This seems to be a…

Comment

This seems to be a streamline path to habitat destruction which does not enable the protection of species no matter what kind of offsets can be generated with funds. Many habitats such as wetlands develop specific conditions over thousands of years. This kind of complexity cannot be fixed or created by human intervention. For example, seed banks can store species diversity in an area that if developed is not replaceable. This is because many species are simply not easy to grow horticulturally and therefore cannot be placed into a newly created offset. These types of losses are why the original habitat will always be superior to protecting species at risk than an offset.

There also seems to be a lack of transparency and accountability in the fund.