11 Brower et al.: Biodiversity compensation compliance
Compliance with biodiversity compensation on New Zealand’s public
conservation lands
Ann Brower*, Laurien Heijs, Ruth Kimani, James Ross and Crile Doscher
Department of Environmental Management, Lincoln University, PO Box 84, Lincoln 7647, Canterbury, New Zealand
*Author for correspondence (Email: Ann.Brower@lincoln.ac.nz)
Published online: 27 November 2017
Abstract: This article assesses compliance with biodiversity compensation on New Zealand’s conservation
land. Of the 261 Department of Conservation (DOC) concessions for commercial activity searched, only about
15% included compensation provisions. A sample of 20 concessions of that 15% suggests 68% achieve full
compliance. Our results suggest compliance is infuenced by factors such as habitat and activity type, protected
area category, and whether a concession holder has pending concessions and/or renewals. Inconsistencies
in compliance monitoring, enforcement, and reporting merit attention. Although New Zealand’s rate of
full compliance with biodiversity compensation conditions is higher than that observed in other countries,
compensation is rarely requested. This rarity and the lack of national guidelines on how and what to ask for
in compensation, suggest that compliance with compensation once requested, and the quality and consistency
of requests, limit biodiversity protection. Jurisdictions engaging in biodiversity compensation should attend
not just to compliance, but also to the requests themselves. To do so, they should develop clear guidelines,
enforcement strategies, and reporting processes.
Keywords: biodiversity compensation; compliance; concession; Conservation Act; Department of Conservation;
enforcement; implementation; monitoring; New Zealand; policy
Introduction
Biodiversity compensation employs positive conservation
actions to mitigate the adverse effects of resource use and
development (Burgin 2008; Gordon et al. 2011; Pilgrim et
al. 2013). It is a prominent and growing practice on public
and private lands around the world (Burgin 2008; Madsen
et al. 2011) as it promises to advance development and
conservation simultaneously (Ten Kate et al. 2004; McKenney
& Kiesecker 2010; Bull et al. 2013; Linterman 2014). While
growing in popularity, biodiversity compensation is fraught
with complications, particularly in biodiversity offsets, a
subset of compensation (Walker et al. 2009; Maron et al.
2012; Brownlie et al. 2013). One such complication, and our
focus, is inadequate compliance monitoring and compliance
outcomes (Gibbons & Lindenmayer 2007; Bull et al. 2013).
In New Zealand, compliance with compensation is fretted
over more than measured (Tonkin and Taylor 2012; Brown et
al. 2013; Linterman 2014). A 2017 report by the Environmental
Defence Society found that New Zealand’s environmental
compliance regimes are less than robust throughout the
sector (Brown 2017). This issue represents an unquantifed
threat to biodiversity (Bekessy et al. 2010; Brown et al. 2013)
and undermines the credibility of biodiversity protection
(Hornyak & Halvorsen 2003). Reasons for poor monitoring
and compliance of biodiversity compensation include lack of:
(1) a regulatory framework for biodiversity compensation;
(2) monitoring resources; (3) clarity in responsibility for
monitoring; (4) training in biodiversity compensation
monitoring; (5) clear and effective methods for measuring
biodiversity; and (6) political will (Walker et al. 2009; Tonkin
and Taylor 2012; Rega 2013).
Biodiversity compensation occurs ad hoc under two of New
Zealand’s most prominent biodiversity laws, the Conservation
Act 1987 and the Resource Management Act 1991 (RMA) (see
http://legislation.govt.nz). Currently, there is no national policy
guiding implementation and evaluation (Madsen et al. 2011;
Brown et al. 2013), but we defned compensation as additional
conservation actions that went beyond what would be required
under the traditional avoid-remedy-mitigate approach. Brown
et al.’s (2013) study was the frst systematic evaluation of
compliance with biodiversity compensation on predominantly
private land, under the RMA. Ours is the frst study on public
conservation land, under the Conservation Act.
Administered by the Department of Conservation (DOC),
the Conservation Act governs the conservation estate – one third
of New Zealand’s landmass. While the Act favours conservation
over development on public conservation land, DOC will allow
commercial activity in some form through a concession. DOC
can place conditions on a concession, requiring compensation
or remediation in some form for detrimental effects that were
impossible to avoid, remedy, or mitigate (DOC 2014). This
article explores geographic, procedural, regulatory and social
infuences on compliance, and recommends improvements for
compensation to better avoid biodiversity loss.
Methods
We examined compliance with biodiversity compensation
conditions in DOC concessions. An agreement with DOC
allowed data collection for no more than 20 concessions, due
to time constraints for feld inspections and the commercially
sensitive nature of the concessions database. Each of the 20
concession cases required up to fve compensatory conditions,
for a total of 32 conditions. We had to exclude four conditions
due to insuffcient data. In total, our sample included 28
conditions.
New Zealand Journal of Ecology (2018) 42(1): 11-17 © New Zealand Ecological Society.
DOI: 10.20417/nzjecol.42.4