We read with great interest the draft guidelines published by Peru’s environment ministry and want to express a few concerns:
- Concern 1: We note that the draft guidelines mention “net gain”, which suggests that biodiversity credits could be used for offsetting. The mention of “net gain” in the draft guidelines does not clarify how ” net gain ” is defined or how much it is supposed to be. It also lacks clarity on whether it envisions like-for-like offsetting or any other type. If this “net gain” approach remains, equivalence tables should be made publicly available, and this should follow a public consultation.
- Concern 2: We would like to see more clarification on who can purchase the credits, what claims buyers can make, and what it means to benefit “indirectly”. It will be important to determine if international trading would be allowed (i.e., if a European company could purchase the credits and then claim that this purchase offsets biodiversity destruction caused by its own activities or those of a Peruvian subsidiary elsewhere, or as another example, if a foreign investment fund could purchase credits to bet on their future price).
- Concern 3: It would be important to clarify if the Environmental ministry foresees any future formal linkages between Peru’s biodiversity credits and forthcoming EU nature credits, and if so what linkages; if, for example, the above-mentioned European company could purchase Peruvian biodiversity credits and convert them into EU nature credits.
- Concern 4: In the draft guidelines, it is not clear whether the credits can be purchased and sold an unlimited number of times, thereby favouring speculation, or whether there will be limits or a ban on secondary market trading.
- Concern 5: It is not clear whether the ex-ante sale of credits will be authorised or banned. If banned, biodiversity credits should only be issued after a positive biodiversity outcome has been measured.
- Concern 6: It would be important to know if the Environmental Ministry can take measures to ensure that the lessons learned from the past experiences from Alto Mayo and the Cordillera Azul National Park will be taken into account to not repeat the past mistakes.