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transfer of development rights). This quantification is the basis for asserting
equivalencies across sites and projects, and it makes it possible to assign
value and to conduct transactions through the exchange.
EDF convened a panel of scientific experts to produce the HQT, and
there was an active effort to shield this process from political and economic considerations. The HQT was peer-reviewed by a committee under
the auspices of the Ecological Society of America, as well as by a 3rd-party
reviewer selected by the oil and gas industry. The process of creating a
science-based routine for accounting of habitat values and to assign rights
(credits) and responsibilities (debits) are key practices of accountability
advanced by the exchange. The elaborate process through which debits
and credits are assigned, and the performances of rigour associated with
the algorithm, legitimates the exchange. In fact, habitat exchanges were
developed in response to perceived shortcomings of existing models of
offsetting based on ‘conservation banking’ (Toombs et  al. 2018; Barral
2019). In conservation banking schemes, offsets are typically assigned
based on ad hoc negotiations between administrators and buyers and sellers of credits/debits. There is typically no standardised biological modelling, and rights and responsibilities are not specified a priori. Additionally,
offsets in habitat banking programmes have largely been financed by institutional investors engaged in a form of speculation, and there have been
limited opportunities for local landowners to participate as suppliers of
credits. The HQT responds to concerns about transparency, consistency,
and access, which bolsters its legitimacy as a conservation mechanism. In
terms of accountability, the HQT is a technical standard that quantifies
rights and responsibilities. In terms of legitimacy, this standard presents
opportunities for efficient assessment of the extent to which an energy
project or firm has internalised a commitment to no-net loss of habitat.
In reflecting on the development and the current status of the exchange,
it is worthwhile to note that mobilising science and making significant
investments in a standardised, transparent, quantitative approach to assigning habitat values have not succeeded in advancing accountability applied
to oil and gas firms’ degradation of sage-grouse habitat. From a biological
perspective, the sage-grouse does not cope well with disturbance, and this
is reflected in the debits assigned by the HQT. A firm building a four-acre
well pad in sage-grouse habitat can be assigned as much as 800 acres of
offsetting responsibility. Since the HQT was unveiled, the oil and gas
industry has consistently raised critical questions about the magnitude of
the debits assigned to specific projects. The oil and gas industry has stated
S. WOLF
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