Sarah Benabou

Making Up for Lost Nature? A Critical Review of the International Development of Voluntary Biodiversity Off sets

Keywords: biodiversity, conservation, market framing, measurement, mining, standard, uneven development, voluntary biodiversity of sets

h is article analyzes the international development of voluntary biodiver- sity of sets, a conservation instrument that permits developers to pursue their activities if conservation actions are undertaken elsewhere to compensate for the environmental impacts of their projects. Largely undertaken by extractive industries that operate in the global South where no of setting regulations exist, this tool is currently attracting growing interest from policy makers, private companies, i nancial institutions, and conservation experts. Building upon the concept of market framing developed by Callon (1998), I explore in what contexts and through what processes this idea has gathered momentum, as well as the disturbing gap between the way it has been framed and its practical implementation. It is suggested that once immersed in the outside world, the market framing of of sets appears as a fragile result dependent upon substantial investments, which casts serious doubts about of sets' ability to reduce biodiversity loss on technical, governance, and social grounds.

Introduction

In 2004, the launch of a report (ten [START_REF] Ten Kate | Biodiversity Of sets: Views, Experience and the Business Case[END_REF]) put out jointly by the International Union for the Conservation of Nature and Insight Investment, one of the United Kingdom's largest investment management companies, propelled the idea of "biodiversity of setting" to the forefront of the global conservation scene. Entitled "Biodiversity Of sets: Views, Experiences and the Business Case, " this document enshrines this conservation tool as a way of maintaining biodiversity levels while at the same time permitting development. Simply said, the destruction of one habitat would be "of set" by the conservation, restoration, or creation of another. h is is an attractive proposition for policy makers, business entrepreneurs, environmental consultancies, and conservation groups alike, of ering the promise of resolving the ot en conl icting aims of providing for more infrastructure development while at the same time conserving the world's shrinking biodiversity (e.g., [START_REF] Kiesecker | A Framework for Implementing Biodiversity Of sets: Selecting Sites and Determining Scales[END_REF][START_REF] Rajvanshi | Reconciling Conservation and Development: the Role of Biodiversity Of sets[END_REF].

Over the past ten years, the idea of biodiversity of setting has thus experienced rapid success. Pioneered in the United States in the 1990s [START_REF] Robertson | h e Neoliberalization of Ecosystem Services: Wetland Mitigation Banking and Problems in Environmental Governance[END_REF], legislation mandating compensatory mitigation programs (including of sets) now exists in 45 countries and is under development in another 27 [START_REF] Madsen | State of Biodiversity Markets Report: Of set and Compensation Programs Worldwide[END_REF]). Meanwhile, the potential of voluntary biodiversity of sets has attracted growing interest from corporate actors, fuelled by the emergence of a dedicated i nancial sector that has framed biodiversity loss as a material risk to the "bottom line" of i rms, especially those who operate in the global South [START_REF] Dempsey | Biodiversity Loss as Material Risk: Tracking the Changing Meanings and Materialities of Biodiversity Conservation[END_REF].

If biodiversity of sets are an increasingly popular tool, they are also fraught with controversy. Of sets are conservation activities that are carried out in order to counterbalance adverse environmental impacts of development projects, within the overall goal of "no net loss", or, preferably, a "net gain" of biodiversity (BBOP 2012). h e controversy lies precisely in the trade-of that this implies: accepting ecological losses in return for uncertain gains [START_REF] Bull | Biodiversity Of sets in h eory and Practice[END_REF]. Some environmental nongovernmental organizations (NGOs) are concerned that biodiversity of sets could thus be treated as a "license to trash" nature, by allowing the continuation of projects at the potential expense of biodiversity (e.g., [START_REF] Howarth | A License to Trash? Why Biodiversity Of setting (BO) Will Be a Disaster for the Environment[END_REF].

It is thus not surprising that the issue of biodiversity of sets has been widely addressed in the academic literature, particularly in the i elds of biology and ecology. However, the subject has not yet attracted great interest among social scientists (for notable exceptions, see [START_REF] Robertson | No Net Loss: Wetland Restoration and the Incomplete Capitalization of Nature[END_REF][START_REF] Robertson | h e Neoliberalization of Ecosystem Services: Wetland Mitigation Banking and Problems in Environmental Governance[END_REF][START_REF] Robertson | h e Nature h at Capital Can See: Science, State, and Market in the Commodii cation of Ecosystem Services[END_REF][START_REF] Robertson | Measurement and Alienation: Making a World of Ecosystem Services[END_REF][START_REF] Sullivan | Financialisation, Biodiversity Conservation and Equity: Some Currents and Concerns[END_REF][START_REF] Sullivan | At er the Green Rush? Biodiversity Of sets, Uranium Power and the 'Calculus of Casualties' in Greening Growth[END_REF]. It is beyond the scope of this article to cover all of the many issues that have been addressed in the literature, 1 but it should be noted that the situations of biodiversity of setting that have been discussed cover mainly regulatory contextsmost notably the United States and Australia. h ese countries, along with some others, have the particularity of having introduced a trading element into the of setting mechanism through a "habitat banking" scheme. In this case, conservation banks (i.e., parcels of lands managed for their conservation values) are created. In exchange for permanently protecting the land, the bank owner (the government, the developer, or an entrepreneur) is allowed to sell "credits" (of sets) to parties who need them to satisfy legal requirements for compensating the environmental impacts ("debits") of their development projects [START_REF] Carroll | Conservation and Biodiversity Banking: A Guide to Setting Up and Running Biodiversity Credit Trading Systems[END_REF]. Examples include systems such as Wetland Banking in the United States (NRC 2001) and BioBanking in Australia (DECCW 2009). Habitat banking is an institutional arrangement that is ot en dei ned as a "market-based instrument" [START_REF] Et Ec | h e Use of Market-Based Instruments for Biodiversity Protection: h e Case of Habitat Banking[END_REF] and is considered more cost-ef ective than traditional "command-and-control" approaches, where of sets need to be designed and implanted on a case-by-case basis.

h e market logic behind habitat banking has been particularly pervasive in the development of voluntary biodiversity of sets. h eir multiplication in recent years has indeed been largely prompted by the 2004 report, which develops in great detail what is now commonly referred to as the "business case", that is, the idea that there is something to be gained for the i rm that undertakes an of set. However, despite the steady growth in the number of companies with "no net loss"-type commitments over the last ten years (TBC 2012), very little has been said in the academic literature about what biodiversity of setting could cover in such voluntary situations. In what context and on what grounds have these corporate commitments emerged? How has the concept of biodiversity of sets been coni gured and circulated to gain traction among corporate leaders? Why, despite these developments, does the implementation of voluntary biodiversity of sets on the ground remain limited? h is article attempts to give possible answers to these questions (and to leave open those that remain to be addressed in future research) by providing a synthesized critique of the international development of voluntary biodiversity of sets, based on a review of the relevant literature, ranging across a spectrum of academic articles, gray literature, and policy documents.

Genealogies of the Corporate "No Net Loss" Strategy h e Recognition of Biodiversity Loss as a Business Risk

In a joint workshop organized in July 2003 by the International Union for Conservation of Nature (IUCN) and the International Council on Mining and Metals (ICMM), the participants agreed "to explore the use of biodiversity of sets in recognition that there may be a point at which investment in biodiversity of sets provides greater social, environmental and economic benei ts than trying to mitigate all impacts" (ICMM 2005: 2). h is initiative, entitled "Mining, Protected Areas and Biodiversity Conservation: Searching and Pursuing Best Practice and Reporting in the Mining Industry, " was held in the IUCN headquarters in Switzerland. Several of the participants were to become major thinkers in the development of biodiversity of sets at the international level: Kerry ten Kate (director of investor responsibility, Insight Investment), David Richards (principal adviser in environment, Rio Tinto), Assheton Stewart Carter (chief advisor for business practices, Conservation International), Martin Hollands (deputy director, Flora and Fauna International), and Mohammed Rai q (leader of the IUCN biodiversity dialogue with the mining industry), among others. As far as the mining sector is concerned, 2 it seems that this was the i rst time that the issue of biodiversity of sets had been oi cially put on the table for discussion, even if the ground had been prepared beforehand.

Since the mid-1990s, in order to improve its image linked to its social, economic, and environmental footprint, the mining industry has indeed engaged in dialogue with environmental and social organizations in order to determine how to address these challenges (ICMM 2005). In 1999, nine of the largest global mining corporations, under the impetus of the Rio Tinto chairman, joined together to launch the Global Mining Initiative (GMI). If the oi cial intention was to develop the contribution of the mining sector to the transition toward sustainable development, the real motives were much more pragmatic. According to Dr. John Groom, an oi cial of Anglo American, "the drivers for GMI were clear recognition that mining companies had problems of access to land, and access to markets, and cost of capital. h e fundamental underlying reason was the reputation of the industry. To tackle this we would have to work with others and also improve the way we worked" (Buxton 2012: 7). h e following year, the GMI started a process of consultation and research known as the Mining, Minerals and Sustainable Development (MMSD) project to determine the fundamental orientations that would shape the future of the industry. h is project led to the creation of the ICMM in 2002. A few months later, at the Johannesburg World Summit on Sustainable Development, the ICMM and the IUCN started a joint dialogue on mining and biodiversity "to provide a platform for communities, corporations, NGOs and governments to engage in a dialogue to seek the best balance between the protection of important ecosystems and the social and economic importance of mining" (IUCN 2003: 1). h e 2003 workshop was part of this dialogue. h e mining industry was, however, under tremendous pressure to make progress on this issue of "residual" impacts on biodiversity. h e same year as the IUCN/ICMM workshop, the World Resources Institute published a report indicating that three-quarters of active mines and exploratory sites overlapped with areas of high conservation value [START_REF] Miranda | Mining and Critical Ecosystems: Mapping the Risks[END_REF]. h e next year, Earthworks and Oxfam launched the "No Dirty Gold" campaign, accompanied by a critical report against the mining industry, Dirty Metals: Mining, Communities and the Environment (2004). h is latest attack prompted a coordinated response on several fronts. On the one hand, the ICMM immediately responded by insisting on the fact that this report failed to take into account its commitments made during the MMSD process (ICMM 2004). On the other hand, Kerry ten Kate undertook a series of interviews with major industrial players to clarify the concept of biodiversity of sets and make it relevant for business. h is led to the publication at the end of 2004 of the report on the "business case" for biodiversity of sets, and to the creation of an organization dedicated to its development worldwide, the Business and Biodiversity Of sets Programme (BBOP). Meanwhile, the h ird IUCN World Conservation Congress in Bangkok witnessed the intensii cation of IUCN's engagement with the private sector (IUCN 2006). At this very congress Rio Tinto launched its biodiversity strategy, where it committed itself to have a "net positive impact" on biodiversity (Rio Tinto 2004), thus putting itself at the vanguard of the mining sector on this question.

h e US Experience

Biodiversity of setting was, however, not terra incognita for the business and conservation community. In the United States this idea emerged in the late 1970s and was oi cially enshrined as a biodiversity of sets market in the early 1990s. Participants in the IUCN/ICMM workshop thus had experiences to draw upon, even if the particularly regulated situation of biodiversity of sets in the United States cannot be transposed term-for-term in other biodiversity-rich countries where mining companies operate and where no such regulation exists. h is experience has nonetheless largely "captured the imagination of those who promote market-led environmental policy" (Robertson 2006: 372), especially in the way it has framed biodiversity of sets as a useful tool to ensure competitiveness and make conservation "work for capitalism".

According to Morgan [START_REF] Robertson | No Net Loss: Wetland Restoration and the Incomplete Capitalization of Nature[END_REF], the idea that nature destroyed in one place could be compensated by a similar natural habitat restored or created elsewhere was i rst developed during the 1970s in wetland policy. During this decade, two amendments to the Water Pollution Control Act of 1948 were passed to stop the unregulated destruction of these ecosystems. In 1972, the Army Corps of Engineers was given the authority to issue or deny permits for the i lling of wetlands, while the Environmental Protection Agency (EPA) had a veto power over these permits. Five years later, wetlands were explicitly mentioned as a protected category by stating that mitigation (i.e., restoration or creation) of wetlands was only to be considered as a last resort, once strategies of avoidance and minimization of impact had been considered. However, due to a lack of clarity about the specii c division of responsibility between the various governmental agencies supposedly in charge of executing this law (generally known as the CWA, the Clean Water Act, from 1972 onward), friction between them developed, with the result that the mitigation hierarchy was not, in fact, enforced [START_REF] Robertson | No Net Loss: Wetland Restoration and the Incomplete Capitalization of Nature[END_REF]. Developers were invited to proceed directly to restoration or creation of wetlands to compensate for their impact, with the consequence that, even if the slogan of "no net loss" had not yet been invented, "it can be used to describe the informal compromise worked out in the 1970s between institutions, unwilling partners in carrying out the awkward rules generated by the CWA" (Robertson 2000: 471). At the request of President Reagan's Council on Competitiveness, a national forum was convened by the EPA in 1987 in order to clarify federal wetlands regulation. h is forum led to the transformation of the de facto situation into a de jure institutionalization through the adoption of the slogan "no net loss of wetlands" (Robertson 2000: 471). h e following year, this term was popularized by the presidential campaign of George H. W. Bush, who pledged to ensure no net loss of wetlands "to shore up a dismal environmental record" (Robertson 2000: 471).

As one might expect in relation to a slogan adopted by the Council on Competitiveness, the policy that was shaped introduced greater l exibility into the regulation itself by permitting restoration/creation elsewhere, where the cost is lower. Beyond this mechanism of l exibility based on the postulate of an ecological equivalence between disparate locales, another element in this project was to open up the i eld to the growth of a private sector conservation business. For, now, any landholder could become an ecological restoration entrepreneur, a so-called nature banker, and sell credits to clients. A developer can thus choose, in the specii c service area where s/he operates, the bank from which s/he wants to buy credits. Launched in 1991, this new biodiversity of set market developed rapidly, starting originally with wetlands and extending in 1995 to protected species. Today, there is a total of 1,044 active and sold-out wetland, stream, and conservation banks that account for the greatest volume of payments and area in the global biodiversity market, bringing in $2.0-3.4 billion and covering over 15,000 hectares (37,700 acres) annually [START_REF] Madsen | State of Biodiversity Markets Report: Of set and Compensation Programs Worldwide[END_REF].

h e United States' of setting legislation was inevitably a point of reference for the actors engaged in the development of voluntary biodiversity of sets in the global South. It was, however, thought that "the legally mandated and tradable of sets (such as those that are emerging in the USA) … will probably not be feasible in the short to medium term in most of the countries that hold the majority of the world's biodiversity" (ten Kate et al. 2004: 82). Central to the actors' concerns was what to do in countries where of sets are not legally mandated-how to build up voluntary of sets robust enough to save companies from potential adverse campaigning by local communities and national and international NGOs for poor biodiversity management (ten [START_REF] Ten Kate | Biodiversity Of sets: Views, Experience and the Business Case[END_REF]. It thus took a decade or so (from the mid-1990s to the mid-2000s) for this conservation instrument to become institutionalized in the rapidly growing i eld of "business and biodiversity", through a triple process of (1) alignment of corporate executives, senior actors in conservation organizations, and bureaucrats, (2) articulation through multiple "dialogues" and publications, and (3) orchestration in major conservation meetings. To understand how the concept of biodiversity of sets has gained traction in such a short period, I turn now to its coni guration and circulation in relation to particular interests and the forms that make it relevant for business.

Biodiversity Of sets in the Art of Market Framing

Building Blocks

Contemporary debates on appropriate biodiversity conservation policy have seen the emergence and consolidation of a "neoliberal conservation" paradigm [START_REF] Igoe | Neoliberal Conservation: A Brief Introduction[END_REF][START_REF] Igoe | A Spectacular Eco-Tour Around the Historic Bloc: h eorizing the Convergence of Biodiversity Conservation and Capitalist Expansion[END_REF][START_REF] Büscher | Towards a Synthesized Critique of Neoliberal Biodiversity Conservation[END_REF] based on the premise that the target of halting biodiversity loss will only be achieved by subordinating environmental conservation to capitalist logics and associated market mechanisms, for instance, through commodii cation and trading of ecosystem services (McAfee 2012). Biodiversity of sets, I suggest, draw much of their legitimacy from their recent realignment with this dominant discourse on sustainability. h e upsurge of interest in many countries and among many NGOs and businesses for this instrument over the last ten years, it seems, has indeed been largely driven by the way it has been framed as a potential market-based mechanism (or at minimum a mechanism for pricing certain negative environmental externalities within development projects; see [START_REF] Bull | Biodiversity Of sets in h eory and Practice[END_REF], which supposedly ensures its economic ei ciency. h e sociologist Michel Callon uses the notion of "framing" to show how economic actors identify externalities as exceptions "that must be contained and channeled with the help of appropriate investments" (1998: 250). h is section takes the notion of market framing to qualify some of the processes-both the products of discursive reconi gurations and crystallization of relations between particular sets of actors-through which biodiversity of sets have come to gain such central importance in international debates on conservation.

In his analysis of the conditions required for the existence of markets, [START_REF] Callon | An Essay of Framing and Overl owing[END_REF] borrows the concept of "framing" from Gof man (1974). h e process involves the demarcation of a "stage" that has been specially prepared and upon which the actors involved are capable of agreeing. "To negotiate a contract or perform a commercial transaction, " Callon argues, "ef ectively presupposes a framing of the action without which it would be impossible to reach an agreement, in the same way that in order to play a game of chess, two players must agree to submit to the rules" (1998: 250, emphasis added). h e role of the players' mutual agreement in creating this closed interactional space is indeed essential in that it clarii es "the frame within which their interactions will take place and . . . the courses of action open to them" (Callon 1998: 249).

h is concept of framing is helpful to understand how the emergence of biodiversity of sets carries a particular coni guration of the conservation ef ort. Consider this quote from Joseph Kiesecker, scientist for the Nature Conservancy (TNC):

Between one-third and one-half of Earth's land surface has been altered by human action, resulting in an unprecedented loss of biodiversity. … Looking forward, such impacts could increase dramatically: the global economy is expected to double by 2030, and unprecedented investments are being made in resource development to support this growth, especially in developing countries. Given the importance of economic development for improving human well-being, there is greater pressure to i nd ways to balance the needs of development with those of biodiversity conservation. Biodiversity of sets are one important tool for maintaining or enhancing environmental values in situations where development is sought despite detrimental environmental impacts. (Kiesecker et al. 2009: 77) h e "stage" set here is that of a world where economic growth is seen as both desirable and inevitable, and thus where the course of action, as far as conservation is concerned, is to accompany this growth by managing its ecologically damaging side ef ects. It is quite striking to notice how such a statement is radically dif erent from the once widely shared idea that conservation is about saving lands from development. Instead, it acts as an invitation for conservation experts to accommodate the needs of capitalism, that is, to assist developers in proceeding with their large projects, accompanied by some sort of proper compensation.

h is framing of a "development/market-led" conservation is now largely considered in the international conservation milieu as the norm, in the double sense of something that is desirable and also (increasingly) statistically predominant. A peculiarly privileged vantage point to observe the pregnancy of this reasoning is constituted by international conservation meetings such as the 2008 World Conservation Congress or the 2010 Conference of the Parties to the Convention on Biological Diversity (CBD). As has been noted by scholars, the message constantly emphasized is that capitalism is the key to our ecological future [START_REF] Igoe | A Spectacular Eco-Tour Around the Historic Bloc: h eorizing the Convergence of Biodiversity Conservation and Capitalist Expansion[END_REF]Mac-Donald 2010;[START_REF] Macdonald | TEEB Begins Now': A Virtual Moment in the Production of Natural Capital[END_REF]. In particular, these venues have been the sites of the emergence and consolidation of powerful discursive claims that market-based instruments, when suitably framed by expert and technical knowledge, constitute the most robust alternatives to command-and-control or community-based approaches, which are widely seen as having proved their inadequacy in practice. A good example of these claims can be found in an article written by Peter [START_REF] Kareiva | Conservation in the Anthropocene: Beyond Solitude and Fragility[END_REF]. h e future of conservation, says Kareiva, the chief scientist for TNC, does not lie in "preserving islands of Holocene ecosystems in the age of the Anthropocene, " but should take into account to a much larger degree the transformation of the rest of the landscape through mining, damming, logging, intensive agriculture, and urbanization [START_REF] Kareiva | Conservation in the Anthropocene: Beyond Solitude and Fragility[END_REF]. h e challenge ahead is to explore "the right kinds of technologies" that could enable these landscapes to support healthy ecosystems and to contribute to the prioritization of "economic development for all" [START_REF] Kareiva | Conservation in the Anthropocene: Beyond Solitude and Fragility[END_REF]. "Instead of scolding capitalism, " he concludes, "conservationists should partner with corporations in a science-based ef ort to integrate the value of nature's benei ts into their operations and cultures" [START_REF] Kareiva | Conservation in the Anthropocene: Beyond Solitude and Fragility[END_REF].

Market-based approaches to conserving nature are not new, but they have clearly gained new impetus at er a 2010 initiative entitled the Economics of Ecosystems and Biodiversity (TEEB). h is international initiative promotes a new economy, "one in which the values of natural capital, and the ecosystem services which this capital supplies, are fully rel ected in the mainstream of public and private decision-making" (TEEB 2010). h e basic premise is that, in order to properly protect nature, it must be given a "value". h is usually means creating methods to measure ecosystems and biodiversity in monetary terms so that "nature" can be visible on the balance sheet. "It is what economists call a problem of externalities, " diagnoses Ricardo Bayon, former director of Ecosystem Marketplace, a platform for information on ecosystem services markets. "Some values-like that of a species of woodpecker or of a particular ecosystem such as a rainforest or a wetland-do not enter into the economic system. h ey are external to it, and so they are not taken into account when economic decisions are made" (Bayon 2008: 123-124). h is overl ow, as Callon might put it, can be channeled back into the economic system through the help of market-based mechanisms such as of sets, where the positive and negative impacts on biodiversity are measured and represented as "credits" and "debits" [START_REF] Doswald | Biodiversity Of sets: Voluntary and Compliance Regimes-a Review of Existing Schemes, Initiatives and Guidance for Financial Institutions[END_REF]). h us quantii ed and monetized, they are supposedly more easily integrated through cost-benei t analysis into economic decision making [START_REF] Doswald | Biodiversity Of sets: Voluntary and Compliance Regimes-a Review of Existing Schemes, Initiatives and Guidance for Financial Institutions[END_REF]. Central to the idea of biodiversity of setting is the notion that, by putting a price on ecosystems, developers will be discouraged to use a site that involves high biodiversity compensation costs. Should work go ahead nonetheless, the developers will have to i nance conservation. At a time when traditional sources of conservation funding (including government budget allocations, oi cial development assistance, and philanthropy) are widely considered as insui cient [START_REF] Parker | h e Little Biodiversity Finance Book[END_REF], this is clearly an attractive proposition. Indeed, the strategy for resource mobilization adopted at the ninth meeting of the CBD invited parties to come forward with "innovative i nancial mechanisms" (IFMs) that have the potential to generate new and additional resources for biodiversity. IFMs are based on the idea that economic incentives can be used to achieve positive conservation outcomes and draw heavily on private sector involvement (and the state as market facilitator), using tools such as biodiversity of sets (OECD 2013).

Monetization, the process whereby something can be turned into money, thus occupies a central position in this overarching market framing of conservation. Money provides "the universal yardstick of value" (Harvey 1993: 4) against which grounds for action are evaluated. Terms such as "natural capital" or "ecosystem services" operate as powerful signii ers that produce a vision of nature that folds it into the monetary value sphere. h is entwining of ecological and economic categories has the inevitable ef ect of orienting the search for solutions "in particular directions-namely towards market and technological innovation-in ways that arguably, and ot en intentionally, del ect understanding away from systemic causes of ecological (and associated socio-economic) crisis" (Büscher et al. 2012: 9). In other words, it traces a course of action where i nancial motives increasingly govern conduct, at the ineluctable expense of other forms of rules-based environmental regulations. A site of high biodiversity value is saved from destruction (or not) because it makes economic sense, not because the society as a whole has decided so.

Harnessing Conservation Experts to the Private Sector

h is process of market framing "presupposes actors who are bringing to bear cognitive resources as well as forms of behavior and strategies which have been shaped and structured by pre-vious experience" (Callon 1998: 249). Interestingly, as far as voluntary of sets are concerned, this work has been largely shaped not only by business actors (leaders of extractive industries, i nancial institutions, investors), but also by conservation NGOs and environmental consultancies. Together, they form, within the growing i eld of "business and biodiversity", an emerging cluster of "technical experts" that advance the of sets agenda at the international level, ot en in coordination with government representatives. It is a small and interactive community, since the actors that specii cally work on of sets in each organization are not numerous and very ot en come to work together or circulate between the various organizations.

To date, most of these voluntary of sets have been undertaken by extractive industries, backed by their respective industry associations for environmental and social issues, the IPIECA (global oil and gas industry association for environmental and social issues) and the ICMM. For oil and gas, the Energy and Biodiversity Initiative (made up of BP, Chevron, Shell, Statoil, Conservation International, Flora and Fauna International, Smithsonian, IUCN, and TNC) played an important role by stating a "no net loss of biodiversity at project site" as a minimum standard (EBI 2003), whereas mining has engaged early on with the IUCN-a major broker between corporations and conservation groups-in a dialogue on of sets, as discussed previously. h ere are also examples from other sectors, such as water and urban development [START_REF] Madsen | State of Biodiversity Markets Report: Of set and Compensation Programs Worldwide[END_REF][START_REF] Ten Kate | Biodiversity Of sets: Views, Experience and the Business Case[END_REF].

h e growing interest of corporate actors for biodiversity of setting as a risk management strategy has been largely fuelled by its uptake by major i nancial institutions. h e leading body in this i eld is the International Finance Corporation (IFC), the World Bank's private sector i nancing arm. In 2012, the IFC revised its Performance Standard 6 (PS6) on biodiversity to explicitly require its clients to undertake an of set in order to meet the target of a "net gain" for impacts on critical habitat and a "no net loss", where feasible, for impacts on natural habitats (IFC 2012). Many multilateral banks such as the Inter-American Development Bank follow PS6 guidelines or have developed similar approaches themselves. In addition, the 78 institutions worldwide that abide by the Equator Principles, and whose investments cover 70 percent of international project i nance debt in emerging markets, have agreed to follow IFC standards in their loan agreements (Equator Principles 2006).

h ese business actors, both corporate and lenders, rely heavily on technical guidance from external experts that will facilitate the use of biodiversity of sets in development projects. Conservation NGOs play a key role here, even if it should be remembered that "conservation" is a broad and diverse church. h e idea that conservation NGOs should partner with corporations is not consensual, and Friends of the Earth International has, for instance, withdrawn from the IUCN to mark its disapproval of the IUCN's agreement with Shell (MacDonald 2010). Collaborating with companies is nonetheless a major strategy for other large conservation NGOs. TNC's Development by Design program is presented as a way of "supporting energy, mining, and infrastructure development done in the right way and in the right places, " (TNC 2014) while Conservation International's Center for Environmental Leadership in Business works with their corporate partners " to improve their business practices, creating and implementing strategies that combine bold commitments to sustainability with practical solutions that deliver benei ts to the bottom line and the environment" (CI 2014). h rough these large-scale programs, TNC and Conservation International regularly engage with companies to help in the development of voluntary of sets.

Consulting i rms that are much smaller in size but that have developed dedicated technical expertise, policy advice, and i eld capacity on biodiversity of setting also have an important position. One of the references in this i eld is a small UK consultancy created in 2006, the Biodiversity Consultancy (TBC). TBC has worked as in-house advisor for major corporate groups such as Rio Tinto or Shell, collaborated with governments (e.g., New Zealand, Mongolia), partnered with conservation NGOs on specii c projects (e.g., with FFI for the Oyu Tolgoi project in Mongolia), and published a whole set of industry briei ng notes and reports on of setting, including a so-called independent report on biodiversity of sets commissioned by the IUCN and the ICMM (ICMM and IUCN 2012). TBC has also been closely involved in the development of new environmental safeguards for lenders such as the IFC.

h is far-from-exhaustive overview of the main actors involved in the development of corporate biodiversity of sets would not be complete without mentioning the BBOP, an organization that has provided the major contribution to date on the topic. Run by the market-oriented organization Forest Trends, based in Washington, DC, the BBOP has published a number of papers on of set principles, criteria and indicators, methodologies for design and implementation, and more recently a standard on biodiversity of sets (BBOP 2012). h e BBOP is a collaboration of more than 75 organizations and individuals, including companies, i nancial institutions, government agencies, and civil organizations that are members of its advisory group, including (as of July 2013) many of the actors that have been cited above: IFC, TBC, Conservation International, and TNC. Shell and Rio Tinto were part of this group during its i rst phase of work (2004)(2005)(2006)(2007)(2008). It also draws its strength from its proximity with other sister initiatives produced by Forest Trends, such as Ecosystem Marketplace. h e success of the BBOP is also due to the charisma of its director, Kerry ten Kate, the "visionary" and embodied presence of the of sets agenda (Carrier and West 2009;[START_REF] Macdonald | TEEB Begins Now': A Virtual Moment in the Production of Natural Capital[END_REF], who is also a good example of the circulation of these actors through public, pseudopublic, and private organizations. Formerly a barrister in London, ten Kate served on the secretariat of the United Nations Conference on Environment and Development in 1992. She then founded the private consultancy Environmental Strategies, and then became the head of the CBD unit at Kew Gardens. In 2002, as director of "investor responsibility" for the i rm Insight Investment, she worked extensively on business arguments and motivation for biodiversity management, which i nally led her to head the newly created BBOP in 2004.

Given this coni guration-a relatively small community of highly connected individuals in a milieu where the frontiers between the public, private, and corporate worlds are quite permeable-it is thus not particularly surprising to say that biodiversity of sets i ts into a conception of conservation as a nonantagonistic process [START_REF] Igoe | A Spectacular Eco-Tour Around the Historic Bloc: h eorizing the Convergence of Biodiversity Conservation and Capitalist Expansion[END_REF]. From this perspective, conservation accompanies and should stimulate economic development, a central thrust behind what is commonly referred to as the "business case" for of sets.

Making the "Case" for Biodiversity Of sets

Many of the gray literature and policy documents on of setting develop various sets of narrative strategies that serve the business and biodiversity community in justifying their actions and legitimizing their views on the biodiversity agenda. In accordance with the business imperative of seeking a return on investment, there are supposedly real benei ts to be gained for companies that engage in this new domain. As clearly stated by the organizations that advocate of sets, a "business case" can be made (ten [START_REF] Ten Kate | Biodiversity Of sets: Views, Experience and the Business Case[END_REF]ICMM and IUCN 2012) that operates as an instantiation of market framing specii cally applied to the corporate sector. h is case, whereby corporate environmental liability can be turned into an asset that takes various forms, can be divided into four main drivers: regulation, i nance, business risk management, and business opportunities.

Regulation

. h e obvious argument advanced here is that more and more governmental policies and legislations now suggest or require the use of biodiversity of sets (TBC 2013b). But, beyond compliance, it is argued that there is also a business case for developers to undertake voluntary of sets: in order to preempt future mandatory requirements. Indeed, the prospect of a "rapid proliferation" of these of set policies is raised to motivate companies to make costly ef orts. h is strategy has been widely studied in environmental economics literature that suggests that "voluntary" corporate environmental improvement depends upon a strong background regulatory threat-or the prospect of a reward (cf., in the i eld of climate policy, [START_REF] Baranzini | An Overview of the Economics of Voluntary Approaches in Climate Policies[END_REF]. h e reward, in the case of biodiversity of sets, is presented as a "i rst-mover" competitive advantage that could open up the possibility for companies in inl uencing emerging environmental regulation.

Finance.

As detailed in the previous section, i nancial institutions occupy a central position in the development of of sets at the international level, notably through the generalization of the adoption of the IFC's PS6. Easy access to capital (and associated competitive advantages) being of utmost importance to companies who undertake large-scale industrial projects, this new environmental safeguard has become a major driver of of sets within industry (ICMM and IUCN 2012).

3. Business risk management. While the two i rst drivers are largely determined by compliance to governmental or i nancial requirements, the third stems from calculations that are endogenous to the developers themselves, especially when they operate within companies with high dependency and impacts on biodiversity, such as extractive industries. For them, there is a clear business case in demonstrating good biodiversity performance and risk management, as is widely recognized in the corporate literature (ICMM 2005;Rio Tinto 2004;[START_REF] Ten Kate | Biodiversity Of sets: Views, Experience and the Business Case[END_REF]). It includes: gaining access to land and resources, since their activities ot en overlap with areas of high conservation value; obtaining a "license to operate", that is, showing concern for conservation helps to obtain (1) better relationships with local communities and environmental groups and (2) a "regulatory goodwill" that can lead to faster permits; and more generally reputational benei ts for demonstrating environmental/social stewardship as part of the corporate social responsibility portfolio, for instance, by turning biodiversity of sets into l agship environmental and community-based projects (TBC 2013b). All of these factors contribute to explain the increase in "no net loss"-type commitments within the private sector (TBC 2012).

4. Business opportunities. Last but not least, there is the promise of a direct business opportunity behind this recent corporate appetite for of sets. h is has probably never been so clearly expounded as in the account of Rio Tinto's biodiversity strategy, recounted by its chief biodiversity adviser, Stuart Anstee, during a side event of the 2010 CBD conference in Nagoya, Japan. Rio Tinto's i rst incentive for engaging in of sets, he said, had to do with minimizing the business risk of their operations. However, he continued:

[T]he next part is … the opportunity side. I guess when we started thinking about this whole policy, and the development of a policy about net positive impact, this sets of i gures played a really important part. Rio Tinto is a signii cant landholder. h rough exploration projects and development operations, we have some form of tenure to over … 132,000 square kilometers. At an operational level, so where we actually have direct management control … we're looking at about 41 to 42,000 square kilometers of land. … Of that, we actually only impact about 9 percent. So as a company we have a very large expanse or portfolio of nonoperational land that traditionally has just basically sat there. It's being used for whatever it was being used before. So with the biodiversity strategy and the net positive impact policy, what we are trying to do is to say to the company: "What's the resource value of that land as it currently sits? What's the ecosystem or natural capital value?" And I guess that's one of the reasons why we felt that we should be looking at a no net loss or net positive impact policy piece. [START_REF] Anstee | How Rio Tinto Is Approaching h eir Objective of Net Positive Impact on Biodiversity[END_REF] In other words, of sets facilitate the opening up of elements of nature currently still beyond the reach of markets for trading (and, potentially, speculation). Former i nancially sterile lands could be transformed into assets and used as "biodiversity banks", for instance, through the sale of ecosystem service credits such as forest carbon, or of excess biodiversity credits as an of set to other developers (TBC 2013b).

Biodiversity Of sets in Practice

Metrological Issues in Biodiversity Of set Design h e overarching goal of "no net loss", or preferably a "net gain" of biodiversity (with respect to species composition, habitat structure, ecosystem function, and people's use and cultural values associated with biodiversity), is supposedly achievable through adherence to a few key design principles established by the BBOP in 2009, which revolve around the issue of measurement. Biodiversity of sets have indeed come into being through metrological ef orts to ensure that the gains through an of set are "commensurate" with the losses. h rough sound ecological science and quantitative rigor, it is argued, of sets can prove to be an ei cient tool [START_REF] Quétier | Assessing Ecological Equivalence in Biodiversity Of set Schemes: Key Issues and Solutions[END_REF]. Among the principles that have been put forward to frame the work of designing an of set, four in particular deserve attention in this context, as has been acutely observed by Sian [START_REF] Sullivan | At er the Green Rush? Biodiversity Of sets, Uranium Power and the 'Calculus of Casualties' in Greening Growth[END_REF].

1. Of sets should come as a measure of last resort. h e i rst principle relates to adherence to the mitigation hierarchy, a tool commonly applied in environmental impact assessments. It states that, in order to limit as far as possible the deleterious impacts on biodiversity from development projects, a sequential procedure is to be followed-avoid, minimize, restore, and of set. h e i rst step comprises measures to avoid creating impact from the outset of the project, such as creating roads that bypass key natural habitats. h en comes minimizing the impacts that cannot be completely avoided, such as building wildlife crossings. Usually, measures of rehabilitation or restoration should also be taken to improve the ecosystems that have been impacted anyhow, during an operation or more frequently toward the end of a project's life cycle. Collectively, these three steps aim to limit any negative impact. Of sets come as the last resort of the hierarchy, "to compensate for any residual signii cant adverse impacts that cannot be avoided, minimized and/ or rehabilitated or restored" (BBOP 2013: 7). h e justii cation of proceeding to of setting thus rests on the assumption that "residual" impacts of development projects are unavoidable. But, as noted by Sullivan (2013: 84), it is precisely the very availability of this option that "permits the rationalization of aspects of both development and the residual environmental harm thereby caused as unavoidable. " An early focus on of sets can thus encourage "fast-tracking" through the hierarchy, particularly discounting the possibility of avoidance, as has already been observed in wetland policy in Alberta, Canada [START_REF] Clare | Where Is the Avoidance in the Implementation of Wetland Law and Policy?[END_REF]; see also [START_REF] Walker | Why Bartering Biodiversity Fails[END_REF].

2. Of sets should consolidate areas of high biodiversity value. Another principle that has recently gained a lot of attention rests on the possibility of mitigating the negative impact of a development project of -site, a principle that has been institutionalized in habitat banking programs but that is also used, in addition with on-site conservation measures, in of sets not associated with trading. Of -site mitigation selects an of set site ex situ, that is, outside the immediate bound-ary of the development project, but usually within a dei ned area with a similar habitat. h is is justii ed by stating that, whereas on-site of sets result in "inef ective, small, randomly created compensations, " of -site mitigation can provide a "well-thought out, larger preserve with greater ecological value" (White 2008: 34). Here again, this principle, presented as objective and making ecological sense-which is, as Sullivan notes, highly debatable (2013: 84)-seems rather to serve particular interests. It indeed constitutes a necessary step toward the abstraction process that eases the constitution of an extended market, as well as of ering the possibility for developers to design an of set at a competitive price by choosing cheaper sites than the development site.

3. Of sets should be additional. According to the BBOP, "a biodiversity of set should achieve conservation outcomes above and beyond results that would have occurred if the of set had not taken place " (2009: 15). To determine what would have happened in the site selected for an ofset in business-as-usual scenarios, the designer tends to use local, regional, or national statistics (such as deforestation rates) in order to predict the evolution of the biodiversity of the site. If a biodiversity loss is expected through this calculation, then the of set is justii ed and considered additional. Proving and measuring "additionality", as might be expected, is a dii cult and somewhat subjective exercise, since the alternative scenario (the one in which conservation action did not occur) "cannot be known with certainty" (Maron et al. 2013: 360). Moreover, it places a faith in the ability of restoration ecologists to restore or recreate ecosystems that contain the same biodiversity values to those that are lost that is not shared by the practitioners themselves, given the complexity and variability of ecosystems [START_REF] Hobbs | Intervention Ecology: Applying Ecological Science in the Twenty-First Century[END_REF][START_REF] Maron | Faustian Bargains? Restoration Realities in the Context of Biodiversity Of set Policies[END_REF]. In order to reduce the risk of a restoration failure for business, real-world of set practices tend to privilege an option known as "trading up" (TBC 2013a). h is of ers the possibility of of sets in sites that are considered more important for biodiversity conservation than those impacted. Habitat banking in regulatory systems can thus be considered a form of "trading up". In voluntary situations, "trading up" consists of i nancing conservation measures in places known to be of importance for the conservation of biodiversity: usually sites that may be already protected (TBC 2013a). Proving "additionality" in such cases is thus a tightrope walking exercise, since the developer has to prove that the site chosen is "under imminent threat" or in need "of protection or ef ective management" (IFC 2012: 2; TBC 2013a).

4. Of sets should be equivalent to permit exchangeability. h is is probably the most important principle guiding biodiversity of sets: of sets are usually intended to produce gains equivalent and thus commensurable to the ecological loss produced by the development project. h e design of an of set should adhere to a "like-for-like or better" principle (IFC 2012), which means that an of set must be designed to conserve the same biodiversity values that are being impacted ("in-kind" of set), or, in situation where areas to be impacted are considered as having little conservation value, an "out-of-kind" of set can be considered. In both cases, the aim is equivalence, and this is achieved by assuming commensurability. An of set is regarded as equivalent if gains are scaled to balance losses in:

• Type: Same kind of species, habitats, ecological functions, etc. (except when "trading-up"; or in habitat banking schemes such as in the UK where habitat types are exchangeable, see Defra 2011). • Amount: Measured in hectares, habitat hectares, species population sizes. • Time: For example, if an of set equivalent in type and size only achieves its goals in 20 years' time, it is not regarded as an ef ective compensation for the losses. h is is why of sets should in theory be put in place before the impact occurs, or time discount rates should be applied [START_REF] Bekessy | h e Biodiversity Bank Cannot Be a Lending Bank[END_REF][START_REF] Evans | A Bird in the Hand Is Worth Two in the Bush: Ecological Time Preference and Biodiversity Of sets[END_REF]).

• Space: Of sets site should be situated nearby impact sites so that equivalency in type is more likely. However, in practice, for either conservation ("trading-up") or sociopolitical reasons, the of set site chosen is not necessarily the closest.

How to measure through loss-gain calculations equivalency for of sets is probably the most debated of the technical issues among experts, but it should also be of great interest to social scientists interested in the abstraction process leading to nature commodii cation. To assess ecological equivalency, of set designers follow a sequential method that ultimately permits them to decide that the of set site is a "fair exchange" with the impacts of the developer. For this purpose, they need to put in place "some form of ecosystem metrics that account for and calculate nature so as to permit exchangeability" (Sullivan 2013: 84, emphasis in original; see also [START_REF] Robertson | h e Nature h at Capital Can See: Science, State, and Market in the Commodii cation of Ecosystem Services[END_REF][START_REF] Robertson | Measurement and Alienation: Making a World of Ecosystem Services[END_REF], usually constructed through a four-step process.

First, it is necessary to prioritize and select the biodiversity features to include in the calculation, since it is impossible to measure everything. h e surrogates that will be ultimately chosen should, in theory, be "scientii cally defensible" (in terms of irreplaceability or vulnerability, for instance) and relevant to the various (global, national, local) stakeholders. Second, the priority features identii ed must be measured, and thus methods to collect data on amounts of each feature must be chosen, such as canopy cover or species abundance. h ird, the data collected must be converted into a biodiversity "currency" to facilitate exchange and trade. Like i nancial currencies, it must be fungible and allow the substitutability and exchangeability of losses and gains through the dei nition of a common unit. Most biodiversity of setting projects worldwide use currencies calculated by multiplying extent (quantity, usually hectares) by condition (quality, e.g., species density, vegetation condition). Famous examples are the Australian State of Victoria's "Habitat Hectares" and Rio Tinto's "Quality Hectares", expressed in percentage. For instance, 100 hectares of forest at 50 percent condition is 50 "Habitat Hectares". Finally, this currency should be adjusted by putting into the equation ratios and multipliers to account for time discounting, uncertainty, and risks, with the aim of resulting ultimately in "no net loss" (ICMM and IUCN 2012).

h ere is a paradox in the central role that this work of measurement plays in of setting. h e overwhelming appeal for quantii cation is obviously driven by a pursuit of credibility for a tool that is supposed to perform the promise of substitution for the nature that is lost through development. h e development of biodiversity of sets is indeed clearly embedded in a discourse that states that ecological problems are the outcome of inadequate adoption and implementation of "modern" economic techniques of conservation informed by state-of-the-art science, which is ot en placed under the umbrella concept of "ecological modernization" [START_REF] Hajer | h e Politics of Environmental Discourse: Ecological Modernization and the Policy Process[END_REF]. With adequate calculations and metrics, it is argued, of sets could result in a "positive-sum game", with both economic growth and environmental protection. But, as Sullivan notes, "what is exchanged through these of setting mechanisms are the numerical indicators proposed by metrics … [that] may or may not provide a 'good i t' with the material natures they represent" (2013: 86). Or, to put it in another way, what is produced through these calculations is a "nature that capital can see" (Robertson 2006: 367), where the debates, rei nements, and uncertainties in ecological science over what is measured have no room.

h e capacity of such currencies to be an adequate substitute for the biodiversity they represent is an issue that has led a substantive body of scholars to question the reliability of of set systems to truly achieve "no net loss" [START_REF] Salzman | Currencies and the Commodii cation of Environmental Law[END_REF][START_REF] Quigley | Ef ectiveness of Fish Habitat Compensation in Canada in Achieving No Net Loss[END_REF][START_REF] Gibbons | Of sets for Land Clearing: No Net Loss or the Tail Wagging the Dog?[END_REF][START_REF] Walker | Why Bartering Biodiversity Fails[END_REF]. As summarized by Brownlie, King, and Treweek, "h e use of crude currencies, poor biodiversity surrogates and over-simplii ed metrics in of sets fails to account for the signii cant environmental and social welfare values across space, type and time " (2013: 27). However, what is surely achieved by this process of quantii cation and abstraction is the creation of an illusion of objectivity, of an impersonal knowledge "independent of the particular people who make it" (Porter 1995: ix)-a direct ef ect of the phenomenon of "trust in numbers" analyzed by Porter. h e real individuals, organizations, and interests pushing the development of the biodiversity of sets agenda are thereby ef aced. Invisible behind the banner of ecological science, which is legitimated by the force of numbers, metrics, ratios, and so forth, lie calculations that are based on subjective choices and may or may not serve particular interests. Of sets demand a high level of expertise: large amounts of ecological data have to be gathered and analyzed, not to mention the task of valuing and pricing the natural elements selected. All this involves considerable expenditure borne by the developer, who would thus have considerable power over the process. Since it is in the developer's best interest to see this work done as quickly as possible, this could lead to the environmental impact of a project being underestimated. Beyond the issue of relationships of forces, what is also rarely clearly stated in the research on measurement issues is that environmental management decisions are expressions of preferences and values that are ultimately a matter of societal choices. In situations where dif erent groups have disparate desires, with potentially conl icting social, economic, and/or ecological values, lies a question that is at the heart of of sets' operations: "[W]ho decides 'societal values' , both now and for future society?" (Brownlie et al. 2013: 26).

Implementing Biodiversity Of sets and Verifying h eir Success

h e issue of the reliability of methods to calculate biodiversity of sets is not only a problem for scientists; it is also a major concern for business actors. To date, no internationally accepted standard exists to provide guidance on of set design. Many regulators, especially in North America and Australia, have developed their own mandatory currencies along with their own methods to measure biodiversity. On the voluntary side, Rio Tinto and the BBOP, among others, have also developed their own procedures. h is lack of a widely agreed and credible standard on of sets is seen as a risk for the industry, and explains why few companies are currently engaged in this process. Indeed, without a recognized norm that provides "a common language to evaluators, the evaluated and their audiences" (Ponte et al. 2011: 1), there is no way to judge and compare the quality of an of set project. Furthermore, engaging in an of set project for developers means investing a large sum of money and being exposed to scrutiny and potential criticism if the of set is considered a failure. h e development of a standard on biodiversity of sets is thus critical to protect themselves from the double risk of criticism (which can seriously harm their reputation and "license to operate") and of losing their investment due to the uncertainty of the result.

h is concern has been registered by the BBOP, which dedicated its second phase of work (2009)(2010)(2011)(2012) to developing the trademarked BBOP Standard on Biodiversity Of sets. h is document adds a hierarchy of criteria and indicators to the principles guiding biodiversity ofsets' design. It is the result of the collective work of the BBOP secretariat and the many bodies that compose its advisory group, and is therefore presented as agreed by "an international, multi-stakeholder group" (BBOP 2012). However, as one can observe by l ipping chronologically through the various publications of the BBOP, while the BBOP was starting to work on its standard, many large transnational corporations that were key BBOP pillars, such as Rio Tinto, Shell, Anglo American, and Newmount, were abandoning the organization. h e logos of these companies oi cially i gured in the 2009 BBOP's Biodiversity Of set Design Handbook, which was the output of the BBOP's i rst phase of work, but these same logos shine by their absence in the 2012 BBOP's Standard on Biodiversity Of sets, a document that was developed at er the 2009 handbook.

It is probably not a coincidence that these industrial giants let the BBOP's advisory committee precisely when the organization was starting to engage in the process of developing a standard on biodiversity of sets, even if the precise reasons remain to be clarii ed. What is at stake here is the construction of a regulatory framework for biodiversity of sets, especially in developing countries where clear guidance in this i eld is ot en lacking. Who sets the rules regarding of sets and who verii es their success? Governments? Private companies? Independent certii cation agencies? A good deal of the ecology literature on of sets make important points in terms of governance, but the main focus remains on "adequate compliance" and the necessity of audits (e.g., Bull et al. 2012;[START_REF] Gibbons | Of sets for Land Clearing: No Net Loss or the Tail Wagging the Dog?[END_REF]. h e specii c issue of the mainstreaming of a global biodiversity of set standard, a step that is crucial for the potential development of a large-scale of set market, poses instead the question of the porous relationships between voluntary standards as developed by Rio Tinto or the BBOP and those set by public authorities. Mainstreaming biodiversity of sets, even strictly voluntary ones, requires an "enabling policy framework" to support this activity, such as "ef ective law and policy on conservation; environmental impact assessment and mitigation; land use planning and zoning; conditions for extractive and other industrial developments with biodiversity impacts; and clear national sustainable development goals and priorities with associated national biodiversity strategies and action plans" (ten Kate et al. 2004: 10). In the absence of policies or plans containing biodiversity goals, the "of setability" of biodiversity impacts is much more dii cult to assess [START_REF] Pilgrim | A Process for Assessing the Of setability of Biodiversity Impacts[END_REF]. h e lack of such policy frameworks in many countries leaves the door open for a struggle to inl uence its constitution. Companies such as Rio Tinto, which presents itself as a pioneer of best practice in of setting, are indeed in a good position to inl uence governments in ways that may favor their corporate interests. h e BBOP, on the other hand, is also clearly engaged in exploring potential certii cation and verii cation systems for of sets (see BBOP 2008: 3).

Uneven Development: Some Equity Issues

A last avenue in the study of the material implications of biodiversity of setting relates to the equity issues that are likely to arise locally from the distribution and allocation of "environmental health and harm" for humans as well as nonhuman nature [START_REF] Sullivan | At er the Green Rush? Biodiversity Of sets, Uranium Power and the 'Calculus of Casualties' in Greening Growth[END_REF]. h is is indeed fertile ground for anthropologists or geographers who can observe in their i eldwork the distributive ef ects of development projects that involve of sets. However, pilot projects in of sets being few and far between, very few case studies exist, with the notable exception of Sian Sullivan's already much-cited paper that connects the extraction of uranium in Namibia with the generation of nuclear power in the UK (2013), and Caroline Seagle's research on land access issues surrounding the Rio Tinto/QMM ilmenite mine in southeast Madagascar (2011Madagascar ( , 2012)).

For both these scholars, biodiversity of sets are to be placed within the current phenomenon of "land grabbing" in developing countries, a notion that is ot en used in the African context to characterize the allocation of large swaths of farmland to investors to provide for the future food and fuel needs of foreign nations (De Schutter 2011). Recently, this notion has been extended to the appropriation of land and resources for industrial expansion and/or for environmental ends and christened "green grabbing" [START_REF] Fairhead | Green Grabbing: A New Appropriation of Nature?[END_REF]. [START_REF] Seagle | h e Mining-Conservation Nexus: Rio Tinto, Development 'Git s' and Contested Compensation in Madagascar[END_REF] insists on the commonalities and interdependency between these two types of land acquisition, exploring what she coins the "mining-conservation nexus. " As might be expected, environmental and land access changes induced by biodiversity of sets produce the very same economic, social, and ontological ef ects as those that have been widely but ot en separately observed for local land users living around protected areas or near development projects, notably through their resettlement, lost access to critical resources, or land dispossession [START_REF] Seagle | h e Mining-Conservation Nexus: Rio Tinto, Development 'Git s' and Contested Compensation in Madagascar[END_REF])-not to mention, in this "cal-culus of casualties", the loss of biodiversity at the development site, whose spatial and temporal specii cities can never be fully compensated for by an of set [START_REF] Sullivan | At er the Green Rush? Biodiversity Of sets, Uranium Power and the 'Calculus of Casualties' in Greening Growth[END_REF].

In what ways, then, and to what extent, does biodiversity of setting constitute a new form of appropriation of nature, and with what particular material impacts? What are the power dynamics involved in the decision-making process, with what socioeconomic implications? h ese questions remain largely open for investigation, particularly as far as agrarian social relations are restructured through the development of such projects. Indeed, it might be considered unfair to accuse of set projects of repeating exactly the same ills caused by protected areas. Biodiversity of sets advocates state, for instance, that "no net loss" includes socioeconomic and cultural uses of biodiversity. A further question, then, is how it would even be possible to "of set" cultural values within a "no net loss" perspective? What kinds of compensation packages are of ered? If the material translation of this particular issue has not been investigated in case studies on of sets, its strategic discursive wrapping has drawn attention. As [START_REF] Seagle | Inverting the Impacts: Mining, Conservation and Sustainability Claims Near the Rio Tinto/QMM Ilmenite Mine in Southeast Madagascar[END_REF] has argued, biodiversity of sets allow a legitimation strategy through which the deleterious material impacts at the development site are "inverted" into "git s" of sustainable development, an "ideologically useful fantasy that papers over the potentially disturbing gap between material and symbolic orders" (Sullivan 2013: 95).

Conclusion

h e growing interest in voluntary biodiversity of sets among many transnational extractive industries has been shaped through a decade-long process of "dialogues" that saw the alignment of corporate executives, senior actors in conservation organizations, and bureaucrats around the recognition that the environmental damage accruing from corporate activities represents a major business risk that can be minimized through the use of of sets. Under constant pressure from adverse campaigning from social and environmental organizations, the reputation of these large companies was at stake and with it their "license to operate", that is, their continued access to land, markets, and capital. h is initial defensive position has, however, been quickly replaced by a more of ensive strategy whereby corporate liability is increasingly turned into an asset. With the long history of wetland banking in the United States in the background, ofsets are increasingly framed as a nonantagonistic market-based instrument and an opportunity for business. Following Michel Callon's observations on the process of market framing, I have argued that this work of coni guration traces a normative course of action as far as conservation is concerned, where i nancial motives increasingly dictate conducts, a paradigm shit away from enforceable environmental legislation. h e emergence of a dedicated, small, and interactive community of biodiversity of sets experts, composed of corporate leaders, i nancial institutions, conservation NGOs, and private environmental consultancies, has greatly contributed to this process.

However, the collective work that has been carried out under the umbrella of the BBOP to weave together a seductive business case and the promise of reconciling conservation and development faces many challenges when it comes to its implementation in the real world. h e market framing of of sets appears here as a fragile result dependent upon substantial and costly investments. h e complexity of measuring biodiversity in a way that is both intelligible to capital and scientii cally defensible, the absence of a generalized standard to assess the quality of of set projects, and the many uncertainties that revolve around the impacts of these projects on local communities are all reasons that cast serious doubts about of sets' ability to reduce biodiversity loss on technical, governance, and social grounds. Given all the developments under way and the multiplication of pilot projects, these are issues that could become fruitful research subjects in the near future.

Ⅲ ACKNOWLEDGMENTS I am extremely grateful to Paige West and Dan Brockington for accepting my article proposal. I also would like to thank my colleagues Valérie Boisvert, Christophe Bonneuil, and David Dumoulin for their constructive comments, as well as the Région Ile de France and the Institute for Research and Innovation in Society (IFRIS), who provided the funding to undertake this study.

Ⅲ SARAH BENABOU is postdoctoral fellow at the Centre Alexandre Koyré/IFRIS, Paris. Her principal research interest is in the evolution of environmental conservation in the global South (with a focus on India), as part of a wider interest in the political economy of environmental conservation. She is currently engaged in an ethnography of the making of voluntary standards for biodiversity of sets. Before this research project, she worked on the pitfalls of environmental conservation in India. She submitted in 2012 a PhD thesis in social anthropology entitled "Conserving Nature by Excluding Humans? h e Struggle for Access and Use of Natural Resources in the Nanda Devi Biosphere Reserve, Uttarakhand (India)" at the Ecole des Hautes Etudes en Sciences Sociales, Paris.

Ⅲ NOTES 1. I can, however, refer the reader to some of the most recent articles that provide a global overview of the debates in ecology on biodiversity of sets: [START_REF] Bull | Biodiversity Of sets in h eory and Practice[END_REF][START_REF] Brownlie | Biodiversity Tradeof s and Of sets in Impact Assessment and Decision Making: Can we Stop the Loss?[END_REF][START_REF] Pilgrim | A Process for Assessing the Of setability of Biodiversity Impacts[END_REF] 2. I choose to focus on the mining industry, but many parallels can be drawn with the oil and gas sector, which has been exploring the use of biodiversity of sets around the same time through the Energy and Biodiversity Initiative (EBI 2003).