Accounting for Mitigation
Strategic management and governance
Strategic advisory services
Lack of understanding on project level approaches to protect marine biodiversity leading to ongoing impacts
What is happening?
In order to obtain construction and/or operational licences for infrastructure projects developers often seek to implement mitigation measures using the Mitigation Hierarchy. The premise of the Mitigation Hierarchy is to avoid as the first most important step. If avoidance is not possible then minimisation measures can be adopted. Residual impacts should be addressed through restoration. The last step is to offset, which should only be undertaken if all other measures in the Mitigation Hierarchy have been taken.
Implementation of the Mitigation Hierarchy for biodiversity is measurable. However, it is rarely measured strategically across projects by developers or other development decision makers. Mitigation is frequently buried amongst detailed project related reports and is not often clearly reported for each step of the hierarchy. On an individual project basis, approaches to mitigation are understood and set out in the ESIA and accompanying management plans, but there is little if any strategic review across all projects.
Accounting biodiversity does happen, but that is also mostly a project-by-project consideration. Sahley et al. (2017) have developed an approach to quantifying impact reduction due to avoidance, minimization and restoration for a natural gas pipeline in the Peruvian Andes. This provides an interesting indication of a project level review. However, the time taken required to deliver a detailed review across projects may be prohibitive. Additional project assessments have been undertaken to account the implementation of Net Positive Impacts for projects (TBC and FFI, 2012). IUCN and The Biodiversity Consultancy have also recently published a global database of the implementation of offset policy at a government level, which is a great initiative to understand top-down approaches to this element of the Mitigation Hierarchy.
C.T. Sahley, B. Vildoso, C. Casaretto, P. Taborga, K. Ledesma, R. Linares-Palomino, G. Mamani, F. Dallmeier, A. Alonso (2017). Quantifying impact reduction due to avoidance, minimization and restoration for a natural gas pipeline in the Peruvian Andes. Environmental Impact Assessment Review 66 (2017) 53-65.
TBC and FFI (2012). Oyu Tolgoi Net Positive Impact Forecast. Unpublished draft report of The Biodiversity Consultancy Ltd and Fauna & Flora International, May 2012.
Why is it a problem?
Without analysis of how mitigation is being implemented, there is a flaw in the understanding of how businesses are impacting on biodiversity and it is difficult to understand where improvements are possible. Often decisions are made to provide short-term project gains or approaches may be constrained by the project timeline. This may bring long-term costs and risks that are not always well understood. The lack of understanding can make it difficult for developers to know the overall consequence of not implementing early mitigation steps at a strategic level, learn lessons and develop better approaches.
Of note, there is little assessment of how avoidance is being delivered by developers and sometimes there is a focus on demonstrating implementation of later mitigation steps as part of a positive communication of outcomes. Addressing this is of vital importance not only to adopt the best approaches but also due to the technical difficulty, cost and uncertain success of restoration and offset strategies.
How do we help to solve it?
We will help developers to measure their implementation of the hierarchy, identify success, understand common issues and how best to standardise management, consider the consistency of their approaches; when they most often deliver measures in a project timeline; and what long-term business and biodiversity consequences result from decisions that are made.
We seek to help businesses by reviewing and reporting on:
- How they are implementing the Mitigation Hierarchy by undertaking a standardised review and reporting approach of the ‘mitigation balance’.
- Where gaps exist and where improvements to implementation of the Mitigation Hierarchy can be made.
- How sustainability goals or commitments No Net Loss and Net Positive Impact have been applied in project strategies.
- What are the commonly encountered commitments at an early stage, which should enable greater focus, efficiency and reduction of duplicative activities across projects for commonly encountered issues.
- Providing a sector or project specific road map for implementing the Mitigation Hierarchy effectively.
The reports we produce can be used by developers as a record of implementation, publication and for monitoring. We consider this to form a new reporting standard that can be combined with other sustainability reporting initiatives that are often delivered in business, e.g. GRI sustainability reporting.
The value of engaging with Bluedot to undertake this approach is that we have significant understanding of mitigation for marine biodiversity and what are the most effective measures and approaches across the Mitigation Hierarchy. We also understand what works and what is practicable to implement on the ground. We can talk to clients about the issues and problems associated with implementation so that they are fully aware of the consequence of actions even at early project stages. Finally, our technical knowledge enables us to help clients to develop standardised mitigation approaches based on commonly encountered issues and key risks.