The Conservation, Mitigation and Biodiversity Offset (COMBO) program helps countries around the world balance biodiversity conservation with development. Our approach encourages governments, industry and civil society to apply the mitigation hierarchy, a sequence of four key steps – Avoidance, Minimisation, Restoration and Offsets – which are international best practice for reducing impacts on biodiversity from development.

COMBO supports uptake of the mitigation hierarchy globally by working with a wide range of stakeholders. Our current focus is to improve mitigation practices in four African countries – Guinea, Uganda, Mozambique and Madagascar – and two Asian countries – Laos and Myanmar. The six countries all present global opportunities for the conservation of global biodiversity and are faced with very rapid development of large potentially impacting infrastructure projects. Our goal is to reconcile economic development and conservation objectives, by contributing to the definition and implementation of policies aimed at no net loss, or even a net gain, in biodiversity and the achievement of national biodiversity
targets that will result from CBD COP 15.

COMBO encourages uptake of the mitigation hierarchy by supporting: (1) improved national policy and its application, particularly through cross-sectoral coordination; (2) tools and guidance for better use of biodiversity data for avoiding impacts and other mitigation actions; (3) financing and implementation mechanisms; and (4) better institutional capacity of governments, industry, financial institutions and civil society.

COMBO builds national capacity in each focal country to reconcile economic development and biodiversity conservation. We work with a wide range of actors to achieve our objectives. In the public sector, we work with a wide range of institutions and people. We engage policy-makers at national level and in local government for provincial development plans. In central government, our partners include environment ministries and affiliate agencies, as well as sectoral institutions (e.g. ministries of energy and infrastructure agencies) and multi-sectoral institutions such as the Office of the Prime Minister and agencies involved in strategic environmental assessments.

Relevant industry sectors for our work include extractives, energy, agro-industry, forestry, tourism and transport sectors. We help government agencies improve regulation on environmental impact assessment and we build capacity of environmental and social consultants to apply regulation. We work closely with development banks and private sector lenders to encourage application of lender standards. Conservation trust funds are important partners for developing offsets financing and assuring effective outcomes from offsets. We work with civil society organisations because of their role in observing potential impacts on biodiversity and their potential to hold public and private sectors to account.
Community-based organisations, communities and indigenous peoples can contribute unique perspectives on biodiversity and the benefits people derive from nature. Their participation in design of site-based activities is necessary to integrate their needs and priorities and avoid adverse impacts on communities. Conservation organisations have expertise in biodiversity measurement and conservation management which is relevant for understanding development impacts and managing offsets.

Government Policy

COMBO assists national and local governments in establishing appropriate governance systems and policies to guide implementation of the mitigation hierarchy. Our approach focuses on helping government institutions develop policy tools which support best practice. COMBO has worked with governments to develop new primary legislation which requires that development projects achieve biodiversity goals such as no net loss through application of the mitigation hierarchy. In Uganda, we advised the Government on integration of mitigation targets of no net loss into the National Environment Act (2019) and offset requirements in the Uganda Wildlife Act (2019). We have helped individual institutions develop implementing regulations which describe how primary legislation should be applied for environmental and social impact assessment (ESIA) and other development-related activities. In Mozambique, we advised the Government on integrating mitigation requirements into the Regulation for the Conservation Law (2017) and the Decree on Biodiversity Offsets Regulation (2017). We advised the Government of Guinea on integrating mitigation requirements into the Environment Code (2019).

We work with public institutions to support practical solutions which encourage uptake and application of policy. Potential impacts on biodiversity may come from a range of sectors and act through a combination of factors. Mitigation actions to address these impacts often require acting early in development lifecycles and require early planning with a range of actors. Geographical or sectoral planning such as Strategic Environmental Assessment is a valuable approach that improves integration of biodiversity and social risk into development planning. COMBO helps government institutions apply policy by understanding how these impacts can be addressed through better planning to avoid impacts before they take place. As part of our work, we support national roadmaps or strategies which tie together the necessary steps and required actors to ensure effective implementation of policy. We have advised the Governments of Guinea, Uganda and Mozambique in developing these national documents.

Development originates from many sectors including energy, extractive industry, production and transport. Effective application of policy requires coordination across sectors to avoid and reduce complex impacts on biodiversity from multiple industry projects. COMBO supports cross-sectoral collaboration to encourage better application of policy on the mitigation hierarchy by different government institutions. We work with institutions at the highest levels of national leadership, to individual sectoral organisations, through to local government. This support often requires input into appropriate legal, administrative and financial mechanisms and guidance.

National mitigation policy defines required biodiversity outcomes following project development. Best practice such as IFC Performance Standard 6 encourages achieving a net gain for priority biodiversity and no net loss for other biodiversity. However, there are concerns that such approaches do not in fact assure maintenance of biodiversity due to ongoing declines from other sources. The IUCN Impact Mitigation and Ecological Compensation thematic group has identified opportunities for aligning mitigation outcomes with national contributions towards Convention on Biological Diversity post-2020 targets. COMBO supports ongoing updates to policy on mitigation outcomes. We lead development of novel approaches which support improved policy links between mitigation outcomes and post-2020 targets.

Knowledge base

Effective mitigation of biodiversity impacts from development requires an understanding of the type and location of biodiversity and its importance in the area of interest around the development. Data on five characteristics of a biodiversity feature are necessary for analysis to inform mitigation planning. Characteristics required will whether the biodiversity feature under assessment is a species or ecosystem as described below:

  • Type of biodiversity: species or ecosystem type
  • Amount of biodiversity: number of individuals of a species; extent of an ecosystem
  • Condition: population structure of a species; ecosystem condition
  • Relative location of the biodiversity feature to other biodiversity and landscape features: i.e. connectivity or isolation of a feature
  • Temporal data for the biodiversity feature: i.e. series of data over time of the above characteristics

Analyses and outputs based on these data can contribute to different processes and stages of mitigation. Some outputs and applications include:

Mapping biodiversity, such as species populations and extent of ecosystems, is a first stage of analysis for informing mitigation. Outputs include ecosystem maps or species density maps. National protected areas can also be included into related outputs to aid understanding of data. These can inform national conservation actions and be incorporated into a National Biodiversity Strategy and Action Plan.

Implementation Mechanisms

COMBO works with stakeholders to put in place the systems and guidance necessary for the long-term finance and management of offsets. Ensuring sufficient financing is imperative and without appropriate, adequate, and long-term finance, the additional biodiversity conservation required by offsets would fail to materialize and the goal of reaching conservation objectives that are equal to or of greater priority than what has been impacted and align with national biodiversity targets, would never materialize. COMBO works with governments and other stakeholders toward achieving the following results:

  • Offsets are funded for as long as the impacts are present or preferably in perpetuity;
  • Offsets are paid either in full, or in agreed upon instalments at the time of licensing and the funds put into a Trust Fund or other special account; where full payment is not made, financial guarantees are provided; The project developer either implements the offset directly or contracts a third party to implement the offset.

COMBO partners with Conservation Trust Funds where they exist to develop appropriate mechanisms for implementation. In Mozambique, BIOFUND has contributed significantly to designing the road map for offset implementation and is identified as a recipient of offset funding, with responsibility for supporting third party offset implementation. The Madagascar Biodiversity and Protected Area Fund (FAPBM) currently manages voluntary offset financing and will take on greater offset financing once new legislation, developed through COMBO program efforts, is in place. There are opportunities to work with other national conservation trust fund on offsets financing and implementation.

The existence of offset policy and the greater levels of information on biodiversity in COMBO countries offer an opportunity to aggregate offsets in areas of importance for conservation. In many COMBO countries, that aggregation will occur in existing protected areas, newly established areas and Key Biodiversity Areas (KBAs). Many of these areas exist on paper but have little to no funding, allowing offset funding to be additional. Offset financing will also provide benefits to local communities who depend on natural resources for their livelihoods. The provision of performance payments and utilization of easements can make conservation a viable economic alternative for communities.

As part of the implementation program, COMBO works with the national regulator to establish monitoring protocols and systems, such as a register of offset programs and sites, to ensure that conservation targets and objectives are being met. Given the long-term nature of offset financing, management will need to be adaptive to meet new and emerging challenges to biodiversity in those countries where COMBO works.

Capacity Building

Improved understanding of the need for balancing conservation and development is a priority for better application of mitigation policy. We work with a wide range of national and global stakeholders to improve knowledge of how effective implementation of policy can support progress towards biodiversity targets. We engage governments, civil society, financial institutions and business to build national capacity for developing mitigation actions.

We have hosted and continue to run webinars and training sessions for interested people from around the world. We have produced detailed training materials in several languages, including 20 training modules which we continue to develop for public use. These events and materials are aimed at practitioners from government and the private sector. They are particularly suitable for government planning and licencing authorities, including those involved in policy development. This approach has allowed us to mentor individuals as they develop national policy, including mitigation guidance. Industry partners, including national infrastructure agencies and commercial businesses, have benefited from tailored engagement and support through training sessions and ongoing discussions. These have helped build national capacity in project countries to improve biodiversity outcomes from development.

Training resources will be placed on the COMBO website shortly.

Partner training resources include the IUCN IMEC videos.