We welcome the opportunity to express our views on this second consultation. The stated goal of this consultation is to gather feedback on 6 models for biodiversity credit markets, that differ from one another on two features: voluntary versus compliance, and offset versus “contributions to improving nature.
Overall, we find that the range of options considered, some of the questions being asked and the justification provided for including offsetting are not neutral, and suggest that the IAPB has a very clear idea of which type of market it wants to promote: an international compliance biodiversity offset market that allows for secondary market trading.
While a market with these features would benefit the most private corporations with destructive activities and generate the most speculative profits for financial actors, it would also repeat and magnify all the documented issues of carbon offsetting.