The island of Madagascar, home to high floral and faunal endemism, is one of the 36 biodiversity hotspots with 15,000 plant species of which more than 12,000 are endemic. 212 Key Biodiversity Areas (KBAs) were identified during the development of the CEPF Critical Ecosystem Profile published in 2014, encompassing an area of 107,309 km2 including both terrestrial and offshore sites. Across these KBAs, 80 are under temporary protection status and 80 have no legal protection.

According to the IUCN Red List of Threatened Species of wildlife, Madagascar is home to 107 Critically Endangered species, 260 Endangered species and 121 Vulnerable species. The recently published IUCN Red List of Ecosystems of Madagascar provides a comprehensive assessment of the spatial dynamics of terrestrial, freshwater and marine ecosystems in Madagascar. Of the 35 terrestrial, coastal and marine ecosystems evaluated, 16 are threatened (Critically Endangered, Endangered or Vulnerable) and 16 are too poorly known to be evaluated and fall in the category ‘Data Deficient’.

Up-to-date information is also available on the conservation status, distribution of freshwater species in inland waters in Madagascar and the Indian Ocean islands. This recent report on the freshwater wildlife of the Madagascar and Indian Ocean islands hotspot, identifies important sites for conserving biodiversity. Forty-three percent of freshwater species in the hotspot were found to be threatened with extinction. Freshwater biodiversity was found to be significantly underrepresented within protected areas in Madagascar. In the hotspot, the twenty-three freshwater Key Biodiversity Areas that were identified represent a network of sites critical for the survival of freshwater biodiversity. The high endemism that Madagascar shelters is a priority for conservation of biodiversity for the country.

Madagascar faces major environmental issues including deforestation, loss of endemic species, degradation and depletion of natural resources, amongst others. Most often, these are caused by anthropogenic pressures on renewable and non-renewable resources, such as agricultural activities and forestry, mining and other extractive industries (oil, gas), spatial planning (transport, production of energy and other industries, etc.). These sectors, formal as well as informal, often have considerable impacts on the environment. Hence, project lenders and public and private project developers should be strongly motivated to limit their impacts and put in place mitigation measures when required.

Madagascar has ratified several international environmental Conventions referring to biodiversity to reduce pressures on its natural resources (CBD, Ramsar, UNFCCC, UNCCD, CMS, CITES, etc.). At the World Parks Congress in Durban in September 2003, the Government of Madagascar pledged to triple the surface of protected areas in Madagascar, which amounts to at least 10% of the national territory.

The country also has national strategies and action plans for biodiversity. The Madagascar Environment Charter adopted in 1990 and modified in 2015 (Loi n° 2015-003 du 20 Janvier 2015 portant Charte de l'Environnement actualisée), recommends the establishment of a legal framework for environmental impact studies and is implemented by Decree No. 99-954 (1999) modified by Decree 2004-167 (2004) concerning the Compatibility of Investments with the Environment (Décret N° 2004-167 du 03 Février 2004 relatif à la Mise En Compatibilité des Investissements avec l’Environnement - MECIE). The MECIE is applied to public and private investments which are likely affected the environment. The EIA documents preparation concerns the promoter of the project while the evaluation of documents is coordinated by the National Office of Environment (Office National pour l'Environnement – ONE). Additionally, the National Biodiversity Strategy and Action Plans – NBSAP (2015-2025) outlines guidelines and action plans to improve Madagascar’s biodiversity status by 2025.

The Law on Land Use Planning Orientation (Loi 2015- 051 du 03 Février 2016 Portant Orientation de l’Aménagement du Territoire - LOAT) sets the general legal framework for national land use planning with consideration of sustainable development at the national, provincial, regional and municipal levels. It defines in particular the guiding principles, the objectives, the various tools and the means of implementation in accordance with the orientations formulated in the national policy of land use planning.

Madagascar has a Protected Areas Management Code (Code de gestion des Aires Protégées du 26 Février 2015 - COAP). This is a legal framework essential to meet the biodiversity conservation goals set out by the country. It provides an opportunity for stakeholder participation other than state institutions in the management and governance of protected areas (local communities, associations and NGOs, private sector and local authorities). A decree No. 2017- 415 of May 30, 2017 sets the terms and conditions for the application of COAP Law 2015-005.

Objectives & Activities

We are implementing activities in Madagascar towards four main objectives:

Institutionalisation of policy. The first objective is to support the government in finalizing the laws and regulations that direct the implementation of the mitigation hierarchy. For this first objective, we will focus on delivering the following:

  • Regulatory tools: the PAHAC (Plan d’Action pour la consolidation de la hiérarchie d’atténuation et la compensation) will be finalized and put in place. Other proposals made in Phase 1 of COMBO for changes in regulatory tools will be pursued to support the government in updating and contributing to new legislation or regulation.
  • Strengthened capacity of relevant public institutions: a technical assistant will be seconded to the Ministry of the Environment and Sustainable Development (Ministère de l’Environnement et du Développement Durable – MEDD).
  • Coordinated application of policy on the mitigation hierarchy: we will improve coordination of implementation of policy through several measures including strengthening the role of conservation trust funds, supporting the establishment of a Steering and Monitoring Committee to implement the PAHAC, helping develop a Technical Committee and Technical Resources Centre to share lessons learnt and developing a directory of experts working on the mitigation hierarchy. The team will also assist in the definition of national objectives for biodiversity conservation and support in the production of tools and studies to implement relevant national policy.

Planning and implementation tools. The second objective focuses on developing spatial planning as a tool to implement the mitigation hierarchy. We aim to achieve these outputs: 

  • Biodiversity data: current available data and data gaps will be assessed, an environmental database will be developed and networks with researchers will be strengthened to support access to recent data.
  • Tools and metrics for biodiversity: we will focus on assessing the feasibility of developing an accurate typology and spatial prioritization of ecosystems and a methodology to define exchange rules, losses and gains of ecosystems. We will support development of technical guidelines to support the biodiversity offset regulation. The team will also support national capacity in implementation of technical guidelines and support a roadmap for rolling out the mitigation hierarchy.
  • Legal and financial mechanisms to support implementation of offset outcomes: the government will be supported in the development of a monitoring system for offset projects and an offset registry. We will provide technical and legal assistance to ensure that appropriate mechanisms for operationalising offsets are in place. We will assess options for green taxation, ecological damage and possible alternatives to financing mechanisms for biodiversity mitigation. 

Capacity building and awareness-raising. The third objective focuses on capacity building and outreach for governments, civil society, financial institutions, and the private sector to improve their understanding implementation of the mitigation hierarchy. We aim to deliver the following results: 

  • National capacity building: we will identify capacity gaps and needs at the national level for implementating the mitigation hierarchy and providing training to relevant national institutions, as well as practitioners such as consultants and project developers. We will also build capacity of civil society and national financial institutions to help roll out policy. The team will also review opportunities for development of a validation process for skills in ESIA, and biodiversity surveys. Similarly, we will define and develop a training program for young people and develop non-scientific communication products for the public.
  • A communication strategy: field visits will be organized between COMBO+ countries, participation by national stakeholders in relevant events and by national stakeholders in communication on the project’s activities will be supported.

Models for offsets implementation. The fourth objective focuses on developing innovative models and operational protocols to implement the mitigation hierarchy. We anticipate the following results: 

  • Models to implement the mitigation hierarchy: we will develop a preliminary analysis of successful experiences in conservation projects and assess how these can be applied for relevant governance and contractual models for offsets. Working with a range of relevant stakeholders we will test and validate operational models for offset pilot projects.
  • National experiences of implementing the mitigation hierarchy and offsets: we will publish scientific and technical articles based on our findings and hold technical workshops to share lessons learnt. We have provided important capacity support to the government, through the Office National de l’Environnement and its technical review committees (Comité Technique d’Evaluation – CTE), as well as to a range of stakeholders.  This has supported, greater understanding of the mitigation hierarchy and improved capacity to apply practice across national institutions, civil society and financial institutions.

The Ministry of the Environment and Sustainable Development (Ministère de l’Environnement et du Développement Durable – MEDD) developed the legal framework for requiring environmental impact assessment in Madagascar, through the MECIE Decree (Mise en Compatibilité des investissements avec l’Environnement). The Ministry was greatly involved in the first phase of COMBO and the work developed in Phase 1 will be pursued in Phase 2. The national regulator, the ONE (Office National pour l’Environnement), oversees that the MECIE Decree is put in place and provides the environmental permit or the Environmental Commitment Program (PREE) approval. The ONE is thus a pivotal partner in COMBO's work.

The Ministry of Land Use Planning and Public Works (Ministère de l’Aménagement du Territoire et des Travaux Publics – MATP) is in charge of putting in place the Law on Land Use Planning Orientation of 2015 (Loi sur l'Orientation de l’Aménagement du Territoire – LOAT).

Two trust funds were involved in the first phase of COMBO:the Madagascar Protected Areas and Biodiversity Fund (Fondation pour les Aires Protégés et la Biodiversité de Madagascar – FAPBM) and the Tany Meva Foundation. Madagascar Biodiversity Fund is private foundation that works towards the financial sustainability of Madagascar’s protected areas and biodiversity.Tany Meva Foundation’s mission is to mobilize and manage financial resources with the aim to promote sustainable environmental management through the involvement of local communities.

We liaise regularly with our donors at the Agence Française pour le Développement (AFD) and the Fonds Français pour l’Environnement Mondial (FFEM) notably with the AFD office in Antananarivo. Both funding agencies have significant involvement in Madagascar (natural resources management, conservation of biodiversity, etc.). We have engaged the private sector in recent activities, for example, the two mining companies Ambatovy and Rio Tinto QMM, as well as other sectors. This has helped us understand the opportunities and constraints that development projects have for reducing the impacts of their operations on the environment.


The key result from our activities so far has been the development of the Action Plan for the consolidation of the application of the Mitigation and Compensation Hierarchy (PAHAC), a document presenting 44 recommendations across five main themes: i) policy & strategy; ii) regulatory framework; iii) governance; iv) technical implementation tools and measures; and v) capacity building. 

In Madagascar, we analyzed the regulatory framework and capacities of organizations and institutions to achieve no net loss or net gain (NNL/NG) goals for biodiversity in Madagascar. This has provided direction for development of new policy instruments which incorporate the mitigation hierarchy and NNL/NG goals. In addition to the PAHAC, our main focus has been to provide expertise in reviewing the draft amendment of the MECIE Decree (Décret MECIE - Mise en Comptabilité des Investissements avec l’Environnement). We will maintain our support for the development of the MECIE.

We have provided important capacity support to the government, through the Office National de l’Environnement and its technical review committees (Comité Technique d’Evaluation – CTE), as well as to a range of stakeholders.  This has supported, greater understanding of the mitigation hierarchy and improved capacity to apply practice across national institutions, civil society and financial institutions.

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© Diane Detoeuf/WCS, © Efard Arevr/ WCS