Sustainability is arguably at or near the top of the agenda for individuals and organisations now more than ever as net zero targets get closer. But the green landscape can be difficult to navigate given the number of buzzwords and phrases that abound.
A new edition of The Scotsman’s Sustainable Scotland podcast, in partnership with independent UK law firm Burges Salmon delves into the topics of natural capital, sustainable land use and nature-based solutions to help listeners make sense of these concepts and their role in the push to net zero
A new edition of The Scotsman’s Sustainable Scotland podcast, in partnership with independent UK law firm Burges Salmon delves into the topics of natural capital, sustainable land use and nature-based solutions to help listeners make sense of these concepts and their role in the push to net zero
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NewsTranscript
00:00Hello, I'm Rosemary Gallagher and welcome to our Sustainable Scotland podcast, brought
00:07to you by The Scotsman, Scotland's national newspaper since 1817, now bringing you fresh
00:12and relevant content for the 21st century. Sustainable Scotland is how Scotland is doing
00:16its efforts to be cleaner and greener for the next generation. In this edition, in partnership
00:20with law firm Bruges Salmon, which celebrates its fifth anniversary in Edinburgh this year,
00:24we're discussing the topics of natural capital, sustainable land use and nature-based solutions.
00:30Our guests today are Stuart Macmillan, partner with Bruges Salmon, Sarah Sackville-Hamilton,
00:34director at Bruges Salmon, and Ross Simpson, partner with Bruges Salmon. Could I please
00:38ask you all to introduce yourselves and tell me more about your roles and involvement in
00:41natural capital?
00:42Thanks, Rosemary. I'm Sarah Sackville-Hamilton. I'm a director in the environment team at
00:47Bruges Salmon. I've been at Bruges Salmon for just over 10 years now, having trained
00:53and qualified at the firm. And throughout that time, what I've specialised in is helping
00:58clients to navigate environmental regulatory and contractual issues and bring forward
01:04net zero and sustainability projects. And in the last few years, a lot of what that
01:09has meant is helping clients to navigate nature-based solutions projects and natural capital markets.
01:16My specialism within that area is advising clients on regulation and policy, and on drafting
01:24and negotiating the commercial contracts for the various strands of delivering nature-based
01:30solutions projects.
01:31Thank you, Sarah. Stuart, could you tell me a bit about your background and your experience
01:37in nature-based solutions?
01:38Sure, Rosemary. My name is Stuart Macmillan. I'm a finance partner based in Bruges Salmon's
01:45Edinburgh office. So I joined just after we opened here about five years ago. My day job
01:53is advising lenders and borrowers on various financing projects. Traditionally, that's
02:00been things like renewable energy, solar, wind, all that sort of stuff. But increasingly,
02:07we are seeing natural capital as being something that funders in the market are very interested
02:12in and interested in lending. And so I've done a few of these alongside Ross and his
02:16team up here in Scotland. So I can talk about them in a bit.
02:21Thanks, Stuart. And Ross, over to you, please.
02:23Cheers. Thanks, Rosemary. Thanks for having us along today. My name is Ross Simpson. I'm
02:28a partner in Bruges Salmon's real estate team. I specialize in land and rural property. So
02:34a Greenwelly lawyer, if some might say. I joined Bruges Salmon in 2015. I'm dual qualified,
02:42which allows me to practice in England and Wales and also in Scotland. I find that really
02:46useful because it provides that kind of ideal opportunity to see how things are dealt with
02:51and approach south and north of the border for various clients who are looking to engage
02:57with nature markets, particular focus on landowners. So you're kind of institutions,
03:02your traditional private landowners, historic estates, charities, and also maybe from time
03:08to time as a consortia of landowners. They're trying to achieve maybe landscape scale type
03:13projects. And yeah, we've as a firm always had a kind of very strong agriculture and estates
03:19practice. And one of the first firms to actually have a dedicated environmental law team. So
03:25collaboratively working with my environment and commercial team colleagues, we're increasingly
03:30involved in helping clients realize their net zero ambitions, advising landowners,
03:36corporates, brokers, all trying to maximize the sorts of opportunities that come from
03:41natural capital assets. Thanks, Sean. I like the Greenwellian lawyer description.
03:48Thanks, everyone. So if we just delve into the topic matter now, so nature-based solutions,
03:55it'd be good to have a definition of what they are to start with, because not everyone listening
03:59will be completely clear on what that is. So can someone explain what nature-based solutions
04:04actually are? Yes, I'm very happy to take that one. It's a very good question. There are lots
04:11of labels and buzzwords and expressions being bandied about in this space at the moment,
04:16whether it's natural capital, sustainable land projects, nature-based solutions,
04:21ecosystem services, some might just badge it, the green stuff. And yeah, I think it's really
04:29important. You know, there is this new language and it's vocabulary emerging, and it's good to
04:34have a really important handle on it, because I think, yeah, certainly some of the conversations
04:39that I've been having, there is a tendency to conflate terms, and that can be problematic and
04:45sometimes can undermine the utility of the terms and the concepts and ideas that we're using in
04:49this space. So at a very high level, in terms of what we mean by nature-based solutions,
04:57we're essentially talking about nature restoration projects, things that are designed to create or to
05:04enhance or to protect various forms of natural capital. And by natural capital, we mean nature
05:11stocks, natural resources, things like woodlands, peatlands, soils, hedgerows, rivers, waterways,
05:17that kind of thing. And when nature-based solutions are used to generate ecosystem services,
05:25they can then be monetised. So, for example, if a nature-based solution involves the sequestration
05:31of carbon, that may generate carbon credits. Or if you're generating biodiversity, that could
05:38create biodiversity units and the like. And yeah, nature markets and nature-based solutions are the
05:45kind of packaged way in which ecosystem services can be valued and paid for by individuals and
05:51corporates and other types of organisations. OK, now, thanks, Ross. It's a fairly new concept,
05:57something that's been around for a long time, which has become more prevalent in recent years.
06:03I think it's something that has been around probably longer than we actually appreciate,
06:07I think, as a business and as a firm. Gosh, we were advising tree planting contracts 15,
06:1220 years ago when corporates were first looking at their carbon footprint and how they might
06:19address and tackle some of the associated issues, you know, the early movers in terms of developing
06:25their ESG strategies. We were having those conversations back then. Sometimes people
06:30forget that, but as there is now this race to net zero and how we're going to achieve that,
06:35it's definitely at the forefront of a lot of people's thinking and the kind of strategies
06:39that businesses are working on at the moment. Yeah, I completely agree with that. And just to
06:44jump in, I think it's right that the sort of fundamental principles of what these projects
06:51are and what they can do have been around for a little while. But it's in the last few years
06:57that we've really seen crystallisation and formation of what you might actually look at
07:02and think of as a as a market rather than individual projects for people who are pursuing
07:08them. And it's, yeah, as Ross said, that that key terminology around natural capital and that
07:14awareness of natural capital and its value and its importance in the transition to net zero
07:20has really come firmly into focus in the last few years.
07:25Thanks, Sarah. And can you tell me more about natural based capital markets in the UK,
07:29especially Scotland, and how they have developed in recent years?
07:33Yeah, I'd be very happy to to take that one. I think the starting point for me is that natural
07:41capital markets in the UK are still quite nascent. But as Ross and I have both just said, they're
07:46growing very rapidly. And that's true both of voluntary markets and compliance markets.
07:53And if I just unpack slightly what I mean by that, voluntary markets are ones where
07:59buyers of ecosystem services or natural capital credits or however you want to refer to them,
08:06where those buyers don't have legal obligations to do that, but they're choosing to do so
08:13to support their net zero trajectories or their wider ESG strategies.
08:18So a good example of that is carbon credits and, for example, projects that are being
08:24delivered under the Woodland Code or the Peatland Code. If you contrast those voluntary markets with
08:30compliance markets, those are ones where buyers have got actual legal obligations to secure
08:35credits. And a really good example of that in the UK at the moment is the new mandatory biodiversity
08:42net gain regime that has come in in England. It's not yet a requirement for Scotland,
08:47but it is a big hot topic in England at the moment.
08:52And as Ross said, we've seen a real upswing in activity in nature-based capital markets in the
08:59UK in the last few years, and that's both in the compliance markets and also in the voluntary markets.
09:07I think that's exactly right, Sarah. And I think this whole question around sustainability has
09:13become a concern across all sectors and all industries. And the expectation is for everyone,
09:19whether it's landowners or corporates or whoever, we all need to deliver against
09:23environmental objectives alongside our core business activities. So that's
09:28really bringing a focus on to nature markets. Thank you. And we're all aware of the race to
09:35net zero and deadlines getting closer. So how big a role do nature-based solutions
09:40and capital markets have to play in that journey to net zero, particularly in Scotland?
09:45I'll maybe come in on that. I mean, we're very lucky in Scotland that we have
09:51a landscape that's set up quite well to get us to net zero. I'm talking, of course,
09:55about offshore wind, onshore wind, all the work that we're doing in that area. But
10:01natural capital and natural capital markets also have a huge part in that and a growing part in
10:07that. It's very important to have a mix of different ways to get to net zero. We're not
10:13going to get to net zero simply through offshore wind alone or onshore wind alone. We have to have
10:19that mix. And the market's realising that up here, that more and more often now we're seeing
10:26landowners are particularly interested in this. There's investors that are looking at it and also
10:30funders. So everybody's really converging on this market. And I think over the next 10, 15 years,
10:37it's going to play a growing and increasingly large part in that mix.
10:42Okay. And with it being a growing market, I take it that, as well as giving opportunities,
10:47it opens up challenges as well. So could you maybe cover some of the challenge and
10:50opportunities presented by nature-based capital markets and their growth?
10:55I think opportunities are, there's various opportunities. Lots of organisations these
11:02days, and particularly some of the blue chips that we see and act for, they're under increasing
11:10pressure from their own investors and their own stakeholders to prove that they're
11:15doing more than greenwashing. It's more than talk to actually get to net zero.
11:19And these markets really help to demonstrate that they're involved in the journey to net zero.
11:27In terms of opportunities, there's quite a few. It's a new market. It's a market that's
11:33changing all the time, developing all the time. And that brings challenges. I'll talk in a minute
11:39about a deal that we've done with 25-year funding to invest in this. And actually,
11:46doing that, you're not quite a leap of faith, but you are taking a view on how markets might
11:53develop and what might change over time. So change is a good thing, but it's also a challenge for
11:59some funders and investors as well. And that's important to keep an eye on. And the other
12:05challenge, I guess, is Scotland, as in many things, in net zero, in some ways, we're leading
12:12the way. But it's an international market. There's opportunities for investors increasingly across
12:20the globe. So we need to make sure that what we are doing is intelligible to landowners,
12:27investors, funders, but also that it remains attractive because other jurisdictions will
12:34start moving on this soon as well. I'm sorry, I was just going to say, on the landowner side,
12:39there are definitely challenges and opportunities as well. The key opportunities that are often
12:44cited for the landowner is the ability to provide, each markets have this ability to provide
12:51alternative income stream, just with, you know, tapering down and disappearance of BPS and what
12:58might become of, you know, the kind of subsidy regimes that are available publicly and the fact
13:03that nature markets does have the potential to provide a bit of a financial solution and plug
13:10that particular gap. And it also provides an opportunity for landowners to do something with
13:16marginal or unproductive land that might otherwise not have a viable use within a kind of an
13:24agricultural estate or farmland entity. And then, sorry, on the challenges side,
13:32one thing that is definitely a concern for landowners would be the tax treatment that's
13:39associated as well. It's really important to consider from a landowner perspective that if you
13:45do start using land in different ways, that that could impact in some unexpected way on tax
13:52treatment. So it is definitely a need, there's a gap there at the moment for some additional HMRC
13:59guidance on some of this, but it's definitely something for landowners to be aware of.
14:06And I can finish us off on this one with my perspective on challenges and opportunities,
14:11but I'll flip it around and be positive first. So in terms of opportunities, I think for
14:16corporate buyers and investors, so the people who are going to be doing the buying in these
14:22natural capital markets, Stuart touched on the sort of the drivers from investors and stakeholders
14:30for sort of being ESG positive and getting involved in these types of projects and walking
14:38the walk rather than just talking the talk or greenwashing. What I'd add on that is that for
14:45lots of corporate buyers or investors, it's not just stakeholder expectation. There are some
14:51hard-edged legal obligations that are going to be driving their involvement in these types of
14:59projects, their investment in these types of projects. There are more and more organisations
15:04that through various different legal mechanisms are coming within the scope of having to make
15:09mandatory disclosures and reporting around carbon emissions. So the TCFD, Task Force on Climate
15:17Related Financial Disclosures is becoming a mandatory standard for more and more people.
15:22There's an equivalent nature standard, another acronym, TNFD, Task Force for Nature Related
15:27Financial Disclosures, which isn't yet mandatory, but lots of consultation going on in various parts
15:32of the UK around making that mandatory for some people. So it's those types of actual hard-edged
15:38legal obligations which are driving an opportunity for corporate buyers and investors through
15:46engagement in nature markets to meet those obligations and to put themselves really on
15:51the front foot and being able to make really good reports and disclosures. So that's what I'd say on
15:57the opportunity side for them. I think another key opportunity we're seeing is for brokerage
16:02businesses. So organisations, particularly those that can successfully draw on sort of true
16:09ecological expertise to position themselves in the market as introducers between those corporate
16:15buyers and investors who are wanting or needing to buy carbon credits, et cetera, on the one hand,
16:23and then the landowners on the other. There are some circumstances we're seeing where your landowners
16:29and buyers are coming together themselves without needing a middleman, but I'd say the majority of
16:34what we're seeing, you are having brokers of varying shapes and sizes getting involved. So
16:39there is definite early mover advantage for people who are looking to set themselves up as
16:43brokers in these new markets. On the challenges side of things, the less positive bit, I think
16:52I'd pick out two points which are drawing on things I think we've all talked about before. But firstly,
16:58the uncertainty in the market. As we've said, the whole market is relatively nascent.
17:03Some areas are definitely more advanced than others, but even in those more advanced areas,
17:08your regulation and your guidance and your principles are often lagging behind market
17:13activity and market appetite. And that then leads on to the second key challenge, which I'd pick out
17:18is integrity in the market, where you've got these nascent and rapidly growing markets where
17:24activity is moving ahead of policy and regulation. They can be vulnerable to participants who lack
17:30integrity. There have been a number of stories in the press, I think, focused more on what's going
17:36on in other global jurisdictions than in Scotland or the UK, but certainly lots of stories about
17:42some carbon credit schemes which aren't representing genuine carbon reductions and
17:47then associated allegations of greenwashing going along with that. And the challenge is that poor
17:54practice by a minority can undermine confidence in the wider market and poor practice in one
18:01natural capital market like carbon can undermine confidence in other new emerging markets like
18:06biodiversity markets. Thank you all and thanks Sarah. It's an interesting point in regulation,
18:11I was going to ask about that, where we are with regulation and what you think has to come next to
18:15protect people and protect the reputation of the whole sector as a growing and fairly new market.
18:21Yeah, so I think if I start on that one, I think it's true to say that the markets that we have
18:29in the natural capital space in Scotland are voluntary, they aren't underpinned by regulatory
18:37requirements. What that then feeds into is those challenges that we were just describing around
18:47uncertainty on exactly where they're going and concerns around integrity. We're seeing a lot of
18:54work at the moment by various different bodies on developing standards for different types of
18:59nature markets. You don't have one single standard that is the rubber stamped gold star that can be
19:09box ticked, this is a good scheme to go for, but you do have different ones that are
19:14emerging. I also know that the Scottish Government I think is preparing at the moment
19:22a natural capital market framework for publication this year, although we'll see what happens with
19:27that amidst other political goings on, but the intention of that framework is to provide
19:34guidance for those who are seeking to enhance Scotland's natural capital through private
19:38investment. So that I think is going to be really interesting to see what comes through there,
19:44what is said about that, because there are challenges where you have got markets that
19:49are evolving ahead of regulation. On the one hand it gives them the space to be innovative and to
19:56evolve and to go with demand, but on the other hand there are the other risks and issues that
20:02we've been talking about. You're listening to the sustainable Scotland podcast. This episode
20:07is brought to you in partnership with law firm Bruges Salmon. If you'd like to discuss partnering
20:10with the Scotsman for an episode of Sustainable Scotland, please email podcasts at scotsman.com.
20:15Now back to the episode focused on natural capital, sustainable land use and nature-based
20:19solutions with Bruges Salmon. Can you give me examples of projects and activity in nature-based
20:23capital markets in Scotland in recent years and the wider UK, but also we're very interested in
20:27what's happening here in Scotland? Absolutely, I'm very happy to take that one, to get going
20:33with that one. We've been kept really busy, lots of really exciting projects, a real standout
20:38Instruction for us has been acting for oxygen conservation. They're an
20:44organisation that's all about tackling climate emergency and biodiversity collapse through the
20:50purchase and management of land and in doing so protecting and restoring natural processes
20:56and over the course of, gosh, the last 24 months we've helped them acquire 10 estates across
21:03Scotland, England and Wales spanning nearly 30,000 acres and they are an example of an organisation
21:12becoming a landowner, buying large-scale rural land holdings with a view to and intent on
21:19protection and restoration of natural processes. On each site they're looking to restore and manage
21:26habitats and also deliver positive environmental and social impacts to
21:34two major holdings that we've acted on for them in Scotland would be Invergeldie Estate
21:39which is near Comrie in Perthshire and then Hartsgarth, part of Langham Moor, both estates covering
21:45more than 22,500 acres. Stuart, you've then been involved with them too?
21:52Yeah, I might be coming on that, so as part of that and acting for oxygen conservation
21:58we did what we think is the largest nature-based financing to occur in the UK to date and that was
22:06a 20 million loan from Truris Bank to assist Oxygen in purchasing the two sites so
22:13Invergeldie and Langham Moor that Ross mentioned and that's 25 years of debt from
22:21from Truris and it's a really interesting transaction. It was a
22:24kind of first in the market to actually structure something that worked for a funder who
22:30obviously wants to be repaid over that 25-year period but was also flexible enough to allow
22:37Oxygen to look at the sites and decide how best to make things work at these sites
22:46and to derive some form of income from them and taking account of the fact that that might
22:51actually change over time as they get to learn about the sites but also as the market develops
22:57so it's a really interesting transaction, really collaborative working with Triodos,
23:01Oxygen and the other sets of advisors as well so it's quite a fulfilling deal to work on.
23:08I can give an example from my neck of the woods as well and one I would pick out as a nice Scottish
23:16project has been that we've been working with a major player in UK forestry who's got a
23:22significant footprint in Scotland and what we've been doing with them is to develop their carbon
23:28offsetting brokerage scheme which as I was describing earlier it's a matchmaking service
23:34of introducing landowners to corporates to help offset carbon through tree planting and the
23:41particular work that we were doing with them was designing and then drafting and negotiating the
23:47contracts which align with the Woodland Carbon Code and its requirements and principles so for
23:54example looking at topics like validation and monitoring of the planting scheme and verification
24:00of the carbon sequestration that's been achieved and the credits that are generated and traded
24:05so seeking to use the legal agreements underpinning the scheme to drive and to
24:12give assurance around the integrity of the projects involved so that again has been a
24:17fantastic one to be involved with. Thank you, some great examples of what's happening in Scotland
24:22there and across the UK and this is a fairly big question but we can cover some of the points in
24:27terms of what should both landowners and corporate buyers and investors consider when looking to
24:32broaden their natural capital portfolios and it will vary with individuals and examples but is there
24:38any sort of key points people should be thinking about? I guess I should start maybe with my land
24:44owner hat on and yeah I think a really important starting point for landowners is to think about
24:51data and the importance of really good data. I think this is a crucial part of ensuring that
24:58what we are creating, what is emerging, is a high integrity natural capital market. It's important
25:05that landowners are baselining appropriately the sites that they're using for these types
25:11of projects and that we can measure the difference that is being made by these projects as well and
25:18that we're measuring that appropriately. It's really important to remember you know these are
25:23really multi-generational projects, they're going to last for a number of years and that robust
25:30comprehensive baseline assessments are really important regardless of the type of project
25:36and the scheme. I think that's a really good starting point for landowners. I think another
25:43thing to be mindful of as well is maybe be careful who you're selling to and the profile of some
25:50investors or partners that landowners might wish to transact with to deliver some of these projects.
25:55As we mentioned the integrity of these markets is under scrutiny and will come under increasing
26:00scrutiny and so yeah there are reputational matters to be thinking about. Then be careful
26:07about how much you're selling as well because landowners and organisations and farmers need to
26:15be careful that they retain as well for their own carbon footprints and maybe for their own
26:22supply chain requirements that they're not selling more than they actually need to retain for their
26:26own business needs. I think finally if land is tenanted that adds a whole other dimension as
26:35well in terms of well who is responsible for the project delivery, what happens to the revenue that's
26:41generated from a project as well and what are the sharing mechanisms that might be associated with
26:45there. So that's a few things in the mix for landowners to be thinking about. Yeah some good
26:50points for landowners and sounds quite a lot of them to balance as well when considering what to
26:53sell, how much to sell and everything else involved. Thank you Ross. Shall I chip in first on the
27:00corporate side and in the same way as on the landowner side there's an awful lot that
27:05corporate buyers and investors should be thinking about when they are approaching a natural capital
27:09deal. The absolutely fundamental consideration has got to be how a particular natural capital
27:15opportunity will align with the corporate or the investor's ESG strategy and priorities.
27:23How is it going to help them? Is it as aligned as it could be? I'll pick out three other
27:32what would be my sort of top three things to be thinking about at the moment.
27:37Firstly and again we're sounding a bit like a broken record but integrity. Corporates should
27:42be looking to buy environmental credits from or otherwise getting involved in financing for nature
27:48based solutions projects which are going to deliver genuine lasting and additional environmental
27:55improvements. They need to be robustly verified and transparently documented with no double
28:01counting or room for misleading claims or greenwashing. The key question for corporates
28:08to be asking is how is the landowner or the broker that they're dealing with going to satisfy
28:14the corporate of the integrity of the scheme? What is the, as Ross said, where's the data?
28:19How are you going to be able to demonstrate that robustly? The second top tip I'd have is
28:27thinking about the payment structures. So how are the financial aspects of the arrangement going to
28:33work? What will the corporate be paying the landowner or the other project delivery body or
28:38habitat bank for? Is it for the provision of ecosystem services? Is it for the provision of
28:44credits? Or is it for a combination of the two? How frequently and at what points are payments
28:51going to be made? For example is there going to be an upfront one-off payment at the start to the
28:56landowner? Or will it be drip fed in installments over the lifetime of the project? And then more
29:04negatively who's going to bear the financial risk if the project fails or if it needs reinstatement
29:09after a catastrophic event like a fire or a flood? The final key thing to think about, and again this
29:16links back to points we were making earlier, is change provisions. As we've been saying throughout
29:24natural capital markets are still nascent and there's scope for a lot to change in the coming
29:30years. For example through increased regulation of the markets potentially and there are undoubtedly
29:39advantages to being early movers and early promoters of voluntary natural capital markets.
29:45But this has to be balanced against the uncertainties of a developing market and it's
29:49really important for corporates to think about how they want change to be dealt with under their
29:54agreements. Both legal change and practical change on the ground given that many nature-based
30:01solutions contracts are going to be very long-term arrangements given the nature of the
30:06projects and the time it takes for them to deliver the benefits they're designed for.
30:11I think those would be my key points. Stuart have you got anything you would
30:15add to round us off? Yeah and as a funding side there's not actually
30:20too much to add to that. A lot of the things that you in particular spoke about
30:25Sarah are the same when you're considering funding. It's really what do you need the
30:30funding for? Is it to buy land? Is it to carry out some form of remediation or something else?
30:38And then the obvious question in funding is how are you going to repay? What's the structure?
30:44What are the cash flows that come out and how is that going to convince a funder that
30:51this is a good investment for their money? And it really comes back to what Ross said at the
30:58top of this question which is it's all to do with data. It's having good data that you can
31:03show to somebody that tells a story and demonstrates that what you have here is
31:08something that's worth going for. Thanks everyone on some good points here for investors,
31:15for buyers, for funders. That sounds really useful. I'm drawn to close now. Is there anything
31:21else we've covered? Lots to do with natural capital and nature-based solutions. It's
31:24very interesting. Is there anything you think we haven't covered yet you would like to add?
31:30I think just from my side it's a really exciting time to be part of this new emerging market and
31:37certainly as a real estate lawyer seeing land as an opportunity to provide a lot of the answers
31:44and to solutions to some of the biggest problems that we face around nature and biodiversity
31:50crisis and climate change. And gosh with all this market growth I heard somebody recently say the
31:56world is suddenly finding it short of ecologists that are so very much needed to underpin a lot
32:03of this and doing all the baselining, getting all that good robust data that we need to do high
32:09integrity projects. And I think just on the whole green, I know we've talked about integrity a lot
32:13in greenwashing and yes there will be concerns out there about greenwashing. I think Dr Rich
32:19Stockdale of auction conservation writes a really good paper on some of this and talks about the
32:24risks associated and market manipulation potential and price volatility. But the reality is that
32:32in this era of global boiling as the UN describes it, environmental credits are going to have a
32:41part to play and you've got existing markets for this stuff voluntary and certainly complies maybe
32:47not as big in Scotland but definitely in England. And whilst nobody can predict the future the best
32:52educated guesses are that these markets are here to stay. Thank you very much for listening to
32:57today's episode in Sustainable Scotland series produced by The Scotsman. This podcast was
33:02delivered in partnership with law firm Bruges Salmon. Please listen out for and enjoy more
33:06episodes of Sustainable Scotland on all your main podcast platforms. This episode is presented by
33:11me Rosemary Gallagher and produced by Andrew Mulligan.