400
I visited twice and I come away 
optimistic each time that these 

404
00:21:57,400 --> 00:22:01,440
schemes can work and can help us
to transition towards nature 

405
00:22:01,440 --> 00:22:04,480
restoration. 
So TNC has just been supporting 

406
00:22:04,480 --> 00:22:06,760
with some of the modelling work,
the business case. 

407
00:22:07,040 --> 00:22:10,000
And at this point now we're also
trying to kind of amplify the 

408
00:22:10,000 --> 00:22:13,320
messaging that's coming out of 
the work at Wendling Beck, both 

409
00:22:13,400 --> 00:22:16,560
here in England, but also within
the European Commission. 

410
00:22:16,560 --> 00:22:19,080
So Wendling Beck's one of the 
case studies that we often take 

411
00:22:19,400 --> 00:22:22,080
to our European stakeholders to 
make the case for each market. 

412
00:22:22,600 --> 00:22:23,920
Brilliant. 
Let's get him on. 

413
00:22:31,560 --> 00:22:33,600
Well, Glenn, thank you so much 
for joining us today. 

414
00:22:34,120 --> 00:22:36,320
It's lovely to have you here. 
Thanks Helen. 

415
00:22:36,320 --> 00:22:39,200
Thanks for having me on. 
And we've just been talking to 

416
00:22:39,200 --> 00:22:42,040
Thomas, who's sort of given us 
sort of the the bigger sort of 

417
00:22:42,040 --> 00:22:45,960
overview of where BNG sort of 
fits in, in terms of sort of 

418
00:22:45,960 --> 00:22:49,440
delivering for nature, 
especially within the context of

419
00:22:49,440 --> 00:22:52,240
Europe. 
But I wondered if you're going 

420
00:22:52,240 --> 00:22:56,240
to sort of give us the on the 
ground experience, if you could 

421
00:22:56,240 --> 00:23:00,120
just actually start by sharing 
with us what is Wendling Beck? 

422
00:23:00,760 --> 00:23:05,840
So we are a a landscape scale 
land use change project. 

423
00:23:05,880 --> 00:23:09,320
So the project is now just over 
5 years old. 

424
00:23:09,840 --> 00:23:12,680
We were kind of slightly ahead 
of the game in terms of looking 

425
00:23:12,720 --> 00:23:15,720
at biodiversity net gain. 
It was, it wasn't a policy when 

426
00:23:15,720 --> 00:23:20,480
we started and we've kind of 
collaborated with a number of of

427
00:23:20,560 --> 00:23:24,520
land owners, neighbours to 
create something bigger and 

428
00:23:24,520 --> 00:23:26,120
better than the sum of the 
parts. 

429
00:23:26,520 --> 00:23:30,200
We needed a bit of aggregation 
to be able to deliver the, the 

430
00:23:30,200 --> 00:23:32,800
type of project that we wanted 
to and at the scale that we 

431
00:23:32,800 --> 00:23:36,240
wanted to. 
Yeah, it's been a learning 

432
00:23:36,240 --> 00:23:39,880
curve, but we've, we've got 
there and we're now market 

433
00:23:39,880 --> 00:23:41,760
ready. 
We're we're sort of trading if 

434
00:23:41,760 --> 00:23:43,840
you like, and that's going quite
well. 

435
00:23:44,600 --> 00:23:46,720
Yeah, it's a, it's a couple of 
1000 acres. 

436
00:23:46,720 --> 00:23:50,080
So we're, we're, you know, 
broadly we've got sort of four 

437
00:23:50,080 --> 00:23:52,160
farms that are about 500 acres 
each. 

438
00:23:52,160 --> 00:23:55,080
So no huge land owners or 
anything like that. 

439
00:23:55,600 --> 00:23:59,840
And we're all on quite marginal 
land, very thin sandy soils. 

440
00:24:00,200 --> 00:24:01,800
We had to do something 
different. 

441
00:24:02,480 --> 00:24:06,520
We, we, our businesses were not 
resilient in the form that they 

442
00:24:06,520 --> 00:24:09,160
were from a farming perspective.
We weren't big enough. 

443
00:24:09,160 --> 00:24:11,960
The soil types were not 
resilient enough. 

444
00:24:11,960 --> 00:24:15,040
We were particularly exposed to 
drought and we're going through 

445
00:24:15,040 --> 00:24:17,680
a a fairly monumental drought at
the moment. 

446
00:24:17,720 --> 00:24:20,440
And, and everybody keeps saying 
to the each other that we're 

447
00:24:20,440 --> 00:24:21,840
glad we haven't got any crops in
the ground. 

448
00:24:21,840 --> 00:24:24,160
It's quite hard actually 
delivering habitat in these 

449
00:24:24,160 --> 00:24:27,880
conditions, but they're a lot 
more forgiving than than trying 

450
00:24:27,880 --> 00:24:31,040
to grow barley or wheat or or 
something like that on on this 

451
00:24:31,040 --> 00:24:34,680
type of land. 
So yeah, it's been a lot of 

452
00:24:34,680 --> 00:24:36,600
work, but we're pleased that we 
did it. 

453
00:24:37,320 --> 00:24:39,040
Oh gosh, it has been a lot of 
work. 

454
00:24:39,040 --> 00:24:41,560
And so I wonder if you can sort 
of tell us, did you say you 

455
00:24:41,560 --> 00:24:45,640
started about 4-5 years ago, was
it now and was that sort of in 

456
00:24:45,640 --> 00:24:47,480
the pilot testing phase for 
government? 

457
00:24:47,480 --> 00:24:48,840
What was? 
What did that look like? 

458
00:24:49,080 --> 00:24:51,680
We did a number of things. 
We're actually one of the round 

459
00:24:51,680 --> 00:24:54,040
one nerf projects. 
So the nerf is the Natural 

460
00:24:54,040 --> 00:24:58,480
Environment Investment Readiness
Fund, which is GFI quite closely

461
00:24:58,480 --> 00:25:02,200
aligned to. 
We managed to secure some 

462
00:25:02,200 --> 00:25:05,960
funding as as part of that, that
round one, which was trying to 

463
00:25:06,200 --> 00:25:10,080
put Seed Rattle into projects to
help with feasibility and get 

464
00:25:10,080 --> 00:25:12,960
them off the ground. 
So that really gave us a leg up 

465
00:25:12,960 --> 00:25:17,160
and helped us to start thinking 
about how it would all work and 

466
00:25:17,160 --> 00:25:18,680
the feasibility and what have 
you. 

467
00:25:19,800 --> 00:25:25,960
And then we were also became a 
Defra BNG pilot, which was again

468
00:25:26,120 --> 00:25:30,960
hugely helpful to us. 
It enabled us to do some of the 

469
00:25:30,960 --> 00:25:35,120
baselining and create some of 
the early habitats off the off 

470
00:25:35,120 --> 00:25:37,560
the back of that through, you 
know, kind of early 

471
00:25:37,560 --> 00:25:39,040
interventions and that sort of 
thing. 

472
00:25:39,040 --> 00:25:43,040
So, you know, it's, it's been 
really quite a positive 

473
00:25:43,040 --> 00:25:47,440
experience I would say overall. 
But I think it shows the point 

474
00:25:47,440 --> 00:25:50,320
that this isn't something you 
can just go out and do. 

475
00:25:50,320 --> 00:25:54,720
There is quite a lot of upfront 
funding, grant funding that 

476
00:25:54,720 --> 00:25:57,480
needs to be put in to help land 
managers and farmers. 

477
00:25:57,760 --> 00:26:02,120
Huge, huge amount, way beyond 
what we ever anticipated to be 

478
00:26:02,120 --> 00:26:04,120
honest. 
So the, the nerf funding was 

479
00:26:04,120 --> 00:26:07,720
100,000 lbs and at the time we 
thought that was, you know, a 

480
00:26:07,720 --> 00:26:10,600
huge amount of money that would 
do everything that we needed to 

481
00:26:10,600 --> 00:26:12,640
do. 
And I think at the moment we're 

482
00:26:12,640 --> 00:26:15,520
up at about two or two and a 
half, £1,000,000 worth of 

483
00:26:15,520 --> 00:26:18,720
investment. 
So it's and obviously that 

484
00:26:18,720 --> 00:26:22,280
figure now includes lots of 
habitat creation and capital 

485
00:26:22,280 --> 00:26:25,440
works that have happened since. 
So gosh, that's a huge upfront 

486
00:26:25,440 --> 00:26:28,560
investment. 
So sort of talk to us about, I 

487
00:26:28,560 --> 00:26:30,560
mean, obviously you don't have 
to tell us how much money you're

488
00:26:30,560 --> 00:26:34,360
making out BNG, but sort of tell
us how the economic stack up 

489
00:26:34,360 --> 00:26:36,600
with the compliance model like 
BNG. 

490
00:26:37,120 --> 00:26:41,240
You know, we've got about 3000 
BNG units that we will deliver. 

491
00:26:41,800 --> 00:26:44,480
You never have a completely 
accurate figure because there's 

492
00:26:44,480 --> 00:26:47,720
these temporal multipliers 
within the BNG metric that mean 

493
00:26:47,720 --> 00:26:51,560
that depending on when you sell.
So if you create habitat in 

494
00:26:51,560 --> 00:26:55,400
advance, the metric deems that 
there's less risk of failure and

495
00:26:55,400 --> 00:26:59,120
it rewards you by giving you 
more units if you sell at a 

496
00:26:59,120 --> 00:27:01,000
later date. 
But obviously you don't know 

497
00:27:01,000 --> 00:27:03,240
when you're going to sell, so 
it's quite difficult to nail 

498
00:27:03,240 --> 00:27:05,520
down exactly how many units 
you're going to deliver. 

499
00:27:05,520 --> 00:27:09,280
Will be somewhere around 3000. 
When we first started the 

500
00:27:09,280 --> 00:27:13,840
project, the early F Tech 
analysis had had BNG units of a 

501
00:27:13,840 --> 00:27:16,680
kind of an average value of 
about £11,000 a unit. 

502
00:27:17,480 --> 00:27:20,280
By the time we got close to 
being market ready, they were at

503
00:27:20,280 --> 00:27:23,560
about 35,000 a unit. 
So you can, you can do the maths

504
00:27:23,560 --> 00:27:25,040
on that. 
It's a, it's a big chunk of 

505
00:27:25,040 --> 00:27:29,240
money, but it is for 30 years 
and it does include all of your 

506
00:27:29,240 --> 00:27:31,760
capital works and it also 
includes inflation and the 

507
00:27:31,760 --> 00:27:33,920
inflationary effect is huge on 
this. 

508
00:27:33,920 --> 00:27:38,520
So from a commercial point of 
view, we have a high kind of 125

509
00:27:38,520 --> 00:27:40,800
year business model I think that
sits behind this. 

510
00:27:40,800 --> 00:27:45,040
This is multi generational 
successional planning and 

511
00:27:45,840 --> 00:27:48,480
although those those numbers are
quite big actually if you take 

512
00:27:48,480 --> 00:27:51,160
the the revenue that's coming 
off the the previous farm 

513
00:27:51,160 --> 00:27:54,480
systems over 30 year and apply 
inflation and what have you, you

514
00:27:54,480 --> 00:27:56,280
actually get to a similar kind 
of number. 

515
00:27:56,880 --> 00:27:59,080
So it does need to be around 
those figures. 

516
00:27:59,080 --> 00:28:02,360
What we have seen as we're 
getting to market now and the 

517
00:28:02,400 --> 00:28:05,920
and supply and demand are 
becoming a bit more equalised is

518
00:28:05,920 --> 00:28:08,440
that actually that price is 
dropping quite quickly as well. 

519
00:28:08,440 --> 00:28:11,640
So I think at the moment with 
the average price, we've gone 

520
00:28:11,640 --> 00:28:15,320
from sort of 35,000 a unit down 
to about 25,000 a unit on 

521
00:28:15,320 --> 00:28:17,880
average. 
But there's quite big variations

522
00:28:17,880 --> 00:28:21,400
between habitat types as well. 
So you might have a very 

523
00:28:21,400 --> 00:28:25,000
difficult to create habitat such
as a watercross unit. 

524
00:28:25,000 --> 00:28:26,720
That's probably quite a lot of 
capital works. 

525
00:28:26,720 --> 00:28:29,840
They might be up sort of a 
hundred, £150,000 a unit. 

526
00:28:30,360 --> 00:28:33,320
You then might have a simple 
grassland, neutral grassland or 

527
00:28:33,320 --> 00:28:36,320
something like that, that you 
could be down sub 20,000 sort of

528
00:28:36,320 --> 00:28:38,480
between sort of 18 and 20,000 a 
unit. 

529
00:28:38,480 --> 00:28:42,000
So there's, you know, the market
is becoming more sophisticated 

530
00:28:42,000 --> 00:28:45,960
as it evolves and people are 
starting to understand what's 

531
00:28:45,960 --> 00:28:48,960
required in actually delivering 
these different habitat types. 

532
00:28:49,320 --> 00:28:51,440
You know, and, and we might not 
sell all the units, we don't 

533
00:28:51,440 --> 00:28:54,160
know exactly how supply and 
demand is going to work. 

534
00:28:54,160 --> 00:28:57,200
So the the business model is 
actually predicated on that, not

535
00:28:57,200 --> 00:29:01,840
selling all of the units that as
long as we sell, you know, a 

536
00:29:01,880 --> 00:29:06,480
proportion or a decent 
proportion 50 to 70%, then we 

537
00:29:06,480 --> 00:29:09,400
should be OK. 
There are a number of variables 

538
00:29:09,400 --> 00:29:12,280
in there that we just not going 
to know until we get to that 

539
00:29:12,280 --> 00:29:15,120
point in time and that's part of
the risk of doing it. 

540
00:29:15,600 --> 00:29:20,280
But we feel that the economics 
stack up better than the 

541
00:29:20,280 --> 00:29:24,120
opportunity cost of farming this
land, particularly when you 

542
00:29:24,120 --> 00:29:26,800
layer in the fact that we're on 
poor quality land. 

543
00:29:27,520 --> 00:29:30,400
You know, we're, we've got the 
vagaries of the weather and, you

544
00:29:30,400 --> 00:29:33,440
know, and the, and actually the 
farming policy environment isn't

545
00:29:33,440 --> 00:29:37,080
terribly stable either. 
So yeah, we're, we're very happy

546
00:29:37,080 --> 00:29:39,760
with what we've done and we're 
really comfortable that we've, 

547
00:29:39,800 --> 00:29:43,480
we've made the right decisions. 
But that's now kind of semi in 

548
00:29:43,480 --> 00:29:47,480
hindsight, whereas at the time 
we were making those decisions 

549
00:29:47,480 --> 00:29:51,280
that that wasn't quite so easy 
because we just had no idea 

550
00:29:51,280 --> 00:29:52,600
whether this was going to work 
or not. 

551
00:29:53,080 --> 00:29:54,440
Well, I bet. 
And then with those large 

552
00:29:54,440 --> 00:29:58,080
upfront costs have been quite as
scary few years I would have 

553
00:29:58,080 --> 00:30:00,640
thought. 
Yeah, we've, we've mitigated it 

554
00:30:00,640 --> 00:30:04,720
to some extent by stacking. 
So we have, we've Norfolk is 

555
00:30:04,800 --> 00:30:07,040
generally in a neutral 
neutrality area and Wendling 

556
00:30:07,040 --> 00:30:09,320
Beck is actually delivering 
nutrient credits as well. 

557
00:30:09,320 --> 00:30:15,200
So we have managed to sell some 
nutrient credits quite early, 

558
00:30:15,200 --> 00:30:18,160
which has given us some of the 
working capital that we need to 

559
00:30:18,160 --> 00:30:21,920
then deliver the habitat. 
So the way we look at it from a 

560
00:30:22,000 --> 00:30:25,400
kind of a stacking and an 
additionality perspective is 

561
00:30:25,400 --> 00:30:29,320
that the nutrients basically pay
for you to take the land out of 

562
00:30:29,320 --> 00:30:31,320
production. 
So they're, they're, they're 

563
00:30:31,600 --> 00:30:34,160
making up for that loss of 
income through that opportunity 

564
00:30:34,160 --> 00:30:38,600
cost of farming it. 
The BNG then pays for delivering

565
00:30:38,600 --> 00:30:41,680
and managing those high 
distinctiveness habitats over 

566
00:30:41,680 --> 00:30:44,400
the long term. 
So that's that's worked quite 

567
00:30:44,400 --> 00:30:47,200
well for us. 
And should we, I mean, while 

568
00:30:47,200 --> 00:30:50,080
we're on the topic of stacking 
and it's the topic we love to 

569
00:30:50,080 --> 00:30:54,960
talk about in the UK in so in 
England, is it worth explaining?

570
00:30:54,960 --> 00:30:57,320
I remember about to explain it, 
but you will explain it better 

571
00:30:57,320 --> 00:31:00,760
that you cannot stack with 
carbon because of the lack of 

572
00:31:00,760 --> 00:31:02,920
additionality. 
I mean to what extent do you 

573
00:31:02,920 --> 00:31:06,920
think that might change over 
time or is is should be a hard 

574
00:31:06,920 --> 00:31:09,440
line? 
There's lots of opinions on this

575
00:31:09,440 --> 00:31:11,120
and it's quite a divisive 
subject, sorry. 

576
00:31:12,440 --> 00:31:14,960
To bring it up. 
Yeah, my personal view is that 

577
00:31:14,960 --> 00:31:17,680
we shouldn't have these stacking
rules that you, they, they don't

578
00:31:17,880 --> 00:31:23,120
exist in any other walk of life.
So if I, if I'm a farmer growing

579
00:31:23,120 --> 00:31:26,960
wheat, I can sell my my wheat 
forward on a contract to a 

580
00:31:27,200 --> 00:31:30,240
buyer. 
That buyer doesn't asked me what

581
00:31:30,240 --> 00:31:33,120
I'm doing with the straw. 
And that's how free market 

582
00:31:33,320 --> 00:31:37,120
economics work is that, you 
know, the markets effectively 

583
00:31:37,120 --> 00:31:41,320
look after the the stacking and 
additionality through those 

584
00:31:41,320 --> 00:31:43,400
market economics. 
But the the buyers are well 

585
00:31:43,400 --> 00:31:46,360
aware that you might already 
been paying for something and 

586
00:31:46,360 --> 00:31:50,400
that affects the value of 1 or 
other of the ecosystem services.

587
00:31:50,920 --> 00:31:54,280
It's helpful to us obviously, 
that we can stack biodiversity 

588
00:31:54,280 --> 00:31:56,600
and nutrients. 
So that is allowed within the 

589
00:31:56,600 --> 00:31:59,320
current stacking rules. 
You know, that's been a huge 

590
00:31:59,320 --> 00:32:02,080
lifeline for us. 
We're not planning on selling 

591
00:32:02,080 --> 00:32:04,840
carbon. 
We don't necessarily think that 

592
00:32:04,840 --> 00:32:07,000
we need to sell carbon. 
We are measuring all of the 

593
00:32:07,000 --> 00:32:08,760
carbon uplift within the 
project. 

594
00:32:08,760 --> 00:32:12,240
So we're working with UKCH and 
the University of East Anglia to

595
00:32:12,240 --> 00:32:16,080
measure above and below ground 
carbon and actually to economy 

596
00:32:16,080 --> 00:32:17,560
as as well. 
They're helping with that 

597
00:32:17,560 --> 00:32:20,680
process and that's not 
necessarily with a view to 

598
00:32:20,680 --> 00:32:24,840
trading that in the future. 
Although if the BNG market 

599
00:32:24,840 --> 00:32:27,640
doesn't materialise to the 
extent that we would like it to,

600
00:32:27,640 --> 00:32:29,680
then it might, we might need to 
do that. 

601
00:32:29,680 --> 00:32:32,640
So it's a, it's kind of a safety
net for us that we could dip 

602
00:32:32,640 --> 00:32:34,880
into the carbon market. 
We wouldn't, we wouldn't be 

603
00:32:34,880 --> 00:32:37,200
double dipping. 
We would, you know, we would be 

604
00:32:37,200 --> 00:32:39,160
using it as an alternative 
revenue source. 

605
00:32:39,160 --> 00:32:41,600
But to be able to do that, you 
have to have a baseline and 

606
00:32:41,600 --> 00:32:43,560
start the project before you 
start the transition. 

607
00:32:43,560 --> 00:32:45,400
And you need to be able to 
measure that to a post 

608
00:32:45,400 --> 00:32:49,760
intervention state if you like. 
I think when you get to much 

609
00:32:49,760 --> 00:32:52,040
bigger projects, and I'm 
thinking particularly of the 

610
00:32:52,040 --> 00:32:55,480
landscape recovery projects, 
stacking really becomes an issue

611
00:32:55,560 --> 00:32:59,840
because those projects are far 
more complicated. 

612
00:32:59,840 --> 00:33:02,120
We're 4 land owners. 
Some of these projects are 50 or

613
00:33:02,120 --> 00:33:05,080
60 land owners. 
We're a couple of 1000 acres. 

614
00:33:05,080 --> 00:33:08,280
Some of these big projects are, 
you know, 10s or even hundreds 

615
00:33:08,280 --> 00:33:11,680
of thousands of acres. 
You can't deliver that scale of 

616
00:33:11,680 --> 00:33:14,080
project through compliance 
markets. 

617
00:33:14,080 --> 00:33:15,720
There just isn't the demand for 
it. 

618
00:33:15,720 --> 00:33:18,800
And you're going to have a blend
of different ecosystem services,

619
00:33:19,120 --> 00:33:21,760
particularly carbon. 
So carbon works particularly 

620
00:33:21,760 --> 00:33:23,240
well for landscape recovery 
projects. 

621
00:33:23,680 --> 00:33:26,120
But actually there are a number 
of those projects that are going

622
00:33:26,120 --> 00:33:30,640
to be Hanford by not being able 
to stack biodiversity alongside 

623
00:33:30,880 --> 00:33:32,920
carbon. 
And I do think that's something 

624
00:33:32,920 --> 00:33:36,760
that, you know, it's not about 
double counting, it's about 

625
00:33:36,760 --> 00:33:39,920
actually making projects viable 
by getting them the finance that

626
00:33:39,920 --> 00:33:42,200
they need. 
Yeah, yeah, totally. 

627
00:33:42,480 --> 00:33:45,200
Well, thank you for taking that 
question on stacking. 

628
00:33:45,440 --> 00:33:47,200
And for those listening, if 
you're not familiar, landscape 

629
00:33:47,200 --> 00:33:52,680
recovery is actually part of our
new farming subsidy regime, 

630
00:33:52,680 --> 00:33:55,640
would we call it? 
That's for, as it sounds, 

631
00:33:55,800 --> 00:34:00,640
landscape scale projects with 
multiple farmers and land 

632
00:34:00,640 --> 00:34:04,400
managers coming together and 
they typically have to produce a

633
00:34:04,400 --> 00:34:07,200
model that attracts both private
sector. 

634
00:34:07,200 --> 00:34:09,320
And then there'll be some 
element where the government 

635
00:34:09,320 --> 00:34:13,040
will complement that through the
subsidy or public funding if I 

636
00:34:13,040 --> 00:34:14,239
have. 
So maybe let's talk about 

637
00:34:14,239 --> 00:34:16,360
upfront finance because 
obviously there is a, there's a 

638
00:34:16,360 --> 00:34:20,159
marketplace between, you know, a
buyer of units and you're 

639
00:34:20,159 --> 00:34:22,520
selling the units. 
But there is that point where 

640
00:34:22,520 --> 00:34:26,679
you might need the upfront 
investment before you find the 

641
00:34:27,040 --> 00:34:29,520
the buyer. 
Does that exist at the moment? 

642
00:34:29,520 --> 00:34:31,520
I mean, how do we, how does that
look in England? 

643
00:34:31,920 --> 00:34:35,400
It's a bit of a hodgepodge. 
So depends on kind of right 

644
00:34:36,280 --> 00:34:38,040
time, right place to some 
extent. 

645
00:34:38,040 --> 00:34:40,080
So there are, there are people 
out there that will put C 

646
00:34:40,080 --> 00:34:44,040
capital into projects if they 
are either answering a 

647
00:34:44,040 --> 00:34:48,760
particular requirement or you 
know, they, they just happen to 

648
00:34:48,760 --> 00:34:52,360
be in a, in a, in a good 
location or, or have an 

649
00:34:52,360 --> 00:34:54,840
ecosystem service benefit that 
somebody really wants. 

650
00:34:55,520 --> 00:34:58,600
Other more kind of speculative 
projects can struggle to get 

651
00:34:58,600 --> 00:35:02,240
that early seed capital. 
So again, we, we talked about 

652
00:35:02,240 --> 00:35:04,760
landscape recovery. 
That's a that's a great way of 

653
00:35:05,200 --> 00:35:09,200
bringing some money for 
feasibility to get the projects 

654
00:35:09,200 --> 00:35:12,440
off the ground for, for more 
kind of stand alone single 

655
00:35:12,440 --> 00:35:15,560
estate compliance market 
solutions. 

656
00:35:16,080 --> 00:35:20,080
That becomes more difficult to, 
to get to bring in the the money

657
00:35:20,080 --> 00:35:24,080
to do the feasibility. 
So baselining, you know, soil 

658
00:35:24,080 --> 00:35:28,200
testing, design, legal 
structures, all of that sort of 

659
00:35:28,200 --> 00:35:30,040
stuff costs quite a lot of 
money. 

660
00:35:30,600 --> 00:35:33,920
So it's either at that point up 
to the landowner to to try and 

661
00:35:33,920 --> 00:35:38,680
finance them that themselves or 
try and take on some debt to be 

662
00:35:38,680 --> 00:35:41,320
able to do that. 
So in some ways it creates an 

663
00:35:41,320 --> 00:35:43,800
opportunity for debt finance 
within there maybe through the 

664
00:35:43,800 --> 00:35:48,480
banks, but I think the banks 
have been relatively slow on the

665
00:35:48,480 --> 00:35:52,240
uptake with compliance markets 
and and nature finance in 

666
00:35:52,240 --> 00:35:54,560
general. 
And we're seeing that on the, 

667
00:35:54,560 --> 00:35:58,000
the flip side of that coin is 
that if you have a charge on a 

668
00:35:58,000 --> 00:36:01,960
piece of land that you need the 
bank's permission to enter into 

669
00:36:01,960 --> 00:36:06,040
biodiversity net gain, the bank 
is unlikely at the moment to, to

670
00:36:06,040 --> 00:36:08,080
allow you to do that because 
they don't know what's going to 

671
00:36:08,080 --> 00:36:10,080
happen to the long term land 
values. 

672
00:36:10,080 --> 00:36:13,880
And the charges are all based on
the, on what happens with those 

673
00:36:13,880 --> 00:36:16,400
long term land values. 
And they know from a, if it's in

674
00:36:16,400 --> 00:36:19,960
farming, they can, they can 
predict that with new markets 

675
00:36:19,960 --> 00:36:22,480
like biodiversity net gain, it's
unpredictable when their 

676
00:36:22,480 --> 00:36:27,200
computer basically says no. 
And you know, they are working 

677
00:36:27,200 --> 00:36:29,800
through that at the moment. 
But that has caused a problem. 

678
00:36:30,160 --> 00:36:34,400
Similarly, the, the kind of the 
risk profile of, of investing in

679
00:36:34,400 --> 00:36:36,840
BNGII would imagine is quite 
similar. 

680
00:36:36,840 --> 00:36:40,160
I mean, if you go and want to 
borrow some money from a bank 

681
00:36:40,160 --> 00:36:42,400
and you've got some assets that 
you can underpin that with, 

682
00:36:42,400 --> 00:36:43,840
they're always going to lend you
the money. 

683
00:36:43,840 --> 00:36:46,680
But at the moment, all of the 
risk is on the landowner. 

684
00:36:46,680 --> 00:36:49,800
And I think as the, as the 
projects mature and the, and the

685
00:36:49,800 --> 00:36:53,080
market matures, the risk gets 
mitigated. 

686
00:36:53,080 --> 00:36:57,240
So we need some of these early 
projects out there to prove the 

687
00:36:57,240 --> 00:37:00,720
model and and prove that the 
market works and then everybody 

688
00:37:00,720 --> 00:37:02,840
becomes a little bit more 
relaxed about it. 

689
00:37:03,360 --> 00:37:08,680
Yeah, yeah. 
So slightly changing topics, is 

690
00:37:08,680 --> 00:37:13,560
there any sort of argument for 
social impact from biodiversity 

691
00:37:13,560 --> 00:37:15,200
net gain? 
I know you've done quite a lot 

692
00:37:15,200 --> 00:37:17,840
of work with communities, but if
you could talk us through that, 

693
00:37:17,840 --> 00:37:20,240
that'd be great. 
You know, I think on all of 

694
00:37:20,240 --> 00:37:24,320
these, these nature recovery 
projects, the local communities 

695
00:37:24,320 --> 00:37:27,400
and that wider society benefit 
is hugely important. 

696
00:37:28,520 --> 00:37:30,960
I don't think there's any 
particular framework that 

697
00:37:31,240 --> 00:37:33,920
predicates that at the moment 
that that needs to be part of 

698
00:37:33,920 --> 00:37:37,800
the design or the the execution.
I think it's more of a best 

699
00:37:37,800 --> 00:37:40,640
practise approach at the moment 
that if you're doing something 

700
00:37:40,640 --> 00:37:45,360
good for nature, you should look
at the why, the bigger picture 

701
00:37:45,440 --> 00:37:49,280
and start to integrate people 
into that mix as well. 

702
00:37:49,280 --> 00:37:51,120
So we're very focused on kind of
habitat. 

703
00:37:51,120 --> 00:37:55,200
We use habitat as a proxy for 
species, but often the kind of 

704
00:37:55,200 --> 00:37:58,120
the people living close to those
sites or visiting those sites 

705
00:37:58,120 --> 00:38:00,400
can be neglected from that 
design. 

706
00:38:00,400 --> 00:38:03,960
So that's something that we've 
been quite conscious to try and 

707
00:38:04,040 --> 00:38:06,600
make sure that we we encapsulate
within the project. 

708
00:38:06,600 --> 00:38:09,000
So we're doing as much as we can
at the moment. 

709
00:38:09,000 --> 00:38:11,960
So we are, we're engaging with, 
with local community groups, 

710
00:38:11,960 --> 00:38:15,920
volunteers, we've put in a cycle
path to kind of connect the 

711
00:38:15,920 --> 00:38:19,520
local town centre to, to, for a 
couple of the villages. 

712
00:38:20,160 --> 00:38:23,720
We've got people counters on the
footpath network and the, and 

713
00:38:23,720 --> 00:38:26,920
the cycle way to understand how 
it's being used and how those 

714
00:38:26,920 --> 00:38:29,920
numbers change over time. 
You know, tracking people coming

715
00:38:29,920 --> 00:38:32,400
into the project, whether 
they're walking, running, 

716
00:38:32,400 --> 00:38:35,240
cycling, you know, we can 
because that's all part of our 

717
00:38:35,240 --> 00:38:38,600
natural capital account. 
And we need to understand what 

718
00:38:38,600 --> 00:38:41,040
the value is to wider society as
well. 

719
00:38:41,080 --> 00:38:46,320
And I think because we don't 
100% understand how the finance 

720
00:38:46,320 --> 00:38:48,280
of these projects is going to 
work at the moment. 

721
00:38:48,280 --> 00:38:50,880
So we have a we have a model 
that we think is going to work 

722
00:38:50,880 --> 00:38:54,120
through biodiversity net gain 
and selling environmental 

723
00:38:54,120 --> 00:38:56,240
credits. 
But if those markets change or 

724
00:38:56,240 --> 00:38:58,880
governments change and the 
policy goes or whatever it might

725
00:38:58,880 --> 00:39:04,440
be, we need to find a way to 
justify back to government, you 

726
00:39:04,440 --> 00:39:07,400
know, public money for public 
goods at that point. 

727
00:39:07,400 --> 00:39:09,640
So if we need to bring in 
subsidies in the future, for 

728
00:39:09,640 --> 00:39:13,360
example, because you know, the 
compliance markets go and then 

729
00:39:13,360 --> 00:39:16,040
we're going to need that data to
be able to say, look, this is 

730
00:39:16,760 --> 00:39:18,360
within our natural capital 
account. 

731
00:39:18,360 --> 00:39:22,880
This is our impact on health and
well-being or whatever it might 

732
00:39:22,880 --> 00:39:25,200
be. 
So I think they're all really 

733
00:39:25,200 --> 00:39:27,960
important, but I think there's 
just a general kind of feel good

734
00:39:27,960 --> 00:39:30,480
factor as well that you create 
something that you're proud of 

735
00:39:30,480 --> 00:39:34,280
and a space for nature and you 
you want to be able to invite 

736
00:39:34,280 --> 00:39:37,160
people in and, and kind of 
integrate with that and and 

737
00:39:37,160 --> 00:39:39,040
connect with that as much as 
possible. 

738
00:39:39,040 --> 00:39:42,640
There is always a balance 
between high distinctiveness 

739
00:39:42,640 --> 00:39:45,560
habitat, species, recovery and 
people because they're not 

740
00:39:45,560 --> 00:39:48,720
natural bedfellows and you tend 
to, you know, you get a lot of 

741
00:39:48,720 --> 00:39:50,440
recreational disturbance and 
things like that. 

742
00:39:50,440 --> 00:39:52,440
So you do need to think about it
within the design. 

743
00:39:52,960 --> 00:39:56,440
But we've been quite careful to 
keep the the really high 

744
00:39:56,440 --> 00:39:59,200
distinctiveness areas separate 
from where we're encouraging 

745
00:39:59,200 --> 00:40:01,880
people in. 
And this is a big question to 

746
00:40:01,880 --> 00:40:05,160
wrap up here with you, Glenn. 
But given over the years you've 

747
00:40:05,160 --> 00:40:08,320
had so many visits from 
government officials across the 

748
00:40:08,320 --> 00:40:13,600
EU seeking to understand BNG, 
what's your sense on whether BNG

749
00:40:13,600 --> 00:40:17,600
is something that should and 
could be applied across Europe? 

750
00:40:17,880 --> 00:40:19,920
You know, we're obviously 
testing this on a kind of a 

751
00:40:20,280 --> 00:40:25,000
micro scale in some ways in, in 
England and we can see the 

752
00:40:25,000 --> 00:40:28,600
potential for this as a, as a 
marketplace and as an 

753
00:40:28,600 --> 00:40:32,160
opportunity to bring private 
finance into nature recovery 

754
00:40:32,160 --> 00:40:36,640
and, and meet many of the 
government's metrics along the 

755
00:40:36,640 --> 00:40:38,320
way. 
So it's a, it really is a win 

756
00:40:38,320 --> 00:40:40,200
win economically and 
environmentally. 

757
00:40:40,200 --> 00:40:43,960
It's a, it's a win win. 
Once you, you kind of amplify 

758
00:40:43,960 --> 00:40:47,760
that to, to the scale of, of 
Europe or, or other kind of 

759
00:40:47,760 --> 00:40:52,200
jurisdictions, it becomes more 
complicated, but also it comes 

760
00:40:52,200 --> 00:40:56,960
with economies of scale and 
opportunities that, you know, 

761
00:40:56,960 --> 00:40:59,160
are quite mind blowing from a 
nature perspective. 

762
00:40:59,760 --> 00:41:03,600
And I, I think looking at 
something like BNG across Europe

763
00:41:03,600 --> 00:41:06,720
would just have so much 
potential, not just from a 

764
00:41:06,720 --> 00:41:10,240
finance point of view, but from 
a, from a nature delivery and a 

765
00:41:10,240 --> 00:41:12,720
people perspective. 
And, and actually that kind of 

766
00:41:12,720 --> 00:41:16,400
cap reform piece as well as to, 
as to how that works over the 

767
00:41:16,400 --> 00:41:18,760
long term. 
I think that the lessons that 

768
00:41:18,760 --> 00:41:21,880
we've learnt and are still 
learning on a daily basis from 

769
00:41:21,880 --> 00:41:26,440
BNG in England are definitely 
relevant and replicable across 

770
00:41:26,440 --> 00:41:30,120
those kind of geographies. 
And you know, in an ideal world,

771
00:41:30,120 --> 00:41:33,920
this would be a, it would be a 
global kind of roll out for, for

772
00:41:33,920 --> 00:41:36,760
biodiversity and climate as 
well, because the two are 

773
00:41:36,760 --> 00:41:38,960
intrinsically linked. 
They kind of go hand in glove. 

774
00:41:38,960 --> 00:41:43,320
And I think we can all see from 
just turning on the news that we

775
00:41:43,320 --> 00:41:46,960
are are facing some pretty 
significant challenges. 

776
00:41:46,960 --> 00:41:49,760
And, and no matter how much 
governments bury their head in 

777
00:41:49,760 --> 00:41:54,040
the sand or because it's not 
convenient, it's coming. 

778
00:41:54,080 --> 00:41:56,520
And sooner or later the penny 
will drop. 

779
00:41:56,520 --> 00:41:58,280
But we need to be able to do 
something about it. 

780
00:41:58,640 --> 00:42:01,080
And as you say, compliance 
markets are doing that. 

781
00:42:01,680 --> 00:42:04,320
And I also mentioned earlier 
that Vanessa Garcia, when she 

782
00:42:04,320 --> 00:42:07,280
was on a couple of weeks back 
was sharing how they are being 

783
00:42:07,280 --> 00:42:10,080
adopted across Latin America and
even in, you know, some parts of

784
00:42:10,080 --> 00:42:13,760
Africa and Southeast Asia. 
So it does feel like the EU is a

785
00:42:13,800 --> 00:42:15,960
little behind, if I can say 
that. 

786
00:42:16,560 --> 00:42:18,800
But thank you, Glenn. 
It's really great to have this 

787
00:42:18,880 --> 00:42:22,080
on the ground view and stay 
where you are as Thomas is going

788
00:42:22,080 --> 00:42:31,960
to come and rejoin us. 
So, Thomas, welcome back. 

789
00:42:32,480 --> 00:42:35,800
And I know you know well the 
experience Glenn has been having

790
00:42:35,800 --> 00:42:37,760
on the ground and what he's just
shared here. 

791
00:42:38,160 --> 00:42:40,760
But we thought for this final 10
minutes, it would be really 

792
00:42:40,760 --> 00:42:44,600
great to have you both here to 
share with us some of these sort

793
00:42:44,600 --> 00:42:46,920
of final thoughts. 
And the first is really about 

794
00:42:46,920 --> 00:42:49,000
the challenges. 
So Thomas, we talked about some 

795
00:42:49,000 --> 00:42:53,400
of the detail around small sites
exemptions and on site delivery,

796
00:42:53,880 --> 00:42:57,200
but where else do you see the 
biggest gaps between the policy 

797
00:42:57,200 --> 00:43:00,040
design and that implementation 
on the ground? 

798
00:43:00,280 --> 00:43:03,760
I think from a policy systems 
lens, I think the biggest gaps 

799
00:43:03,760 --> 00:43:06,280
that we're seeing is around 
regulation and monitoring, 

800
00:43:06,480 --> 00:43:08,960
especially monitoring. 
We don't really have a central 

801
00:43:08,960 --> 00:43:12,520
regulator tasked with like 
enforcing BNG or holding people 

802
00:43:12,520 --> 00:43:16,000
accountable to those agreements 
and penalising non compliance, 

803
00:43:16,000 --> 00:43:18,800
for instance. 
And so like, although we call it

804
00:43:18,800 --> 00:43:21,640
a regulated market, you know, 
it's not a very tightly 

805
00:43:21,640 --> 00:43:24,680
regulated market in in the 
actual practicalities. 

806
00:43:25,280 --> 00:43:27,960
And, you know, local planning 
authorities also just don't have

807
00:43:27,960 --> 00:43:32,600
the capacity to be assessing 
what's going on on the ground, 

808
00:43:33,000 --> 00:43:35,520
both in terms of the the 
applications to create habitat 

809
00:43:35,520 --> 00:43:38,080
banks or, you know, the 
continuous monitoring. 

810
00:43:38,080 --> 00:43:40,080
And so that does create 
blockages in the systems. 

811
00:43:40,400 --> 00:43:43,200
And you know, a report recently 
from IES found that, you know, 

812
00:43:43,200 --> 00:43:45,600
local planning authorities are 
being really overwhelmed by 

813
00:43:45,600 --> 00:43:50,120
section one O 6 demands that 
legal agreements to secure an 

814
00:43:50,120 --> 00:43:52,920
area for 30 years. 
And then I think finally and 

815
00:43:52,920 --> 00:43:56,400
this has come out of our work in
Norfolk, is that gap between 

816
00:43:56,400 --> 00:44:00,200
upfront invested investment 
needed to deliver and verify in 

817
00:44:00,200 --> 00:44:03,280
that gain and the returns from 
the sales of BNG credits. 

818
00:44:03,600 --> 00:44:07,680
And so you know what you can see
is farmers or lenders not being 

819
00:44:07,680 --> 00:44:10,120
willing to put up that 
significant upfront capital 

820
00:44:10,480 --> 00:44:13,040
where we're in what is still a 
fairly nascent market. 

821
00:44:13,560 --> 00:44:17,200
So I think more support around 
that kind of gap would be 

822
00:44:17,200 --> 00:44:19,800
helpful. 
Yeah, I think there's something 

823
00:44:19,800 --> 00:44:24,680
around policy stability as well 
and the, and the kind of the 

824
00:44:24,680 --> 00:44:28,680
market to supply and demand side
of things for BNG. 

825
00:44:28,680 --> 00:44:34,640
So to be able to invest in 
projects that are delivering 

826
00:44:34,640 --> 00:44:38,160
sort of long term biodiversity 
benefit, you have to make sure 

827
00:44:38,160 --> 00:44:41,560
that the goal posts are fixed in
place for a period of time. 

828
00:44:41,720 --> 00:44:45,360
And you know, we're looking at 
kind of long term 30 year 

829
00:44:45,360 --> 00:44:50,040
delivery and we have to be sure 
that the policy environment is 

830
00:44:50,040 --> 00:44:53,720
stable enough to be there at the
end of that process to be able 

831
00:44:53,720 --> 00:44:55,920
to invest in it. 
And I think we we haven't 

832
00:44:55,920 --> 00:44:58,920
necessarily had that today. 
You know, it's, it's been 

833
00:44:59,440 --> 00:45:02,520
slightly lumpy in terms of the 
roll out and now we're going 

834
00:45:02,520 --> 00:45:05,600
through a whole other 
consultation around small sites 

835
00:45:05,600 --> 00:45:09,680
and and things that will 
materially potentially affect 

836
00:45:09,680 --> 00:45:12,720
the market. 
So I think that's that's the 

837
00:45:12,720 --> 00:45:17,200
principle thing from a supply 
side perspective is that you 

838
00:45:17,200 --> 00:45:21,760
have to be sure that there's a 
market there to that is going to

839
00:45:21,760 --> 00:45:25,880
have the the required demand to,
to to make it investable. 

840
00:45:26,200 --> 00:45:29,720
So as we say, it's a, it's a 
great policy, we're glad it's 

841
00:45:29,720 --> 00:45:31,800
there. 
Obviously teething issues and 

842
00:45:31,800 --> 00:45:35,920
any new piece of regulation, but
definitely has the ability to 

843
00:45:35,920 --> 00:45:39,320
mobilise what we all hope is 
private sector capital, not just

844
00:45:39,320 --> 00:45:41,760
maybe from property developers, 
but you know, hopefully large 

845
00:45:41,760 --> 00:45:43,080
infrastructure providers as 
well. 

846
00:45:43,440 --> 00:45:45,840
So just kind of wrapping up last
couple of questions here. 

847
00:45:45,840 --> 00:45:49,720
I'm really keen to ask you both.
I mean, how do you sort of see, 

848
00:45:50,120 --> 00:45:52,680
you know, what would you like to
see in terms of the development 

849
00:45:52,680 --> 00:45:56,760
of biodiversity markets? 
And that can be whether we you 

850
00:45:56,760 --> 00:45:59,440
want to talk about these 
compliance markets, these units 

851
00:45:59,640 --> 00:46:02,240
or whether it's more on the 
voluntary side or as Thomas was 

852
00:46:02,240 --> 00:46:05,440
explaining to me earlier, the 
sort of in between, in between 

853
00:46:05,440 --> 00:46:07,800
regulatory voluntary. 
In terms of where where we're 

854
00:46:07,840 --> 00:46:10,680
going to see the biodiversity 
markets moving, I think we're on

855
00:46:10,680 --> 00:46:12,800
and up for this trajectory. 
It does depend who you ask. 

856
00:46:12,880 --> 00:46:15,000
I talked to some of my 
colleagues who've been around 

857
00:46:15,040 --> 00:46:17,880
longer than I have in this space
and they remembered we bought 

858
00:46:17,880 --> 00:46:20,840
back in the early 2000s and they
were like, there was loads of, 

859
00:46:21,280 --> 00:46:23,800
you know, energy and enthusiasm 
about their diversity markets 

860
00:46:23,800 --> 00:46:24,880
back then. 
And we didn't go anywhere. 

861
00:46:25,520 --> 00:46:28,960
And now we're having that kind 
of like curve of interest back. 

862
00:46:29,560 --> 00:46:33,040
But I do feel like we're in a 
different set of circumstances 

863
00:46:33,040 --> 00:46:36,160
as back then, you know, we have 
technologies and monitoring 

864
00:46:36,160 --> 00:46:38,600
capabilities for biodiversity 
that we just didn't have back 

865
00:46:38,600 --> 00:46:39,920
then. 
So the markets weren't 

866
00:46:39,920 --> 00:46:43,080
particularly high integrity and 
we couldn't measure biodiversity

867
00:46:43,080 --> 00:46:46,240
gains as well as we can now. 
And I also think we're in a 

868
00:46:46,240 --> 00:46:49,000
different space in terms of 
corporates and their 

869
00:46:49,080 --> 00:46:51,360
understanding of biodiversity. 
You know, as we were saying 

870
00:46:51,360 --> 00:46:55,280
before, we've got frameworks 
like TNFD and SBTN which are 

871
00:46:55,280 --> 00:46:57,960
really alerting the private 
sector to their risks and 

872
00:46:57,960 --> 00:46:59,880
dependencies. 
And I think there is going to be

873
00:46:59,880 --> 00:47:03,400
increased interest in these 
markets because of that. 

874
00:47:03,880 --> 00:47:06,680
And we have, you know, the EU 
road map announced, we've got 

875
00:47:06,680 --> 00:47:10,400
the IAPBS framework, we've got 
the work of the BCF and WEF. 

876
00:47:11,160 --> 00:47:14,200
And so I do hope we see this 
kind of proliferation of 

877
00:47:14,200 --> 00:47:17,920
national regulated schemes which
are there to unlock private 

878
00:47:17,920 --> 00:47:20,720
finance for nature while 
benefiting farmers, while 

879
00:47:20,720 --> 00:47:24,160
benefiting local communities and
helping, you know, close that 

880
00:47:24,160 --> 00:47:27,360
finance gap. 
What I worry about is that 

881
00:47:27,400 --> 00:47:31,280
potentially we start to see 
governments talk about private 

882
00:47:31,880 --> 00:47:35,840
markets as a way to make the 
excuse that we don't need as 

883
00:47:35,840 --> 00:47:37,680
much public funding going 
towards nature. 

884
00:47:38,600 --> 00:47:41,000
You know, when we're constantly 
hearing about, you know, the 

885
00:47:41,000 --> 00:47:44,080
worries around low growth and 
fiscal constraints, you can kind

886
00:47:44,080 --> 00:47:45,920
of see where that argument could
come from. 

887
00:47:45,920 --> 00:47:48,600
But I think we all need to be 
saying that it's public funding 

888
00:47:48,640 --> 00:47:50,360
plus private markets or the 
other way around. 

889
00:47:50,520 --> 00:47:53,200
You know, they they both need to
be in the game and both need to 

890
00:47:53,200 --> 00:47:56,880
be scaling up at the same time. 
And I think we're starting to 

891
00:47:56,880 --> 00:47:59,880
see that heading in the right 
direction with the messaging 

892
00:47:59,880 --> 00:48:03,960
that we're seeing from the EU 
framework and the IAPB. 

893
00:48:04,640 --> 00:48:07,400
Yeah. 
So just just to expand on on 

894
00:48:07,400 --> 00:48:12,480
Thomas's point there around the 
wider economy, we see the nature

895
00:48:12,480 --> 00:48:15,480
markets, it should be a triple 
win basically. 

896
00:48:15,480 --> 00:48:19,440
So you know you can grow a whole
green economy off the back of 

897
00:48:19,440 --> 00:48:24,400
compliance markets, which also 
enhance your underlying natural 

898
00:48:24,400 --> 00:48:26,840
capital. 
So to kind of deregulate that 

899
00:48:26,840 --> 00:48:31,880
process and destroy nature as, 
as, as part of development, you 

900
00:48:31,880 --> 00:48:33,880
know, it's just ludicrous 
because you're, you're 

901
00:48:33,880 --> 00:48:36,800
destroying your natural capital 
which sits on the, the 

902
00:48:36,800 --> 00:48:39,000
Treasury's balance sheet as 
opposed to enhance it. 

903
00:48:39,000 --> 00:48:41,720
So you should have a kind of a 
triple fiscal win as part of 

904
00:48:41,720 --> 00:48:45,840
these nature market framework. 
I think we're delighted with 

905
00:48:45,840 --> 00:48:47,840
where BNG has got to at the 
moment. 

906
00:48:47,840 --> 00:48:51,960
We're busy on wending back with,
we're doing a probably somewhere

907
00:48:51,960 --> 00:48:54,640
between sort of 20 and 40 quotes
a week at the moment. 

908
00:48:54,760 --> 00:49:00,360
So I think the market is is 
working better than we expected 

909
00:49:00,360 --> 00:49:05,600
it to at this point of its life 
cycle and for sure it needs kind

910
00:49:05,600 --> 00:49:07,760
of tweaking and evolving as we 
go forward. 

911
00:49:07,760 --> 00:49:12,240
But I would not underestimate 
the the importance of having 

912
00:49:12,240 --> 00:49:15,280
compliance market as the 
foundation for wider nature 

913
00:49:15,280 --> 00:49:17,800
markets. 
Without those compliance markets

914
00:49:17,800 --> 00:49:21,440
there, the the voluntary markets
start to become eroded. 

915
00:49:21,440 --> 00:49:24,840
We're pleased that there seems 
to be commitment to 

916
00:49:24,920 --> 00:49:29,760
infrastructure by 2020, May 2026
now I think so that's really 

917
00:49:29,760 --> 00:49:32,520
important for the BNG market to 
have infrastructure playing 

918
00:49:32,520 --> 00:49:36,680
apart and and being bound by the
same conditions and principles. 

919
00:49:36,680 --> 00:49:40,320
And, and some of the, the 
proposals for infrastructure in 

920
00:49:40,320 --> 00:49:42,640
the consultation, I think we're 
really positive as well. 

921
00:49:43,640 --> 00:49:47,400
But we've also got policies like
TNFD sort of coming down the 

922
00:49:47,400 --> 00:49:51,880
line, which will be really, 
really important in helping to 

923
00:49:51,880 --> 00:49:55,440
deliver a wider voluntary nature
market. 

924
00:49:55,480 --> 00:49:57,880
I think if you've got those two 
things together, then you can 

925
00:49:57,880 --> 00:49:59,560
really guide to go places with 
this. 

926
00:49:59,560 --> 00:50:03,040
And to Thomas's point, it's not 
a substitute for for public 

927
00:50:03,040 --> 00:50:06,640
money, but having the ability to
blend, you know, really 

928
00:50:06,640 --> 00:50:10,400
significant sums of private 
money through either compliance 

929
00:50:10,400 --> 00:50:14,000
markets or voluntary markets 
that are underpinned by 

930
00:50:14,000 --> 00:50:17,760
compliance markets will allow 
governments to deliver the 

931
00:50:17,760 --> 00:50:20,320
targets that they're required to
meet. 

932
00:50:20,640 --> 00:50:22,720
So I think that's a good point 
to end on here. 

933
00:50:22,720 --> 00:50:26,440
So thank you so much, Glenn and 
and thank you so much Thomas as 

934
00:50:26,440 --> 00:50:29,080
well for all your time today. 
A really, really rich discussion

935
00:50:29,080 --> 00:50:32,720
on BNG and the broader European 
landscape on biodiversity 

936
00:50:32,720 --> 00:50:34,840
credits and appliance market. 
So thank you. 

937
00:50:35,040 --> 00:50:35,960
Thanks, Helen. 
Pleasure. 

938
00:50:43,880 --> 00:50:47,040
So that's it for this week, and 
you can find out more about 

939
00:50:47,040 --> 00:50:51,640
Wending Beck, including multiple
case studies on the GFI Hive 

940
00:50:51,640 --> 00:50:54,080
website. 
And that's under our main 

941
00:50:54,080 --> 00:50:58,240
Investment Readiness toolkit. 
You'll find all the case studies

942
00:50:58,240 --> 00:51:02,640
there which go into a lot of 
detail about how it's worked and

943
00:51:02,640 --> 00:51:04,640
what Glenn's been doing for the 
last five years. 

944
00:51:04,880 --> 00:51:08,480
And you can also find the paper 
that Thomas mentioned, obviously

945
00:51:08,480 --> 00:51:10,840
over on the Nature Conservancy's
website. 

946
00:51:11,400 --> 00:51:14,880
We are going to be saying on 
this Compliance market Rd that 

947
00:51:14,880 --> 00:51:18,680
we've started along and I'm 
going to be joined by Tim Male 

948
00:51:18,680 --> 00:51:22,040
from the Environmental Policy 
Innovation Centre in the US, 

949
00:51:22,040 --> 00:51:24,880
also known as EPIC. 
And he's going to be joining us 

950
00:51:24,880 --> 00:51:28,560
next week to talk about 
mitigation banking in the US and

951
00:51:28,560 --> 00:51:30,800
the importance of these policy 
leavers. 

952
00:51:31,040 --> 00:51:33,200
Until then, I hope you have a 
great week.

