Yes, by destroying terrestrial habit and replacing it with marine habitat, or water habitat. But in southern Ontario, if I put a building up or a sidewalk up over a habitat, there's no place I can move that habitat without destroying some other habitat. There's going to be a net loss no matter what. I simply can't see how the notion of a no net loss in habitat can work.
I can see a no net loss in critical habitat, which is why I prefaced my remarks with that question, but no matter what I do in southern Ontario, any human development—short of going straight up—is going to result in a net loss of habitat, isn't it?