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The transition from No Net Loss to a Net Gain of
biodiversity is far from trivial
J.W. BULL and S . B ROWNLIE
Abstract The objectives of No Net Loss and Net Gain have
emerged as key principles in conservation policy. Both give
rise to mechanisms by which certain unavoidable biodiver-
sity losses associated with development are quantified, and
compensated with comparable gains (e.g. habitat restor-
ation). The former seeks a neutral outcome for biodiversity
after losses and gains are accounted for, and the latter seeks
an improved outcome. Policy-makers often assume that the
transition from one to the other is straightforward and es-
sentially a question of the amount of compensation pro-
vided. Consequently, companies increasingly favour Net
Gain type commitments, and financial institutions make
lending conditional on either objective, depending on the
habitat involved. We contend, however, that achieving Net
Gain is fundamentally different to achieving No Net Loss,
and moving from one to the other is less trivial than is
widely realized. Our contention is based on four arguments:
() the two principles represent different underlying conser-
vation philosophies; () ecological uncertainties make it dif-
ficult to know where the threshold between No Net Loss and
Net Gain lies; () different frames of reference are more or
less appropriate in evaluating the ecological outcomes, de-
pending on the principle chosen; and () stakeholder expec-
tations differ considerably under the two principles. In
exploring these arguments we hope to support policy-
makers in choosing the more appropriate of the two objec-
tives. We suggest that financial institutions should provide
greater clarity regarding the explicit requirements for each
principle. We conclude by highlighting questions of rele-
vance to this topic that would benefit from focused research.
Keywords Biodiversity offset, development impacts, frame
of reference, mitigation hierarchy, net gain, net positive, no
net loss, uncertainty
Introduction
The challenge of finding mechanisms that conserve bio-
diversity alongside economic development is a priority
for humanity (Baillie et al., ; Mace et al., ). One
emerging principle that shows promise in this regard is
that of No Net Loss. The objective is to permit development
whilst retaining overall levels of biodiversity, by applying a
mitigation hierarchy (e.g. avoid, minimize, restore, offset;
BBOP, a) in relation to negative impacts of develop-
ment on nature. Despite the technical difficulties that arise
in implementation (Bull et al., a; Gardner et al., )
and the controversy surrounding the logic underpinning
No Net Loss (Apostolopoulou & Adams, ), the prin-
ciple is increasingly well established in international policy
(e.g. Madsen et al., ; Tucker et al., ) and corporate
practice (Rainey et al., ). It is consequently a topic of
ongoing research interest.
In a conference was held on this topic: To no net loss
of biodiversity and beyond (BBOP, ). Throughout, there
was much talk of aiming for a net gain in biodiversity, as a
superior goal to No Net Loss. Net Gain is already reflected
both in relation to project finance (e.g. the International
Finance Corporation specifies the need for a net gain in bio-
diversity in critical habitat as a lending requirement; IFC,
) and in corporate sustainability strategies (e.g. Net
Positive Impact commitments; Rainey et al., ). The
choice of a commitment to positive Net Gain over the
more neutral No Net Loss is desirable to many stakeholders.
In theory it should represent a better outcome for biodiver-
sity conservation, whilst aligning with the Aichi targets
(CBD, ) and presumably the objectives of biodiversity
stakeholders. Furthermore, it is appealing to businesses
seeking a positive strategic message over a neutral one.
There has been scant commentary, however, on the im-
plications of transitioning from one objective to the other.
Net Gain is in some cases simply described as ‘No Net
Loss plus’(GN, guidance note to the International
Finance Corporation’s Performance Standard ; IFC,
), or where the ‘biodiversity gains exceed a specific set
of losses’(BBOP, b). Our view is that this transition is
poorly understood but presents significant challenges, some
of which we outline here.
It seems to be a common assumption that the difference
between achieving the two outcomes is almost trivial (e.g. if
a development clears trees but the developer plants a
stand of trees nearby then there is arguably no net
loss; if the developer plants trees they have achieved a
net gain). We have heard this assumption implied through-
out the No Net Loss conference and elsewhere, although not
in the academic literature. The perceived triviality of such a
transition may partly explain corporate eagerness to make
J.W. BULL (Corresponding author) Department of Food and Resource
Economics & Centre for Macroecology, Evolution and Climate, University of
Copenhagen, Rolighedsvej 23, 1958 Copenhagen, Denmark
E-mail jwb@ifro.ku.dk
S. BROWNLIE deVilliers Brownlie Associates, Claremont, South Africa
Received April . Revision requested May .
Accepted July .
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positive rather than neutral commitments. However, the
differences between the two policy objectives are more sig-
nificant than is currently widely appreciated. The challenges
we explore here illustrate the complexities of the transition
from No Net Loss to Net Gain.
Note that when we refer to biodiversity value, it is in-
tended in this context to mean a measure of any component
of biodiversity that has intrinsic use or cultural significance
for one or more stakeholders, and any component that
forms the basis of impact assessment and mitigation efforts,
including biodiversity offsetting.
The transition from No Net Loss to Net Gain
Distinct underlying conservation philosophies
Whether or not either of the policy objectives can be met
depends explicitly on their scope and what they are intended
to achieve by when (ten Kate & Crowe, ). At its simplest,
to achieve No Net Loss, loss of biodiversity values must be
fully compensated by commensurate gains in those values.
To achieve the more positive objective of a Net Gain, the
biodiversity status quo must be improved, either by over-
compensating for loss in the biodiversity values affected,
or by ensuring no net loss in those values and then provid-
ing additional gains in other biodiversity values. The latter
would involve so-called out-of-kind biodiversity compensa-
tion. Out-of-kind compensation is not synonymous with a
Net Gain objective but is one way of attempting to achieve it.
The concept of ‘like for like or better’exchanges is a
widely held tenet of No Net Loss policy and is expressed
in key standards (e.g. BBOP, a; IFC, ). In certain
contexts gains in a biodiversity component other than that
affected, but of higher conservation value, may be permitted
to count towards achieving No Net Loss/Net Gain (so-called
trading up), rather than requiring like for like gains.
Tensions exist between the like for like and the ‘...or better’
concepts; the former adheres predominantly to scientific
metrics for impact-compensation exchanges, whereas the
latter moves into the realm of societal value judgements,
for which there is no easy metric to convert losses of one
type of biodiversity to gains in another. In some cases the
former may be possible using relatively straightforward
species- or habitat-based metrics, whereas the latter may re-
quire a better understanding of (and metrics that capture)
ecological processes. This shift exacerbates the complexity
of determining when policy goals have been reached.
Occasionally the wisdom of strict like for like constraints
is challenged (Habib et al., ), as conservation objectives
may not always be best served through in-kind exchanges.
Using an example of ecological compensation in relation
to oil and gas activity in north-west Uzbekistan (Bull
et al., b), direct losses primarily comprise clearance of
vegetation for infrastructure (Jones et al., ). A strict
framework for full ecological compensation here could po-
tentially require restoration of vegetation across the land-
scape (Fig. ). However, the vegetation cleared during the
past c. years for oil and gas represents c. .% of the re-
gional habitat by area, and therefore spending funds on its
restoration or protection would not necessarily deliver ma-
terial gains for conservation. Conversely, funding the cre-
ation and operation of aggregated areas where poaching
pressure on threatened fauna was removed, with habitat
protection as an incidental outcome, could represent a
more valuable gain for biodiversity conservation. The latter
approach is out of kind, as losses in grassland would be
traded for gains in fauna conservation, but could deliver
an overall gain from the perspective of conserving priority
biodiversity in Uzbekistan (i.e. would satisfy the ‘...or bet-
ter’condition). Comparable arguments have been made
elsewhere, for example for caribou in Canada (with offsets
that target caribou as an out of kind priority species in ex-
change for vegetation losses; Habib et al., ).
In the Uzbek case if no net loss of specific biodiversity
components were the intention of policy-makers (as for
wetlands in the USA, for example) then the developer
might be obliged to carry out an equivalent amount of
FIG. 1 Extant oil and gas industry infrastructure in north-west
Uzbekistan, alongside potentially optimal regions for biodiversity
offsets. Infrastructure, mapped using data collected by Jones
et al. (), is known to affect fauna and flora negatively in this
region. Potential biodiversity offset sites (displayed here
schematically) were determined based on quantitative analyses
undertaken by Bull (); optimum sites were identified both
for like-for-like offsets (vegetation restoration) and for
out-of-kind offsets (fauna protection).
2 J. W. Bull and S. Brownlie
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habitat restoration, or restore a bit more than was lost to
achieve a net gain. However, the intention is to achieve
net conservation gain, making a stronger case for taking a
more flexible approach, targeting higher priority biodiver-
sity (i.e. fauna species, provided that credible exchange
rules are in place). This example emphasizes a possible dis-
tinction between the two policy objectives: that No Net Loss
could be used to target predominantly ‘like’biodiversity and
maintenance of existing biodiversity trajectories, whereas
Net Gain may aim to achieve gains for conservation overall
using more ‘out of kind’exchanges. The transition from the
former to the latter can represent a fundamental shift in
philosophy, away from one in which the prevailing trend
in biodiversity is accepted even if that is a decline, and the
trajectory is not altered (Gordon et al., ), to one in which
the commitment is used as a mechanism for reversing bio-
diversity declines in priority areas for conservation, poten-
tially with more acceptability of out of kind approaches.
Such a shift in underlying philosophy becomes particularly
important in the context of concerns, held by some, that in
No Net Loss policies involving biodiversity offsets ‘a dys-
topian future of continued biodiversity loss is presented as
the only alternative’(Apostolopoulou & Adams, )–
concerns that may presumably be partly mollified under
policies requiring a Net Gain.
According to International Finance Corporation guide-
lines, where development occurs in critical habitat a net
gain in the biodiversity values for which the critical habitat
was designated is required to satisfy Performance Standard
(IFC, ). However, where an environmental impact as-
sessment concludes that there will be no residual impacts on
the components relevant to the critical habitat designation,
no net loss is effectively already predicted. There is therefore
no need to further demonstrate quantitatively that offset
measures would achieve No Net Loss, as any such measures
(presuming they result in positive outcomes for critical
habitat components) could be presumed to meet the Net
Gain requirement. This facilitates flexibility in designing en-
hancement measures (e.g. Rajvanshi et al., ) and in such
cases apparently obviates the need to further quantify losses
and gains.
Uncertainty in achieving no net loss
Demonstrating that biodiversity gains balance losses is a key
element of No Net Loss. However, the relevant calculations
are subject to uncertainty and risk in a variety of ways; for
example, uncertainty in the success and timing of ecological
restoration (Maron et al., ), measurement error or
vagueness in key terms (Kujala et al., ), and uncertainty
in the degree to which developers will comply with policy
(Bull et al., a). To ensure a neutral outcome, taking ac-
count of the uncertainties in project design and implemen-
tation, projects generally design compensation measures
that create more biodiversity value than is lost, often using
project multipliers (Moilanen et al., ; Pickett et al.,
). Multipliers are used to improve confidence levels in
achieving neutral or net positive biodiversity outcomes
(BBOP, b). The fact that meeting a No Net Loss object-
ive often effectively requires overcompensating for losses
means that it is not straightforward to specify how large
gains should be in the case of a Net Gain policy objective.
Fig. illustrates the net outcome for biodiversity calculated
for the Uzbek case study using biodiversity offset methodolo-
gies from various jurisdictions (Bull et al., a). Even
FIG. 2 Simulated net condition-area trajectories for Uzbek scrub habitat, achieved under three biodiversity offset methodologies, for
the case study of oil and gas infrastructure in north-west Uzbekistan (Fig. ). The condition-area of any one patch of habitat is the
patch area × the condition of the patch (normalized between and ). Vertical lines indicate uncertainty bounds. The methodologies
applied (for illustration) are fish habitat compensation (Canada), biodiversity offsetting pilot (UK) and native grassland compensation
(Victoria, Australia). Net outcome is calculated as the condition-area of habitat gains from offset sites minus the condition-area of
habitat losses as a result of development activities. When net outcome = , No Net Loss is achieved; when net outcome ., Net Gain
is achieved. (Adapted from Bull et al., a)
Transition from No Net Loss to Net Gain 3
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methodologies that should theoretically lead to an overall
outcome of net gain can result in a neutral outcome or
even net loss, once uncertainties are taken into account.
The analysis by Bull et al. (a) considered uncertainty
only in terms of error in the measurement and estimation
of biodiversity losses (i.e. development impacts) and uncer-
tainty in policy compliance; many other sources of uncer-
tainty exist, which would amplify the divergence in outcomes.
If proving that a No Net Loss objective has been attained
requires aiming for a Net Gain in any case, what additional
measures would be needed to demonstrate that a Net Gain
has been achieved? Either () the project must include a
well-developed and quantified understanding of all uncer-
tainties associated with the development and compensation
measures, which is currently beyond the science, let alone
practice, or () the additional biodiversity value created is
such that there can be almost no question that Net Gain is
achieved. Choosing the latter option would rely to some ex-
tent upon informed estimation and could have significant
cost implications compared to the former; this is not a rea-
son to rule it out but is an important consideration. In cases
in which societal value judgements have been incorporated
into questionable exchange rules and in which uncertainties
are large enough, arguably it is impossible to determine the
point at which a given project transitioned from a neutral to
a net positive outcome for biodiversity.
Frame of reference
The outcome of implementing a given conservation policy
depends on the ecological baseline against which it is eval-
uated (Gordon et al., ). This is especially relevant to pol-
icies with measurable goals as a fundamental characteristic,
such as those discussed here. However, the appropriate
choice of baseline is not straightforward, and it is possible
to specify alternative counterfactuals for evaluation (i.e. dy-
namic baselines, for alternative scenarios that could have oc-
curred in the absence of the policy being implemented;
Ferraro & Pattanayak, ). The baseline and set of plaus-
ible counterfactual scenarios used for evaluation can to-
gether be called the frame of reference (Bull et al., b).
The choice of reference frame can significantly influence
the observed outcome; the same policy leading to the same
set of conservation actions can result in net loss, no net loss
or a net gain in biodiversity. Some reference frames make
achieving certain outcomes improbable (Bull et al., b);
for instance, a set of policy-driven compensatory mitigation
actions evaluated against a no-development counterfactual
could point to a net loss for biodiversity, whereas the
same actions evaluated against a business-as-usual counter-
factual might always result in a net gain (Gordon et al., ;
Bull et al., b). The chosen frame of reference embodies
decisions about the spatial and temporal scales upon which
conservation policy is evaluated, which can materially affect
whether No Net Loss or Net Gain objectives are met.
In some respects this point blurs the line between the two
policy goals under discussion: the difference between achiev-
ing neutrality and net gain could be said to rest upon the
frame of reference chosen for evaluation. However, the choice
of baseline or counterfactual does not simply alter the conclu-
sions drawn from evaluation, it also influences the incentives
for participants in the implementation of the policy, and
therefore ultimately their choices, which determine the phys-
ical outcomes of the policy (Bull et al., b).
Consequently, specifying either No Net Loss or Net Gain
as a policy objective requires specifying the frame of refer-
ence to be used in evaluation at both a project and a policy
level. However, it may be appropriate in some cases to use
different baselines to evaluate the various outcomes. For ex-
ample, a No Net Loss policy objective implies a desire not to
exacerbate declines during development projects, perhaps
suggesting evaluation against a no-development counterfac-
tual. Alternatively, a Net Gain objective could imply a desire
to halt and reverse biodiversity declines in the landscape,
suggesting evaluation against a fixed current baseline.
Thus, the transition from one to the other could involve
considering a change in the frame of reference against
which the conservation policy is evaluated. In turn, any
modification of the frame of reference could alter the phys-
ical outcomes by altering incentives for those implementing
the policy.
Stakeholder perceptions
There is some opposition to the implementation of both
policy objectives, and to related mechanisms such as bio-
diversity offsetting (e.g. Burgin, ; Walker et al., ;
Curran et al., ). Moreover, there is often mistrust
amongst public stakeholders in offsetting, which has, for in-
stance, been a barrier to the establishment of such policies in
the UK (Gordon et al., ).
Part of a company’s rationale for choosing a Net Gain
commitment over No Net Loss is that the former sends a
more positive message. The International Financial
Corporation’s distinction between neutral compensation re-
quirements for natural habitat where feasible and net gain
requirements for critical habitat (IFC, ) suggests that
the difference between the two is significant, possibly foster-
ing raised expectations of offset performance.
Although it has been shown that biodiversity offsets can
improve a company’s social licence to operate (Richert et al.,
), many stakeholders will have less confidence that a
company can achieve net biodiversity gains rather than
No Net Loss. This, in turn, could engender mistrust. In
the case of Rio Tinto, for example, who have committed
to a policy of Net Positive Impact (Rainey et al., ), we
4 J. W. Bull and S. Brownlie
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contest that, whatever they achieve in practice, many mem-
bers of the public are unlikely to believe that one of the lar-
gest extractive companies is having a net positive impact
upon nature. Conversely, by implication, No Net Loss com-
mitments suggest only that a company is cleaning up its
mess, which is perhaps a more tenable concept to the non-
specialist. Again, the transition from one policy objective to
the other is arguably not trivial if one is much more difficult
to argue convincingly in a public forum. The ability or
otherwise to convince stakeholders of a company’s biodiver-
sity achievements represents material reputational risks.
Discussion
There are some who regard the policy objectives discussed
here as ‘a symbolic but illusory goal’(Walker et al., )
or would dispute whether either goal represents desirable
conservation policy. Challenges to achieving No Net Loss/
Net Gain have been discussed in the literature (Gardner
et al., ; Bull et al., a), and include difficulties in man-
aging uncertainties (Moilanen et al., ), ensuring suc-
cessful restoration (Maron et al., ; Curran et al., ),
applying appropriate currencies, multipliers and exchange
rules (BBOP, b), and avoiding perverse incentives
(Gordon et al., ). Both policy principles remain contro-
versial (Apostolopoulou & Adams, ). However, the idea
that businesses should contribute towards ecosystem restor-
ation and the reversal of biodiversity declines has consider-
able support (Bayon & Jenkins, ), to the extent that it is
included within the Aichi targets (Target ; CBD, ).
We consider the policy objectives of No Net Loss and Net
Gain to be laudable. Here, we have examined the implica-
tions of and highlighted the differences between the two
objectives, contending that there may be practical ramifica-
tions arising from choosing one over the other. In many
cases, however, achievement of either goal is subject to the
same methodological challenges (e.g. baselines for compari-
son, time-frames, choice of metrics, uncertainty).
Our exploration of the transition from No Net Loss to
Net Gain may suggest the approaches are on a continuum:
in the simplest case, Net Gain may simply be an extension of
No Net Loss, being defined in relation to the same biodiver-
sity values and applying a like for like exchange. However, it
may not be the case that one is always required to be a step-
ping stone towards the other. There are a number of open
questions relevant to this topic. They include but are not
limited to the following:
.How often designing for No Net Loss incidentally leads
to Net Gain, and vice versa;
.The extent to which loss of biodiversity is accepted in ex-
change for conservation of biodiversity of a higher prior-
ity to achieve either No Net Loss or Net Gain, and on
what basis;
.The extent to which the transition from No Net Loss to
Net Gain is viewed as a continuum, and under what con-
ditions and how frequently it is deemed acceptable to tar-
get one set of biodiversity components for the former
and a different set for the latter;
.Whether or not Net Gain of biodiversity and Net Gain
for conservation are perceived as the same or different
objectives (i.e. must Net Gain be defined in relation to
societal priorities for conservation?);
.Whether the exchange rules for attaining No Net Loss
and Net Gain differ in practice;
.How the two objectives apply with respect to social and
cultural benefits and values.
Regardless of one’s perspective the transition from No Net
Loss to Net Gain requires further debate and research, espe-
cially given its importance to policy. The question of
whether one is different from the other is relevant to corpor-
ate considerations regarding setting and evaluating bio-
diversity policy and strategy, which is an emerging item
on the corporate sustainability agenda (Rainey et al.,
2015); to the widespread implementation of the mitigation
hierarchy under the International Finance Corporation’s
Performance Standard 6 guidelines, which require a neutral
outcome in certain habitats and a positive one in others
(IFC, 2012); and to the development of national policy, as
No Net Loss is currently under consideration or revision
as a policy principle in a number of jurisdictions (e.g.
Madsen et al., 2010; Defra, 2011; Tucker et al., 2013;
Poulton, 2014).
The difficulty and feasibility of transitioning from No
Net Loss to Net Gain should not be underestimated. We
have presented four arguments as to why this is the case:
() the two principles often represent different underlying
philosophies on the part of policy-makers; () theoretical
and practical sources of uncertainty make it unclear when
the transition has occurred; () the transition is complicated
by the question of whether the same frame of reference is
appropriate in both cases; and () the two principles are
likely to evoke different perceptions and expectations
among stakeholders. On the basis of this discussion, we ad-
vise the following:
For regulators, policy-makers, consultants, businesses, fi-
nancial institutions and researchers: distinguishing between
No Net Loss and Net Gain as policy principles, recognizing
the connection between them but also that they can have
fundamental differences; and differentiating between, and
defining permissible application of like for like and ‘...or
better’exchanges of biodiversity in relation to specific con-
texts and desired outcomes.
For regulators and policy-makers: clearly defining the
scope of application of either or both policy principles, to
inform approaches in practice (i.e. to what does each policy
principle apply, and what outcomes at what scale are
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required?); and clarifying whether and under what circum-
stances out of kind exchanges would be permitted in rela-
tion to both principles (e.g. in achieving No Net Loss, or
only once No Net Loss has been achieved in attaining Net
Gain).
For consultants: paying particular attention to the spe-
cific outcomes required under either principle within
time-frames required for each case and context, including
exchange options, likely risks and uncertainties, optimum
frames of reference, and choice of metrics.
For businesses: taking into account the frames of refer-
ence, time-frames and the range of uncertainties associated
with pursuing either No Net Loss or Net Gain outcomes
when deciding on policy, balancing the potential reputa-
tional benefits of the latter against the greater potential to
be discredited.
For financial institutions: being more explicit about lend-
ing requirements, particularly in terms of the extra burden
of proof upon achieving and being able to demonstrate de-
fensibly a net positive rather than a net neutral outcome for
biodiversity.
Acknowledgements
We thank Amrei von Hase, Bruce McKenney and Leon
Bennun for insightful comments and constructive criticism
during the discussion of this topic at the BBOP confer-
ence. JWB is supported by a Marie Skłodowska-Curie
Fellowship award from the European Commission.
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Biographical sketches
JOSEPH BULL explores the outcomes of human activities in a range of
ecosystems at macro-ecological scales, considering system change and
uncertainties, through simulation modelling and spatial analyses. He
has a particular research interest in the topic of business and biodiver-
sity. SUSIE BROWNLIE has worked in the field of environmental
assessment for over years. Her core interest is in biodiversity-
inclusive impact assessment at strategic and project levels. She has
been involved in the developing field of biodiversity offsets, has pre-
pared policy and guidance, and has worked on specific offset projects.
Her other interests are ecosystem services and social–ecological
resilience as applied to environmental assessment and planning.
Transition from No Net Loss to Net Gain 7
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