COMMENTS ON THE BIODIVERSITY OFF-SET GUIDELINE

The EMS Foundation was established in 2014. It is a Trust which is a registered nonprofit organisation and public benefit organisation. EMS is committed to social and inclusive justice, compassion and the advancement and protection of the dignity, rights and general welfare of vulnerable and marginalised groups and individuals in South Africa, with particular focus on youth at risk, the elderly and the conservation and protection of wildlife.

On the 25th March 2022 the national Minister responsible for the environment published a draft National Biodiversity Offset Guideline for public comment.

The attached document constitutes the comments of the EMS Foundation, which have been endorsed by a number of organisations, on the Draft Guideline.

Excerpt from the EMS Foundation comments:

“CONCLUSIONS

The concept of biodiversity offsetting does not recognise the right of the individual components of ecosystems to exist and of ecosystems to remain intact and functioning. The Guideline is silent on how the welfare of individual animals is to be protected when a decision is made to authorise the destruction of a habitat, based on offsetting.

The EMS Foundation does not support the use of biodiversity offsetting to allow projects with high or moderate residual negative impacts on biodiversity to be authorised or to allow the public interest in preserving biodiversity and halting the rapid loss of habitats and species to be overridden.

If biodiversity offsetting is to be permitted at all, it must be subject to the strictest of controls, ideally containing in binding legislation, and to effective monitoring and enforcement by the State, not by developers. All interested and affected parties must be consulted during the process of identifying an securing offset sites and developing management plans and implementation agreements.”

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