The evidence of Biodiversity loss is pervasive and ubiquitous. Despite the compelling scientific data and the economic case for preserving Biodiversity in our communities we continue to see unacceptable levels of diminution in the range and number of species across the ecological landscape.

Valiant efforts to designate and promote Biodiversity continue to fall short in the face iof unrelenting pressure from poorly planned development and unsustainable levels of intrusion on the natural environment in pursuit of narrow financial interests.

We strongly suggest that progress on this important issue can be improved if the following recommendations are incorporated into our public policy settings.

(1)  Full cost benefits analysis of biodiversity loss; including costing for externalities need to be incorporated into the planning and development framework at local, national and EU level.

Economic and state actors wishing to make undertake development (including public infrastructure and private capital investment) and ongoing operations that are detrimental to Biodiversity should be required to incorporate the externalities associated with the biodiversity loss into their business case. This could include the use of a choice architecture framework (offset or tax) to take account of these over the life of the project and ensure the burden is borne on a user/owner pays approach. Full cost assessment of Biodiversity impacts will stop the current free riding by private and state capital on the wider wellbeing of the population through unfettered access to our natural capital.  

(2)   Designation of areas of protection is not sufficient; management and enforcement must become a requirement

The experience to date with designated sites is that proactive management and protective is paramount to their long-term sustainability. The evidence from SAC’s in particular is that designation needs to be followed up by a rigorous management and enforcement regime. The current set and forget model is not preventing the ongoing unwarranted intrusions that we see as a result of poor planning, weak local enforcement and under resourced protection agencies. In this regard the baseline biodiversity audit of natural capital is essential to any aspiration to arrest the on going decline.

(3)  An independent environment regulator should be put on a statutory footing and appointed to work jointly with the EPA and the NPWS, and other relevant public bodies to enforce regulations and protections.

The current protection regime has failed to deliver the necessary deterrents to prevent developers, and other stakeholders from ignoring the large body of environmental protection regulations. A fully resource statutory body with appropriate independent powers and mandate could help redress the decades of failure in the enforcement of our environmental protections. To date the vast bulk of ‘enforcement’ has relied on community grass roots level action through the courts under the planning framework and areas such as emissions. This is costly to the communities involved and not sustainable or desirable as the main remedy for breaches. A robust penalty enforcement regime would be self-funding I the early years and could provide the catalyst for stopping the current flood of open transgressions of the regulations.

(4)   The role of patient capital and social capital should be examined to assess, evaluate, account for the production of biodiversity.

As patient pension capital around the world moves to Net zero it is also looking to Biodiversity issues as part of the ESG aspirations. Pension funds have led the way on the transition to Net zero and the transformation of capital markets in support of a low carbon global economy. The next dimension should be biodiversity and funds are already looking at it through the lens of Regenerative agriculture, biodiversity offsets etc. This provides support for deep and liquid Biodiversity offset markets as an alternative to Biodiversity taxes.

(5)   The focus of government should shift to the production of biodiversity; technology and science are key to the transition from loss to production and architect the market to make the production of biodiversity work

The role for the government and the EU is to orchestrate the policy settings that create the conditions for full costing of the externalities of Biodiversity to be taken into account in our economic development. The case for this is firmly established by the Das Gupta and other analysis but a renewed sense of urgency is needed.

About us:

Save Roscam peninsula is dedicated to ensuring that the unique archaeological, recreational and cultural assets and designated natura habitats of the Roscam Peninsula are protected from unwarranted development.

Dr Martin Fahy



Dr Sophie Cacciaguidi-Fahy