The Conservation, Mitigation and Biodiversity Offset (COMBO) program supports countries around the world that are striving to balance biodiversity conservation with economic development. Our approach encourages governments, industry, and civil society to apply the mitigation hierarchy with rigor. The mitigation hierarchy is a sequence of four steps – Avoidance, Minimisation, Restoration and Offsets – which are regarded as international best practice for addressing impacts on biodiversity from project development.

COMBO supports uptake of the mitigation hierarchy globally by working with a wide range of stakeholders. Our current focus is to help improve mitigation practices in four countries in Africa – Guinea, Uganda, Mozambique and Madagascar – and two Asian countries – Laos and Myanmar. These countries present opportunities for the conservation of globally important biodiversity. They are also faced with the rapid development of large, potentially impacting infrastructure projects. Our goal is to reconcile necessary economic development with conservation objectives by contributing to the definition and implementation of policies aimed at no net loss (NNL) or net gain (NG) of biodiversity. We also encourage aligning these policy goals with national and internationally agreed biodiversity targets (e.g. those that will result from the Convention on Biological Diversity’s 15th Conference of the Parties, COP 15).

The COMBO program’s foundational phase ran from 2016 to 2020. It is now in its second phase (2021 to 2025). Its core objectives are to achieve: (1) improved national policy and its application, particularly through cross-sectoral coordination; (2) the availability of tools and guidance for better use of biodiversity data to inform impact avoidance and other mitigation actions, including biodiversity offsets; (3) the development of essential governance, financing and implementation mechanisms; and (4) the necessary capacity of governments, industry, financial institutions and civil society to deliver successful outcomes.

COMBO works with a wide range of stakeholders to achieve the program’s  objectives. In the public sector, engage with policy-makers at the national level, for example in relation to environmental and social impact assessment regulations, to help shape policy and guidance that provides clarity to project proponents and others, and with  local government. Our partners include environment ministries and affiliate agencies,  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. and we help build the capacity of environmental and social specialist consultants hired by project developers. We work closely with development banks and private sector financial institutions to encourage application of high-quality lender standards. Conservation trust funds, amongst others, are important partners for developing innovative financing mechanisms, including in relation to offsets, and for assuring the expected conservation outcomes. We collaborate with civil society organisations because of their role in observing potential impacts on biodiversity and in holding 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 governments establish and improve policies and supporting governance systems to guide implementation of the mitigation hierarchy with the aim of achieving no net loss or net gain of biodiversity.Our approach is based on international best practice, as developed and promoted by the Business and Biodiversity Offsets Programme, the IUCN Thematic Group Impact Mitigation and Ecological Compensation (IMEC)and others, and as included in safeguards by international financial institutions, such as the International Finance Corporation (e.g. Performance Standard 6), the World Bank (Environmental and Social Framework) and Equator Principle Banks. To help address concerns that project-level no net loss or net gain approaches do not maintain or improve biodiversity overall, IMEC has identified opportunities for aligning mitigation policy with national biodiversity targets and international commitments expected to be agreed as part of the Convention on Biological Diversity’s post-2020 Global Biodiversity Framework. COMBO actively takes part in collaborative efforts to continue shaping best practice.

Over the past five years, COMBO has worked with governments to undertake policy and capacity gap analyses and to develop new legislation which requires that development projects achieve biodiversity goals such as no net loss through best practice application of the mitigation hierarchy. In Uganda, we advised the Government on the integration of mitigation measures and no net loss outcomes into the National Environment Act (2019) and biodiversity offset requirements in the Uganda Wildlife Act (2019). We have helped individual institutions develop implementing regulations that 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 the inclusion of mitigation requirements into the Regulation for the Conservation Law (2017) and on the Decree on Biodiversity Offsets Regulation (2017). We advised the Government of Guinea on the incorporation of 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 strategies.

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.

Knowledge Base

Planning effective measures to address potential direct, indirect and cumulative biodiversity impacts from project development relies on a range of biodiversity and related data across various scales. For example, it is important to understand the following characteristics of the biodiversity that may be affected: 

  • Biodiversity type: e.g. species, ecosystems, ecosystem types
  • Distribution or amount of biodiversity: e.g. number of individuals of a species; extent of an ecosystem
  • Condition or integrity: e.g. the population structure of a species; ecosystem integrity measures
  • Conservation significance and protection level: e.g. threat status based on IUCN Species and Ecosystem Red Lists, inclusion in Protected Areas or on national protected lists
  • Relative location of the biodiversity feature to other biodiversity and landscape features: i.e. connectivity or isolation of a feature
  • Threats and pressures on biodiversity
  • Temporal data: e.g. time series relating to the above characteristics

Ideally, maps and other spatial data products are prepared using such biodiversity information and are then publicly hosted by the government or another appropriate institution on an online portal. Guidance for users should also be prepared and posted. The data need to be updated regularly. They can be used for further analyses, to guide land use planning processes, inform conservation prioritisation, be incorporated into a National Biodiversity Strategy and Action Plans, feed into environmental impact assessments at strategic and project-levels to support the design of appropriate mitigation measures, including offsets, and are useful to assist with tracking and reporting on progress against biodiversity goals and commitments.

Where the biodiversity knowledge base still needs to be built and expanded, or where available data need to be compiled from many sources, a gap analysis is often a logical first step. COMBO has supported such gap analyses in its focal countries and continues assisting with the compilation and mapping of useful biodiversity data layers (e.g. ecosystem type maps, metrics) that will expand the information base. This involves close collaboration with many stakeholders in each country who are working to improve data on the state of biodiversity. In addition, we have been actively supporting the identification and development of national online platforms that make the information widely available.

Implementation Mechanisms

Biodiversity offset or ecological compensation projects can be delivered in several ways, including restoring degraded habitats, creating protected areas to conserve priority species and ecosystems (such as Key Biodiversity Areas), and - in some exceptional cases - through supporting the management of already established protected areas. Identifying and putting in place the necessary implementation mechanisms is crucial for long-term offset success. But this not a trivial challenge for policy makers or for project proponents needing to deliver on a no net loss or net gain requirement. For example, adequate financial provision needs to be made, effective financial and legal mechanisms must be set up to channel performance-based payments to communities delivering biodiversity outcomes, robust management structures, plans and partnerships involving a diversity of actors need to be established, offset registries of sites and activities and monitoring systems must be set up and respective responsibilities agreed. Government can greatly assist by setting up enabling governance systems, including cross-sectoral coordination mechanisms, and offering clear guidelines. 

COMBO’s programme of work includes a focus on testing and helping adapt implementation solutions to meet these needs in the current focal countries. Our approach is to work with key stakeholders to identify, and develop as necessary, appropriate operational models and to support the establishment of the systems and guidance needed for the long-term governance of biodiversity offsets.

Given the important role of Conservation Trust Funds in this regard, COMBO has established partnerships with such funds to support our efforts in identifying appropriate implementation mechanisms for offsets. In Mozambique, BIOFUND has contributed significantly to designing the national 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 is interested in expanding this role with COMBO’s support. There are also opportunities to work with other national conservation trust funds on offset financing and implementation as well as with other stakeholders.

Offsets, where well designed and implemented, can provide significant benefits for biodiversity and for local communities dependent on natural resources for their livelihoods. The involvement of these communities is essential for the long-term success of any offset system.

Capacity Building

Improved understanding of the mitigation hierarchy, including biodiversity offsets, and its practical application is a priority in efforts to help balancing conservation and economic development. We work with stakeholders nationally and globally to raise awareness and improve knowledge of how mitigation policy, supported by sound governance systems, can help with progress towards meeting biodiversity targets. We are currently working with several of our government partners to include technical advisors directly in the relevant departments to support the application of mitigation systems.

We have hosted and continue to run webinars related to COMBO’s work, often in collaboration with IMEC, and focused on the topic of mitigation, no net loss and net gain of biodiversity. We also run regular national training events for a diversity of actors. These include government officials from planning and licensing authorities, and those involved in policy development. This approach has allowed us to mentor individuals as they develop national policy, including mitigation guidance. Participants also include public and private companies, civil society and financial institutions. We have prepared detailed materials in several languages to support these training sessions. This includes twenty training modules that we will be revising and making widely available on the COMBO website and elsewhere. 

Partner training resources, which we helped develop, include the Biodiversity Offset videos prepared by several partners, including offset specialists from the IUCN Thematic Group IMEC, the University of Queensland, RMIT University, The University of Melbourne and University of Helsinki with the support of funding from the Australian Government’s National Environmental Science Program through the Threatened Species Recovery Hub.

Photos © Gregoire Dubois and Diane Detoeuf/WCS