Reply by The Wildlife Trusts (and on behalf of RSPB) to 38 Degrees Petition, courtesy of the Director, The Wildlife Trusts England.

Formal response to 38 Degrees Petition and my blog post The Act of Pricing Nature

“Dear Ginny

Firstly I would like to thank you for your comments about the proposals for a Nature and Wellbeing Act. We are keen to receive feedback and your views get to the heart of issues.

Secondly, I’d like to explain some of our thinking around the Act and to provide our perspective on the area you have expressed concern about.

The Wildlife Trusts are committed to the protection and recovery of our natural world for its own sake and for its intrinsic, innate wildness. We have a long tradition of successfully protecting some of the special places, habitats and species in this country for this reason.  But despite the efforts of all those who care about nature, as a society we are still overseeing a continual loss in the extent and quality of our habitats and their wildlife.

The reasons for this are many – and there are lots of people, such as yourself, who are working hard to try and change this on many fronts. A snapshot of what Wildlife Trusts are currently working on includes beaver reintroduction, re-naturalising rivers, nature education in schools, campaigning for protected areas at sea, land acquisition, habitat restoration, ecotherapy projects, and much more.

However we believe that one of the most profound reasons for nature’s decline is the inadequate consideration for nature within decision-making processes at all levels of government and in many parts of business. At the moment nature is almost always ‘trumped’ by the language of ‘profit’, ‘growth’ and ‘jobs’ – often overlooking the many ways that it supports us all, including, ultimately, our jobs and economy.

Recently we have been working with RSPB on a plan to try and tackle some of these fundamental issues in a piece of framework legislation – the Nature and Wellbeing Act – to help create a society that has nature at its heart.

The Green Paper you refer to in your petition presents the key ideas for this. There are 4 main strands to the paper and the Act:

Section 1 proposes new cross-departmental Government targets for increasing wildlife populations and habitats to secure the recovery of nature in a generation.

Section 2 proposes the creation of local ecological networks to increase the resilience of fragmented habitats by reversing the fragmentation that has damaged so many of our landscapes. It embeds a landscape-scale approach in how we make more space available for nature and how we join up and improve existing sites.

Section 3 proposes providing better standards of access to nature for everyone in all new developments (and existing ones where possible). It includes making more provision for environmental education and ‘caring for nature’ as a core purpose of schooling.

Section 4 proposes a new Government body to fully integrate nature into government decision-making (this could be an Office for Environmental Responsibility, like the existing Office for Budgetary Responsibility. It would be similar in function to the Climate Change Committee).

I’ll expand a bit on Section 4 which is the area you have expressed concern about.

The proposals in Section 4 are about developing methods to measure and monitor the health of nature and ecosystems at a national level so that we can determine whether as a society we are having a positive or negative impact on it, and action can then be taken accordingly.  This isn’t really happening at the moment – and those parts of government which do this type of work are not able to develop or enforce solutions at the scale required to halt the decline of wildlife. This approach could also enable businesses to measure and monitor their impacts on nature and take steps to avoid, mitigate or compensate against negative impacts. There are some forward-thinking businesses who are starting to address their impact on the natural world but again this isn’t happening at the scale required and much more needs to be done.

Part of the challenge is to make nature’s contribution to society more visible in economic decision-making where it currently loses out so often – so there is an economic dimension to this.  This is where we think the Natural Capital Committee has been playing an important role – in exploring the intellectual and academic frameworks that might be needed to better embed nature at the heart of decision-making both by the public and the private sector. Much more debate is needed in this area, but we support the presence of an independent body like the NCC (an Office for Environmental Responsibility is part of our proposals), to continue the thinking and analysis needed to better inform a wider public debate.

But, in supporting the existence of the committee and its place in the debate, we never lose sight of the broader holistic value of nature. The vital importance of the contribution that nature makes to our social and emotional wellbeing needs to be recognised much more too, as well as respecting its intrinsic worth. Ultimately, as a society we need to exercise greater accountability for our relationship with nature and we will continue to challenge politicians and others to make decisions which contribute to its health and recovery rather than the opposite.

I also understand your concerns, that by defining nature as a form of capital there is a risk that nature will somehow be ‘priced’ and that it would ultimately be bought and sold – which would be worse than simply ignoring any type of economic value altogether.  But this is not what we are proposing or would want to see. I would agree entirely with you that it is impossible to place an economic price on all nature. But I can see a benefit in better understanding, measuring and monitoring the national health of nature in England, seeking ways in which to better embed this in decision-making and having a system to make government accountable for this.

What we are exploring is the best way to do this. I agree that education and eco-literacy is also a big part of what is needed. The Nature and Wellbeing Act is about using legislation to achieve positive change for nature (and people) but an approach like this needs to work alongside people taking action for nature in their own lives too.

Finally, there are also deeper questions here about the type of society we live in, and how our economy works. This is beyond The Wildlife Trusts’ reach and expertise alone but I hope that for a starting place our contribution could be to help show that a world with more wildlife is possible, that life could be better this way (for wildlife and people) and that over time this could help to reinforce some of the values we need as a society to foster a more sustainable approach to how we live.

Thank you for reading this far Ginny and I hope that helps explain our position – even if you may not agree with it all. Feedback on the proposals is welcome so thank you for sharing your views.

I understand this will be published on your blog so for the benefit of anyone else reading this you can find out more on the Nature & Wellbeing Act here including details on how people can get in touch and send us comments on the proposals:

Martin Harper from the RSPB has also written a blog on this which you can read here. An I’ve also written a blog outlining some of the thinking behind the Act.

With best wishes, Steve (responding here on behalf of The Wildlife Trusts and RSPB)”

5 thoughts on “Reply by The Wildlife Trusts (and on behalf of RSPB) to 38 Degrees Petition, courtesy of the Director, The Wildlife Trusts England.

  1. The danger in creating policies that try to put the value of nature in economic terms is that they might succeed. And they might succeed so completely that we have trouble making the case that we need to protect nature that *doesn’t* prove it’s financial worth. Beyond that, we risk introducing the inherent volatility of the economy into conservation at the same time; the quarterly business cycle is hardly an appropriate timescale for managing complex ecosystems. Most of all, though, reducing conservation decisions to economic rationality opens up entire new realms to the logics that have delivered extreme social inequity and unchecked class power (not to mention the recent global financial meltdown).

  2. I agree with what Mr. Matulis has said.

    I’d also add that I’m concerned that we are being led a merry dance.

    Steve says that:
    “I also understand your concerns, that by defining nature as a form of capital there is a risk that nature will somehow be ‘priced’ and that it would ultimately be bought and sold – which would be worse than simply ignoring any type of economic value altogether. But this is not what we are proposing or would want to see”

    This is a very common view among conservationists. But it is not at all the view of the government of the financial industry who see this as an opportunity to create new markets, a so called ‘green growth’ opportunity. There are already plans afoot for “nature bonds” and their derivatives.

    We think we are being clever and pragmatic by talking to policy makers in terms of price, but actually we’re just giving them what they want on a plate and letting plutocrats and the market decide what is to be conserved and how.

    An excellent overview of how this forces are positioning themselves to take advantage of our desperation to halt environmental degradation is provided by Dr. Sian Sullivan:

    Banking Nature? The Spectacular Financialisation of Environmental Conservation

    Financialisation, Biodiversity Conservation and Equity: Some Currents and Concerns

    And this paper by Prof. Neil Smith looks at the deeper structures of capitalism that are driving it to see nature as an accumulation strategy.

    What these authors make clear is that the valuing of nature invariably becomes a slippery slope to the marketisation of nature. Indeed the only reason that our current policy makers are paying this any attention is that they see it as a massive opportunity take something that was previously a priceless commons and turn it into tradeable commodities.

    And as has happened with carbon markets, it doesn’t matter whether its effective or not, what matters is if money can be made (see for example: The Brave New World of Carbon Trading by Prof. Clive Spash )

    We would do well to remind ourselves of the conclusions of Polanyi’s studies of enclosure and the industrial revolution. The violence of the birth of our ‘market society’, that he termed ‘The Great Transformation’ and the effect it had on our mentalities.

    As Dr. Sullivan concludes her paper:
    “It seems pertinent to remember Polanyi’s (2001(1944):187) description of the transformation of
    land into the commodity form as ‘perhaps the weirdest of all the undertakings of our
    ancestors’. Currently we are in the midst of an equally revolutionary shift in discourses and
    practices regarding a global geography of nonhuman natures and associated cultural diversities.
    While these build on extant understandings of land as commodity and of private property, they
    extend these in radical ways to release new nature ‘values’ that can be traded, invested in and
    speculated on via conceptual and capitalised conversion into the commodity form”

    I feel that we are perilously close to undergoing a similar transformation with regards to our relationship to nature.

    I really hope that the RSPB and the Wildlife trust reconsider their stance on this crucial issue.

  3. Pingback: On ‘natural capital’ and ‘ecosystem services’ in the proposed Nature and Well-being Act (The Wildlife Trusts and RSPB) | Sian Sullivan

  4. Pingback: On ‘natural capital’ and ‘ecosystem services’ in the proposed Nature and Well-being Act (The Wildlife Trusts and RSPB) - Leverhulme Centre for the Study of Value | Leverhulme Centre for the Study of Value