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The inclusion of biodiversity in environmental impact assessment: Policy-related progress limited by gaps and semantic confusion


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Natural habitat loss and fragmentation, as a result of development projects, are major causes of biodiversity erosion. Environmental impact assessment (EIA) is the most commonly used site-specific planning tool that takes into account the effects of development projects on biodiversity by integrating potential impacts into the mitigation hierarchy of avoidance, reduction, and offset measures. However, the extent to which EIA fully address the identification of impacts and conservation stakes associated with biodiversity loss has been criticized in recent work. In this paper we examine the extent to which biodiversity criteria have been integrated into 42 EIA from 2006 to 2016 for small development projects in the Montpellier Metropolitan territory in southern France. This study system allowed us to question how EIA integrates biodiversity impacts on a scale relevant to land-use planning. We examine how biodiversity inclusion has changed over time in relation to new policy for EIA and how the mitigation hierarchy is implemented in practice and in comparison with national guidelines. We demonstrate that the inclusion of biodiversity features into EIA has increased significantly in relation to policy change. Several weaknesses nevertheless persist, including the continued absence of substitution solution assessment, a correct analysis of cumulative impacts, the evaluation of impacts on common species, the inclusion of an ecological network scale, and the lack of monitoring and evaluation measures. We also show that measures for mitigation hierarchy are primarily associated with the reduction of impacts rather than their avoidance, and avoidance and offset measures are often misleadingly proposed in EIA. There is in fact marked semantic confusion between avoidance, reduction and offset measures that may impair stakeholders' understanding. All in all, reconsideration of stakeholders routine practices associated with a more strategic approach towards impact anticipation and avoidance at a land-use planning scale is now necessary for the mitigation hierarchy to become a clear and practical hierarchy for “no net loss” objectives based on conservation priorities.
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Research article
The inclusion of biodiversity in environmental impact assessment:
Policy-related progress limited by gaps and semantic confusion
Charlotte Bigard
, Sylvain Pioch
, John D. Thompson
UMR 5175 Centre d'Ecologie Fonctionnelle et Evolutive, CNRS, 1919 route de Mende, 34293, Montpellier Cedex 5, France
UMR 5175, Centre d'Ecologie Fonctionnelle et Evolutive, Universit!
e de Montpellier - Universit!
e Paul-Val!
ery Montpellier, Route de Mende, 34199,
Montpellier Cedex 5, France
Montpellier M!
ee M!
etropole, 50, place Zeus, CS 39556, 34961, Montpellier Cedex 2, France
article info
Article history:
Received 6 February 2017
Received in revised form
12 May 2017
Accepted 19 May 2017
Available online 26 May 2017
Environmental impact assessment
Mitigation hierarchy
Conservation science
Land use planning
No net loss
Natural habitat loss and fragmentation, as a result of development projects, are major causes of biodi-
versity erosion. Environmental impact assessment (EIA) is the most commonly used site-specic plan-
ning tool that takes into account the effects of development projects on biodiversity by integrating
potential impacts into the mitigation hierarchy of avoidance, reduction, and offset measures. However,
the extent to which EIA fully address the identication of impacts and conservation stakes associated
with biodiversity loss has been criticized in recent work. In this paper we examine the extent to which
biodiversity criteria have been integrated into 42 EIA from 2006 to 2016 for small development projects
in the Montpellier Metropolitan territory in southern France. This study system allowed us to question
how EIA integrates biodiversity impacts on a scale relevant to land-use planning. We examine how
biodiversity inclusion has changed over time in relation to new policy for EIA and how the mitigation
hierarchy is implemented in practice and in comparison with national guidelines. We demonstrate that
the inclusion of biodiversity features into EIA has increased signicantly in relation to policy change.
Several weaknesses nevertheless persist, including the continued absence of substitution solution
assessment, a correct analysis of cumulative impacts, the evaluation of impacts on common species, the
inclusion of an ecological network scale, and the lack of monitoring and evaluation measures. We also
show that measures for mitigation hierarchy are primarily associated with the reduction of impacts
rather than their avoidance, and avoidance and offset measures are often misleadingly proposed in EIA.
There is in fact marked semantic confusion between avoidance, reduction and offset measures that may
impair stakeholders' understanding. All in all, reconsideration of stakeholders routine practices associ-
ated with a more strategic approach towards impact anticipation and avoidance at a land-use planning
scale is now necessary for the mitigation hierarchy to become a clear and practical hierarchy for no net
lossobjectives based on conservation priorities.
©2017 Elsevier Ltd. All rights reserved.
1. Introduction
Natural habitat destruction by development projects (e.g. linear
infrastructures, urbanisation, commercial centres, quarries, etc.)
has continued to cause the loss of genetic and species diversity, the
fragmentation of natural habitats and the degradation of ecosystem
function (Fahrig, 2003; McKinney, 2008; MEA, 2005). Many coun-
tries have thus developed instruments that attempt to ensure a «no
net loss »(henceforth NNL) of biodiversity with measures to
attenuate and mitigate the loss of biodiversity in the face of land
development (Bull et al., 2016; Hassan et al., 2015; Maron et al.,
2016). The development of the NNL paradigm, and its application
in land-use planning, has however encountered difculties due to
inconsistencies in the way its underlying concepts are framed
(Apostolopoulou and Adams, 2015; Bull et al., 2016; Gordon et al.,
2015) and how impacts are compared with a baseline to assure
NNL (Bull et al., 2014; Maron et al., 2016, 2015). Indeed, in practice,
NNL appears to be impossible, there is nearly always some form of
*Corresponding author. UMR 5175 Centre d'Ecologie Fonctionnelle et Evolutive,
CNRS, 1919 route de Mende, 34293, Montpellier Cedex 5, France. Tel.: þ33
E-mail addresses: (C. Bigard), sylvain.pioch@gmail.
com (S. Pioch), (J.D. Thompson).
Contents lists available at ScienceDirect
Journal of Environmental Management
journal homepage:
0301-4797/©2017 Elsevier Ltd. All rights reserved.
Journal of Environmental Management 200 (2017) 35e45
decline in biodiversity - a sort of generalised net loss impossible to
avoid, but never explicitly presented (Aronson and Moreno-
Mateos, 2015; Maron et al., 2012; Moreno-Mateos et al., 2015). In
relation to these difculties, many countries have developed two
main instruments to apply NNL policy in their land-use planning
The rst of these instruments concerns Environmental Impact
Assessment (henceforth EIA) that developed during the 1970's to
become a key instrument in site-specic planning for biodiversity
(Mandelik et al., 2005) and environmental management (Morgan,
2012). EIA contributes to the assessment and anticipation of
development projects and their impacts on environment and to the
adoption of pro-active policy to mitigate the impacts of such pro-
jects. However, many authors have pointed out recurrent weakness
in the identication of impacts and the conservation stakes asso-
ciated with biodiversity and landscape ecological context (Byron
et al., 2000; Drayson et al., 2015; Gontier et al., 2006; Thompson
et al., 1997; Treweek and Thompson, 1997). EIA has also been
criticised because choices among alternative options for develop-
ment projects are more often based on socio-economic consider-
ations than on ecological arguments (Bonthoux et al., 2015), the
delimitation of the area used to assess impacts is often made on a
non-ecological basis (Geneletti, 2006), measurable indicators or
quantitative predictions are rarely used (Mandelik et al., 2005;
Samarakoon and Rowan, 2008), and the relevance of an impact is
unclear (Atkinson et al., 2000; Khera and Kumar, 2010). In addition,
the study scope is often poorly dened or too narrow; many studies
only assess biodiversity in terms of species' populations with little
attention paid to understanding of effects on ecological processes,
ecosystem function or genetic variation (Atkinson et al., 2000;
Gontier et al., 2006; Khera and Kumar, 2010). Finally, an absence
of precise denitions and correct understanding of ecological pro-
cesses makes the identication of what represents a signicant
impact difcult (Briggs and Hudson, 2013; Geneletti, 2006).
EIA provides basic information for the identication of NNL
objectives within the context of a second major policy instrument,
the so-called mitigation hierarchy. This hierarchy provides a policy
framework to identify the process by which environmental impacts
from development can be avoided, unavoidable impacts
reduced, and residual impacts offset(Maron et al., 2016). This
mitigation hierarchy has also become a subject of concern in terms
of its environmental efciency, social implications and ethical basis
(Gobert, 2015; Gordon et al., 2015; Levrel et al., 2015; Lucas, 2009;
Maron et al., 2016; Moreno-Mateos et al., 2015). Despite high sci-
entic tractability, it begets only moderate implementation trac-
tability, and clear-cut rules on how to classify certain impacts
within the mitigation hierarchy barely exist (Martin, 2015; Bull
et al., 2016; Maron et al., 2016). In addition, the common reliance
on offsetting to achieve NNL has received serious criticism due to
the fact that offsets are rarely adequate, complete offsetting may be
illusory due to the complexity of ecological processes (Gardner
et al., 2013; Moreno-Mateos et al., 2015) and weak institutional
organisation of the mitigation hierarchy impairs attempts to ach-
ieve NNL (Jacob et al., 2015; Lucas, 2009). Problems associated with
identifying ecological equivalence and the absence of a systematic
regional approach further undermine the efciency of the mitiga-
tion hierarchy (Habib et al., 2013; Kujala et al., 2015).
The objective of this study is to examine how biodiversity is
integrated into EIA and dened and treated in the mitigation hi-
erarchy. We examine this issue in relation to recent changes in
French policy aimed at improving the EIA procedure and the
implementation of the mitigation hierarchy. In this context, our
study addresses four main questions. First, how are impacts on
biodiversity taken into account in a large sample of EIAs, all elab-
orated within a single territory? Second, is there a signicant effect
of new policy that proposes to make a more detailed analysis of
biodiversity features and their inclusion in EIA? Third, how are
cumulative impacts taken into account in the study area? Finally,
how well do measures proposed in the EIA for the different ele-
ments in the mitigation hierarchy t French national guidelines and
denitions of the mitigation hierarchy?
2. Methods
2.1. Case study
To undertake this study we analysed 42 EIAs associated with
projects in a single territory, that of the Montpellier Metropolitan
Territory (31 municipalities) and nine adjoining municipalities in
southern France (Fig. 1). This form of territorial grouping allows the
different local municipalities to mutualise their objectives and
obligations (waste treatment, sanitation, economic development
) and to develop coherent urban land-use planning strategies.
The territory contains a patchwork of semi-natural Mediterranean-
type habitats rich in biodiversity, various agricultural areas and is
one of the fastest developing metropolitan territories in France.
The 42 EIAs we studied represent a large number of small-scale
projects each of which has impacts primarily on common species
and habitats and, to a lesser extent on protected habitats and
species. The EIAs for the 42 projects were elaborated between 2006
and 2016. Two major infrastructure projects that had EIA docu-
ments elaborated during this time period were not used in the
initial analyses because their impact concerned several munici-
palities and different types of ecosystem. Hence, the amount of
money and time invested in the EIA productionwas way above that
of all the other 42 projects. The two infrastructure projects are thus
not comparable with the 42 small-scale projects. We thus only used
the information in these two EIAs in the analysis of cumulative
impacts on biodiversity (see below). Thirty-nine of the develop-
ment projects are small-scale development zones or housing pro-
jects, there is one photovoltaic solar power plant project and two
short sections of local road construction. The EIA of each project
was obtained from the archives of the State environmental agency
in the study region (DREAL), the authority in charge of examining
EIAs. They represent all the available EIAs that have caused irre-
versible impacts on terrestrial natural habitats in the study region.
2.2. A data base to examine biodiversity inclusion in EIA
We conducted a systematic examination of the extent to which
biodiversity is included in each of the 42 EIAs. To do so we analysed
six criteria, or questions, that reect the organisation of the
different chapters of an EIA (Table 1). The rst criterion concerns a
baselinedescription of the impacted zone in terms of species and
habitats present, ecological networks, ecological equilibria and
ecological interactions. The second involves how dataare
collected and their pertinence. The third concerns a description of
the impactswhich may be positive or negative, direct or indirect,
temporary or permanent and can be cumulative with those in other
development projects. The fourth requires an assessment of alter-
native (substitution) solutions and a test of the compatibility with
existing planning documents. The fth involves descriptions of the
necessary measuresthat are proposed for implementation within
the mitigation hierarchy. The sixth criterion relates to propositions
for monitoring and evaluation. To provide quantitative and
qualitative response data in relation to these questions, 32 in-
dicators concerning how biodiversity is included in an EIA were
developed (Table 1). These indicators were developed in order to
encompass what the French policy reform and the national doc-
trine require in terms of biodiversity inclusion in EIAs.
C. Bigard et al. / Journal of Environmental Management 200 (2017) 35e4536
Each indicator is noted with a score of 1 or 0, depending on
whether the response is positive (inclusion of biodiversity) or
negative respectively. The sum of the scores for each indicator was
determined in order to examine how EIAs integrate biodiversity. To
do so, an Index of Biodiversity Inclusion(IBI), adapted from
Atkinson et al. (2000), was calculated. IBI calculation is based on the
number of positive answers (P) relative to the total number (N) of
questions (32 for EIAs involving offset measures, 30 for the others):
i.e. IBI ¼P/N.
We tested whether the adoption of new policy, aimed at
reforming the procedure for EIAs and the mitigation hierarchy in
France, has had an impact on the integration of criteria to more fully
assess impacts on biodiversity and measures for the mitigation
hierarchy. This policy came with the law n
2010-788 published on
the 12th July 2010 relative to national commitment for the envi-
ronment, with the application of the decree n
2011e2019 of
December 2011 and put into force in June 2012. The main changes
introduced by this reform concern the need to enlarge the scope of
EIA for all projects that may have a signicant impact on the
environment, the requirement of propositions for measures for
implementation within the mitigation hierarchy, an evaluation of
cumulative impacts, and the necessity of a monitoring plan and
environmental compliance (Qu!
etier et al., 2014). To examine the
effect of this policy we tested if IBIs for the 21 EIAs that were made
after June 2012 were greater than the 21 EIAs made before June
2012. Simply by chance the number of pre and post-June 2012 EIAs
was the same. To do so, we did a one-tailed non-parametric Wil-
coxon test (alternative greater) due to the non-normal distribu-
tion of data (result of Shapiro-test not shown). We then focused on
each indicator separately, and tested for an increase of positive
responses after June 2012 by comparing changes in the ratio of
positive to negative responses with a Fisher exact test. All statistical
analysis were made using R statistical software (R development
core team, 2016).
We also analysed the relationship between responses of pre-
dictive variables and the IBI of each EIA, in order to understand
which variables are linked to biodiversity inclusion in EIAs
(Appendix 2). The predictive variables tested are composed of four
qualitative variables: the involvement of expert naturalists in the
EIA, the need for offset measures, the need for an authorisation to
destruct the habitat of protected species and the type of habitat
impacted (for six different habitat types - woodland, cultivated
land, post-cultural semi-open habitat undergoing secondary suc-
cession to scrubland and woodland, wetland, Mediterranean gar-
rigues, and heathland and scrubland), and two quantitative
variables (the surface area of the development project and the
number of pages of the EIA dedicated to natural environment
issue). Environment impacts were taken into account if more than
25% of the study area is concerned. To test for a relationship be-
tween IBI and the qualitative predictive variables, we used
nonparametric one-sided Wilcoxon tests, and compared the IBI
score of EIAs presenting either a negative or positive response to
each qualitative variable. A linear regression was used to test for a
signicant relationship between the two quantitative predictive
variables and IBI scores.
To test for the cumulative impacts of the 42 development pro-
jects in the studied territory (Hawke, 2009) we examined the
spatial distribution of projects and the number of projects that have
Fig. 1. Spatial distribution of the 42 EIAs elaborated in and around the Montpellier Metropolitan territory in France from 2006 to 2016.
C. Bigard et al. / Journal of Environmental Management 200 (2017) 35e45 37
a moderate, high or very high impact on listed species using GIS
software. The level of impact is dened by expert judgment in the
EIA. We also quantied the number of projects that impact on each
of the listed species that incur impact in at least one EIA. The
identity of the listed species is provided in Appendix 1. They
correspond to priority species (from moderate to very high priority)
with a national protection status, listed in the European directives
and/or identied at a regional scale as patrimonialspecies.
Table 1
Criteria used to assess the inclusion of biodiversity in 42 EIAs in the Montpellier Metropolitan territoryfrom 20 06 to 2016. Criteria concern six questions that are assessed with
a total of 32 indicators. For each indicator, the number of positive responses (i.e., responses with a score of 1) before and after June 2012 are noted and signicant differences
between EIAs done before and after 2012 tested with a Fisher exact test.
Criteria Question n
Indicator Number of positive responses
June 2012
June 2012
Total number (%) Signicance of increase
after June 2012
Baseline Is the baseline comprehensive
enough to provide a basis to
evaluate impacts?
1Denition of an area of effects
(different to study area)
3 12 15 (35.7%) **
2Study of a larger area than the
project boundaries
1 15 16 (38.1%) ***
3Expertise on all groups of species 4 20 24 (57.1%) ***
4Detailed inventory of ora in the
study area
7 18 25 (59.5%) **
5Detailed inventory of fauna in
study area
4 16 20 (47.6%) ***
6Description of natural habitats 10 17 27 (64.3%) ns
7Natural features totalised on a
map of the study area
5 12 17 (40.5%) ns
8Study of local ecological
6 19 25 (59.5%) ***
9Study of regional ecological
0 7 7 (16.7%) **
10 Study of ecosystems, species and
0 7 7 (16.7%) **
11 Reference to/or study of
ecological interactions
0 0 0 (0%) 0
12 Reference to population
dynamics or studies
3 9 12 (28.6%) ns
13 Argumentation for inclusion of
common biodiversity
2 8 10 (23.8%) ns
Data Are data gathered in a reliable
way and correctly referenced?
14 Field trip 16 21 37 (88.1%) *
15 More than one season of
5 20 25 (59.5%) ***
16 Clear reference to database
12 20 32 (76.2%) **
17 Consultation of the relevant
scientic literature
5 15 20 (47.6%) **
Impacts Are all the impacts explained
and properly evaluated?
18 Evaluation of the signicance of
each impact
3 3 6 (14.3%) ns
19 Identication of direct and
indirect impacts
12 17 29 (69.0%) ns
20 Identication of temporary and
permanent impacts
15 17 32 (76.2%) ns
21 Description of possible
cumulative impacts
0 17 17 (40.5%) ***
22 Explanation of the method used
to evaluate impacts
4 14 18 (42.9%) **
Substitution Is there an attempt to avoid
impacts on natural
environments at the beginning
of the EIA?
23 Study of alternative solutions 0 4 4 (9.5%) ns
24 Study of the alternative without
1 0 1 (2.4%) ns
Measures Are the measures explained and
detailed enough to potentially
balance impacts?
25 Detailed description of mitigation
6 19 25 (59.5%) ***
26 Distinction between each type of
5 15 20 (47.6%) **
27 Use of a method to propose
offsets based on equivalence
0 0 0 (0%) N.A.
28 Reference to a time lag between
losses and future offsets
0 0 0 (0%) N.A.
and evaluation
Are ways to ensure success and
sustainability of measures
29 Mention of success probability of
mitigation measures
0 2 2 (4.8%) ns
30 Scheduling of a monitoring-
evaluation programme
1 12 13 (31.0%) ***
31 Denition of indicators for
monitoring and evaluation
0 5 5 (11.9%) *
32 Mention of sustainability of the
1 1 2 (4.8%) ns
ns, not signicant; *p <0.05, **p <0.01, ***p <0.001.
C. Bigard et al. / Journal of Environmental Management 200 (2017) 35e4538
2.3. Attribution of measures to the mitigation hierarchy
Finally, we examined how the 42 EIAs propose measures within
the mitigation hierarchy relative to denitions for each level of the
hierarchy in recent national doctrine (MEDDE, 2012) and guidelines
(MEDDE, 2013) proposed by the French Ministry of Ecology. First,
avoidance measure are those that supress any impacts ahead of the
project development by the abandonment of the project, changes
in its perimeter or surface area, or the choice of a new site or use of
technical solutions. Second, reduction measures involve the
implementation of technical solutions to alleviate impacts during
construction and exploitation. Third, offset measures aim to
maintain or enhance biodiversity features that are impacted by a
project. These include ecological restoration and the recreation and
management of natural habitats, species communities, and
ecological networks and can thus include the reinforcement of
natural populations or their reintroduction. Finally, supporting
measures can be proposed to improve the efciency or to ensure
the possible success of biodiversity offset initiatives and include
knowledge improvement, methodological development, etc.
We quantied the number of measures proposed within each
EIA for each of these four types of measure and re-evaluated and
recompiled the number of measures for each of these measures in
relation to denitions in the ministry doctrine. Then, we compared
the number of measures in each level as proposed by the EIA, with
the number of measures reclassied according to ministry deni-
tions and quantied the number of transitions among levels along
the hierarchy.
3. Results
3.1. Index of biodiversity inclusion and its temporal evolution
IBI ranged between 0.07 and 0.75 with a mean value of 0.38
(Appendix 2), i.e. on average a positive response was observed for
38% of the indicators per EIA. Fourteen EIAs (33%) had a very low IBI
(<0.2) and 15 EIAs (36%) had an index between 0.4 and 0.6. Only six
EIAs had indexes between 0.2 and 0.4, seven between 0.6 and 0.8
and none had an IBI >0.8. As a result, more than two thirds of the
EIAs showed either very little effort to integrate biodiversity
(IBI <0.2) or a higher than average IBI of 0.4e0.6.
These different groups showed a clear temporal difference in
their occurrence (Fig. 2;Appendix 2). We observed a signicant
increase in values for the IBI after 2010 (Wilcoxon test: w ¼303,
p¼1.22e-5) and after 2012 (w ¼411.5, p ¼7.72e-7). EIAs conducted
before June 2012 had an average IBI of 0.21 and those conducted
post-June 2012 had an average IBI of 0.55. The former test should be
viewed with caution given the small number (n ¼10) of EIAs prior
to 2010. The criteria that contribute to this increase are mentioned
3.2. Inclusion of biodiversity criteria and indicators
In terms of naturalist expertise on biodiversity, we found that
the inclusion of expert naturalist advice in a specic section of the
EIA represents a major contribution to the IBI (W ¼329, p<0.001).
Naturalist expert advice on the fauna, ora and habitats impacted
by a project was present in roughly 50% of the EIAs. In 25 EIAs (61%)
the spatial area of impacts due to the development project was not
clearly dened. When the studied area was described as going
beyond the current perimeter of the project, the limits were usually
dened on the basis of land-use borders (roads, eld boundary, etc.)
or with a buffer zone with an arbitrary width. In none of the EIAs
was there evidence of an attempt to assess this area on the basis of
the knowledge of species present in the zone or the functional
characteristics of the local ecosystem. Field studies to provide up-
to-date information were made in 37 EIAs (90%) but in only 25
(60%) of these fauna and ora were prospected in more than one
season (Table 1), even though two seasons are a minimum under
the Mediterranean climate due to the marked seasonal contrast
that impacts on biodiversity in this region (Thompson, 2005).
Nineteen out of 21 EIAs (90%) produced after June 2012 involved
surveying in more than one season and provide references of da-
tabases employed. Most of the studies provided clear information
on the databases used to make the EIA and 20 out of 42 (48%)
contain scientic references. In all 21 of the EIAs conducted after
June 2012 a large range of taxonomic groups were analysed,
whereas only four of the 21 EIAs conducted before June 2012 had
such information. Only seven EIAs (~20%) took into account impacts
on all three scales of biodiversity (ecosystem function, species di-
versity and genetic variation). Ecological interactions were not
included in any of the EIAs. In 12 of the 42 EIAs (~25%) there were
either references to population dynamics or there was a presen-
tation of impacts on ordinary nature(species or habitats without
a protection status or a specic regional stake).
Statistical analyses showed that the size of a development
project does not lead to a higher IBI and we detected no difference
in the IBI for projects impacting different types of habitats. The
larger the part of the EIA dedicated to the natural environment
(based on the number of pages in the EIA), the higher the IBI ob-
tained (Linear regression: F¼2.6948, p<0.001). The signicance of
impacts was only dened and evaluated in six EIAs (14%). In 27 EIAs
(64%) the nature of the impacts was detailed as being either direct
or indirect and either temporary or permanent. The necessity of an
authorisation to destroy protected species and their habitats or the
necessity of offsetting signicant residual impacts of the project,
also contributed signicantly to the IBI (W¼178, p<0.001 and
W¼264, p<0.001 respectively).
We observed a signicantly higher number of positive responses
concerning the inclusion of impacts on the local ecological network
after June 2012 (Table 1), i.e. in 21 EIAs, 19 of which were conducted
post-June 2012. Impacts at the scale of the regional ecological
network were only assessed in seven EIAs (20%), all of which were
Fig. 2. Index of biodiversity inclusion (IBI) as a function of EIA submission date and
temporal benchmarks for the EIA reform law n#2010-788 of July 2010 (dotted line)
and the EIA reform decree n#2011e2019 of December 2011 implemented from June
2012 (dashed line).
C. Bigard et al. / Journal of Environmental Management 200 (2017) 35e45 39
conducted after June 2012.
Cumulative impacts were assessed in 17 of the 21 EIAs published
after 2O12 and absent from all EIAs published prior to 2012 (Fig. 3).
In 2012, the three EIAs that identied a cumulative impact all occur
after June 2012. Basically, cumulative impact assessment involved
taking into account known projects spatially close to the project
under EIA, with an identication of whether individual species are
impacted in the neighbouring projects. In EIAs, this assessment can
range from a simple expert judgment to a further analysis of
impacted species, based on eld ecological valuation. Among the 17
EIAs which mentioned cumulative impacts, 12 included an
assessment of their impacts on listed species, nine detected cu-
mulative impacts due to the project, but only two of these explicitly
proposed to take them into account in the mitigation measures. As
a result, although projects assessed after 2012 more rigorously
described cumulative impacts, there was a lack of proposed action
to precisely quantify such impacts and propose adequate measures
within the mitigation hierarchy.
To examine cumulative impacts on listed species, the two
infrastructure projects that cross the territory from East to West
were added to the study of cumulative impacts. We found that 19
(20%) species are impacted by a single project, 37 species (38%) are
impacted by two to three projects and 41 species (42%) are
impacted by more than three projects, with a maximum of 20
projects impacting one species (Fig. 4). It should also be noted that
the number of projects that impact the study species is clearly
underestimated; most EIAs (60%) do not refer to cumulative im-
pacts and the older EIAs do not propose a complete study of species,
natural habitats and ecological functions.
Finally, only four EIAs (10%) studied alternative solutions with
criteria on the natural environment and none of the 42 EIAs studied
alternative solutions without the project(Table 1). Socio-
economic arguments relating to the need for accommodation or
employment and coherence with urban planning documents were
the primary reasons used to justify choices made for the project.
Mitigation measures were described and distinguished from one
another in roughly 50% of the EIAs. EIAs conducted post-June 2012
were signicantly clearer about propositions than pre-June 2012
EIAs an important point for the results presented below. For the
nine EIAs that proposed offset measures, methods based on
equivalence between losses and gains were never used and none of
the EIAs referred to a time lag between destruction and offset
measures. Proposals for monitoring and evaluation were provided
in only 13 EIAs (30%) and in these EIAs only one out of three pro-
vided ecological indicators with which to evaluate and monitor the
benets of mitigation measures. There is almost no mention about
how to assess the success and sustainability of the mitigation
3.3. Attribution of measures to the mitigation hierarchy
For the 42 EIAs analysed in this study, a total of 358 measures
were proposed for the different elements of the mitigation hier-
archy. The number of measures proposed in EIAs published after
June 2012 (n ¼243) was twice as high as in those published prior to
June 2012 (n ¼115). When we compared proposed measures with
ministry denitions for these different elements of the mitigation
hierarchy, we found that only 39% of the proposed measures t the
denitions of the national guidelines (Fig. 5). Most of the proposed
measures for avoidance were in fact measures to reduce impacts
(42 out of 50 proposed avoidance measures). The ve measures
that were truly avoidance measures involved a reduction of the
boundary of the project and landscaping. Almost all measures that
proposed a reduction in impacts t the ministry denitions for a
reduction in the impact. For the 30 proposed offset measures, 11
were in fact measures that reduce impacts, and 17 were correctly
dened as offset measures. Lastly, after reclassication, two of the
proposed 37 supporting measures t ministry denitions, 32 are
Fig. 3. The number of EIAs that include (dark part of histogram) or do not include
(white part of histogram) a reference to cumulative impacts on biodiveristy in relation
to publication of the EIA reform law (July 2010 - dotted arrow) and decree (december
2011 implemented in June 2012 - dashed arrow).
Fig. 4. Number of listed species impacted as a function of the number of EIAs in which
an impact is detected.
C. Bigard et al. / Journal of Environmental Management 200 (2017) 35e4540
reduction measures, one is an offset measure and the two
remaining measures involve monitoring. The majority of EIAs did
not propose realoffset measures (only 9 out of 42 EIAs propose
offset measures). When present, offset measures showed little di-
versity. The most common measures are linked to a management
project to maintain open habitats that favour the presence of
Mediterranean listed species. It should also be noted that 35% of all
measures proposed in the 42 EIAs, were made in absence of a clear
statement about what type of measures were being proposed
(what we refer to as not qualied). When we analysed these
measures, we found that all such measures except one concerned a
reduction in the impact of the project (Fig. 5).
There was thus a major bias towards a weakening of the miti-
gation hierarchy when measures are compared with ministry
guidelines, primarily because avoidance is a less-used measure
than what propositions would suggest. A common feature of all
EIAs is that measures to reduce impacts were by far the dominant
type of proposition (Table 2,Fig. 5). In fact, only 5 of the 42 EIAs
provide for avoidance, prior to reduction measures (Table 2).
4. Discussion
For the Montpellier Metropolitan territory we have shown an
improvement in the inclusion of biodiversity indicators in the
framework of EIA that is correlated with the elaboration of a new
law (2010) and its application decree (2012). This policy reform
provides a legal framework to elaborate a more complete identi-
cation of the biodiversity concerns (baseline approach), impacts on
species, habitats and ecological networks, and the cumulative im-
pacts on biodiversity. However, several important weaknesses
persist and there is semantic confusion concerning proposed
measures for the different elements of the mitigation hierarchy.
4.1. Improved but incomplete integration of biodiversity
The policy reform proposed that alternative solutions to projects
and their impacts be carefully examined prior to project
development. However, our analysis of 42 EIAs reveals that such
alternative solutions are rarely explored; only 5 EIAs out of the 42
propose true avoidance measures. As a result, avoidance, which is
supposedly the rst element in the mitigation hierarchy, is rarely
employed. This is a critical result because it illustrates one reason
why no net lossis almost impossible to achieve. Basically,
biodiversity conservation occurs in a world where there is a back-
ground of generalised net loss(Maron et al., 2016; Moreno-
Mateos et al., 2015). This absence of a search for alternative op-
tions in the early phases of development projects is a clear indi-
cation of the priority for a systematic conservation planning
approach to the question of avoidance (and offset proposition) that
ensure more efcient biodiversity conservation at a territorial scale,
i.e. beyond the scale of individual projects (Kujala et al., 2015).
Although the identication of baseline information on the key
environmental issues in a site where a project occurs has been
more completely assessed in EIAs since the policy reform, several
important issues are open for improvement. For instance, the
denition of the study area (beyond the area directly impacted) is
in most cases made on an arbitrary basis instead of being made on
the basis of species, habitats and functional characteristics of the
local ecosystem. The policy reform produced a three-fold increase
in the inclusion of local ecological continuities in EIAs and stimu-
lated a small number of studies on regional ecological networks
(absent from all EIAs prior to June 2012). However, the global
ecological network and ecosystem levels are still rarely considered
and analysed in EIAs. Moreover, as illustrated elsewhere (Atkinson
et al., 2000; Gontier et al., 2006; Regnery et al., 2013a), we found
that the main focus is on listed species and habitats with less in-
terest in common species and habitats. In addition, we have shown
that the presence of listed species has a signicant positive effect on
IBI, i.e., their presence partly conditions the quality of the EIA. The
problem here is that common habitats and species play a major role
as a part of the habitat or landscape used by listed species (Elliott
and Whiteld, 2011; Gaston and Fuller, 2008) and in terms of
provision of ecological services (Tardieu et al., 2015).
As recommended by the policy reform, cumulative impacts have
Fig. 5. Total number of proposed measures (in the 42 EIAs) for each category of the mitigation hierarchy (in left) and how these numbers change (in right) once the proposed
measures are reclassied in relation to denitions of the national guidelines following the EIA reform law of 2010 (A- Avoid, R- Reduce, O-Offset, S-Support, M-Monitor, NQ- Not
qualied in the proposition).
C. Bigard et al. / Journal of Environmental Management 200 (2017) 35e45 41
been increasingly identied in EIAs. However, their analysis and
quantication remain supercial; the majority of EIAs that refer to
cumulative impacts do not propose adequate measures to reduce
them within the mitigation hierarchy. This is despite our nding
that cumulative impacts are a common feature for listed species in
the study area. The accumulation of impacts by numerous, small
and isolated projects, that individually may have minor impacts on
biodiversity in comparison with large individual projects, leads to
important cumulative impacts on listed species. This represents a
second major reason why the objective of no net loss remains
practically impossible to currently achieve within the mitigation
hierarchy. The issue of how to correctly assess cumulative impacts
raises several questions for the scientic community working on
the efciency of no net loss policy and the mitigation hierarchy
(Halpern and Fujita, 2013; Kiesecker et al., 2010; Tallis et al., 2015).
Hence, there is a need for a methodology to assess such impacts in
order to go beyond the rst come, rst servedlogic that unfor-
tunately persists (Qu!
etier et al., 2014). One methodology to include
cumulative impacts within land use planning could be a form of
strategic environmental assessment (Whitehead et al., 2016).
In addition, the capacity of EIA to take into account environ-
mental issues is directly linked to the issue of determining what
signicant impacts actually represent (George, 1999). In our study
we found that the true signicance of impacts is rarely dened or
explicitly addressed (i.e. in only six EIAs). This is probably because
the identication of signicantimpacts remains difcult due to
the lack of clarity about how to dene such impacts (Geneletti,
2006) and a lack of ecological details in the baseline study, poor
understanding of ecological process and a lack of monitoring and
feedback (Briggs and Hudson, 2013).
Our study illustrates the paucity of monitoring and evaluation
measures, despite the fact that half of the post-June 2012 EIAs
include a schedule for their implementation. This lack of feedback
on the true nature and extent of impacts and the efciency of
mitigation measures is a major concern (Briggs and Hudson, 2013;
Curran et al., 2014). The development of such feedback, including
negative results, could allow environmental managers to propose
more feasible and efcient measures. Reviews of wetland restora-
tion experiments (Benayas et al., 2009; Curran et al., 2014; Maron
et al., 2012; Moreno-Mateos et al., 2012) have shown that biodi-
versity equivalency between restored areas and reference areas is
rarely, if ever, reached, and that there are major limits to the
effectiveness of restoration action as a result of time-lags, uncer-
tainty and the measurability of success. Maron et al. (2012) also
argue that restoration action will attain no net loss only when
impacted ecosystem values can be measured, when results about
restoration trials already exist to evaluate their feasibility, and
when time-lag and uncertainty (ecological risk) are assessed and
claried in the loss compared to gainequation. Results associated
with ecological restoration should thus be examined with caution
(Benayas et al., 2009; Curran et al., 2014; Maron et al., 2012;
Moreno-Mateos et al., 2012; Palmer and Filoso, 2009). All in all, a
wider use of avoidance and reduction measures is a necessity that
can no longer be brushed under the carpet.
Finally, according to the EIA proportionality principle
gated in the policy reform, one would expect a larger project in
terms of surface area to have a higher index in terms of biodiversity
inclusion because the impact is higher. However, this is not the case
in our study. Also, we found no evidence that projects impacting
Table 2
Numbers of measures proposed and reclassied within the mitigation hierarchy (A- Avoid, R- Reduce, O-Offset, S-Support, M-Monitor, NQ- Not qualied) for each EIA
published pre-June 2012 (21 projects with a total of 115 measures) and post- June 2012 (21 projects with a total of 243 measures).
Principle that establishes a link between the size or the level of impact, as a
justication for the intensity, and the requirement level of precision needed to
assess the environmental impact (European Directive 2014/52/UE).
C. Bigard et al. / Journal of Environmental Management 200 (2017) 35e4542
semi-natural and typical Mediterranean habitats have a higher IBI
than those subject to human activities.
4.2. Blurred semantics
The reform policy is associated with a clarication of the nature
of the different measures for the mitigation hierarchy (avoid,
reduce or offset) and the modalities for monitoring and evaluation
of these measures. Our study reveals critical gaps in terms of both
incorporating a functional and wider-scale approach for biodiver-
sity integration in land-use planning and how actors understand
the true meaning of the different elements of the mitigation hier-
archy. Bull et al. (2016) previously identied this kind of ambiguity
and the lack of clarity concerning the concept of biodiversity offsets
in relation to no net loss objectives. Our study conrms this point
and provides a quantication of the types of confusion concerning
the different elements of the mitigation hierarchy.
For the 42 projects we studied, 61% of the proposed measures are
not correctly described in terms of their place in the mitigation hi-
erarchy and, after reclassication by comparison with the national
guidelines in the reform doctrine, it turns out that almost 90%
concern a reduction of impacts. Moreover, very few true offset
measures are suggested. For supporting measures, there was a major
confusion of what such measures represent. This kind of measure
should concern action to improve knowledge (research, experi-
mental project) and methods, to implement a larger-scale conser-
vation strategy, and/or to delimit protected areas, all of which
should contribute to improve the effectiveness of offset measures.
But almost all supporting measures were, according to ministry
denitions, measures that directly relate to impact reduction. So, in
practice, a reduction in impact is by far the most common measure
and after reclassication all EIAs have at least one reduction mea-
sure. Indeed, the 42 reduction measures proposed in EIAs as
avoidance measures do not supress impacts on natural environment
features, they simply minimize them. For instance, propositions (for
avoidance in some EIAs) based on the adaptation of the construction
schedule for species or the maintenance of ecological network fea-
tures in the impacted site do not avoid or supress impacts, they
reduce them. Only a change in the project perimeter or its reduction
so as not to impact the identied species or features of the ecological
network would represent true avoidance. Likewise, nesting box
installation in the development project siteor plantation of native
ora for green areasare proposed in EIA as offset measures, but in
fact, they attenuate (i.e. reduce) impacts. The second stepin the
mitigation hierarchy is thus more common than alternative solu-
tions, avoidance is rarely proposed.
The semantic confusion in the denitions of avoidance, reduc-
tion, offset and supporting measures may stem from a lack of un-
derstanding of ministry guidelines, or from the technical and
economical facility of implementing reduction measures rather
than searching to avoid impacts or implement offset measures that
are often more expensive and more constraining for the developer.
This issue could be resolved by the formation of consulting agencies
that elaborate EIA and clearer explanation of what different mea-
sures actually are in terms of the mitigation hierarchy. Enhance-
ment of regulatory agency control, through standardisation of
methods, could also limit this problem. Such options could ho-
mogenize and reduce misunderstanding among stakeholders,
optimize decision-making in terms of biodiversity conservation,
and improve the IBI scores of EIAs. For true avoidance measures to
be proposed, developers and experts should be in contact from the
very beginning of the project conception to make changes in the
project boundaries and its global form that avoid impacts. Hence, a
real anticipation of where and what to avoid remains a critical step
towards making mitigation measures more efcient in terms of
biodiversity conservation (Kareksela et al., 2013; Kujala et al., 2015;
McKenney and Kiesecker, 2010; Regnery et al., 2013b).
Finally, the proposition of mitigation measures does not ensure
their practical implementation and success in the eld, especially
during the construction and operation phases. Hence, there is a dire
need for monitoring measures that assess any positive effects of
reduction and offset measures on biodiversity conservation. Offsets
should be seen as a last resort solution, with more emphasis and an
accurate focus on avoidance and reduction measures. Otherwise no
net loss will remain a lost cause.
5. Conclusion: towards a territorial-scale analysis
Progress on EIA mitigation propositions reects a shift in
approach to biodiversity conservation. Gontier et al. (2006) pro-
posed three scales of approach to characterize biodiversity inclu-
sion in EIAs: (i) an approach focused on single sites or single
biodiversity element with no general overview, (ii) a functional and
dynamic ecosystem approach and (iii) a habitat suitability
approach based on processes. The policy reform in France recom-
mend an approach focused on the natural habitats, animal and
vegetal species,ecological continuities,biological balance, ecological
functions, physical and biological features that are the support of
former elements and services provided by ecosystems(MEDDE,
2012). This has stimulated a move towards a patchwork and
habitat suitability approach in which ecological connectivity and
cumulative impacts are targeted. However, despite the evolution of
such guidelines and their ambitions, the gap between EIA
commitment and practice thus persists. This result highlights the
dilemma discussed by Calvet et al. (2015) in which the higher the
ecological complexity, the more difcult it is to achieve ecological
equivalency and no net loss.
Our study also illustrates the pertinence of a territorial-scale
assessment of impacts on biodiversity in order to more efciently
contribute to no net loss. In our study area, a correct assessment of
cumulative impacts is absent from land-use planning and impacts
on ecological networks are only partially addressed. Hence, the
development of a territorial strategy that shifts from an approach
based on treating symptomsat the scale of individual projects to
a more preventive approach focused on the avoidance of biodi-
versity loss and mitigation of cumulative impacts is now necessary.
In this context, Strategic Environmental Assessment, a tool that
assesses the impacts of policies, plans and programs (Wood and
Djeddour, 1989), could be used as an instrument to help formu-
late a proactive and more strategic approach in the early stages of
the decision-making processes (Bina, 2007; Partidario, 2015). For
such reasons, Strategic Environmental Assessment represents an
ideal tool to anticipate for avoidance in order to render mitigation
measures a true hierarchy based on priorities.
We thank the DREAL Occitanie for access to their archives and
staff at the Montpellier Mediterran!
ee M!
etropole for providing advice
and for their condence. We thank Perrine Gauthier for comments
on a preliminary version of the manuscript and Guillaume Papuga
for his help and encouragement. This work was carried out with a
PhD grant awarded to Charlotte Bigard from the National Associa-
tion for Research and Technology (ANRT) and funded by the Min-
istry for Higher Education and Research and Montpellier
ee M!
C. Bigard et al. / Journal of Environmental Management 200 (2017) 35e45 43
Appendix 2. Details of EIAs published pre-June 2012 (n ¼21) and post- June 2012 (n ¼21) with their overall IBI based on the
relative number of positive (P) and negative (N) responses to the different criteria (n ¼30 or 32 depending on whether offset
measures are necessary). Project types concern economic development or housing (EDH), infrastructures (INF) and one
photovoltaic solar power plant (PSP). The types of environment impacted are cultivated land (C), post-cultural elds (P), garrigue
(G), heathland and scrubland (HS), woodland (Wo), wetland (We) and urban zone (U).
EIAs IBI Number of responses Project
area (ha)
EIA number
of pages
Need for
Involvment of
expert naturalists
Environment impacted Need for authorisation
to destruct protected species
or habitats
Pre_1 0.20 6 24 EDH 2006 15.8 150 no yes X no
Pre_2 0.23 7 23 EDH 2011 25 52 no yes X X X no
Pre_3 0.23 7 23 EDH 2011 26 167 no no X X no
Pre_4 0.50 15 15 EDH 2011 19 86 no yes X no
Pre_5 0.27 8 22 EDH 2011 5108 no yes X no
Pre_6 0.40 12 18 EDH 2011 30 117 no yes X X no
Pre_7 0.63 19 11 EDH 2011 582 no yes X X no
Pre_8 0.13 4 26 EDH 2011 985 no no X no
Pre_9 0.10 3 27 EDH 2010 13 185 no no X no
Pre_10 0.07 2 28 INF 2008 369 no no X X no
Pre_11 0.47 14 16 EDH 2010 16.7 129 no yes X no
Pre_12 0.07 2 28 EDH 2009 11 116 no yes X no
Pre_13 0.07 2 28 EDH 2010 21 89 no no X no
Pre_14 0.13 4 26 EDH 2009 9268 no no X X no
Pre_15 0.07 2 28 EDH 2010 7.8 153 no no X X no
Pre_16 0.07 2 28 EDH 2010 481 no no X X no
Pre_17 0.13 4 26 EDH 2009 35.6 63 no yes X X no
Pre_18 0.07 2 28 EDH 2009 8112 no no X no
Pre_19 0.17 5 25 INF 2008 10 88 no no X no
Pre_20 0.17 5 25 EDH 2008 6100 no no X no
Pre_21 0.20 6 24 EDH 2011 39 71 no yes X no
Mean 0.21 6.24 23.76 15.19 112.9
Post_1 0.75 24 8 EDH 2014 12.5 219 yes yes X X yes
Post_2 0.57 17 13 EDH 2013 60 2014 no yes X X no
Post_3 0.37 11 19 EDH 2014 10 89 no yes X no
Post_4 0.63 20 12 EDH 2014 13.5 194 yes yes X yes
Post_5 0.75 24 8 EDH 2016 16 yes yes X yes
Post_6 0.60 18 12 EDH 2013 112 323 no yes X X no
Post_7 0.73 22 8 EDH 2013 15 286 no no X X no
Post_8 0.56 18 14 EDH 2013 39 392 yes yes X no
Post_9 0.50 15 15 EDH 2013 13.7 120 no yes X X no
Post_10 0.56 18 14 EDH 2013 23.5 197 yes yes X X no
Post_11 0.43 13 17 EDH 2013 12.8 169 no yes X X no
Post_12 0.59 19 13 EDH 2013 17 132 yes yes X X yes
Post_13 0.44 14 18 EDH 2013 14.3 130 yes yes X no
Post_14 0.50 15 15 EDH 2012 24.5 176 no yes X X no
Post_15 0.69 22 10 EDH 2013 25 117 yes yes X X yes
Post_16 0.33 10 20 EDH 2012 29 241 no no X no
Post_17 0.53 17 15 PSP 2012 66 277 yes yes X no
Post_18 0.50 15 15 EDH 2012 5.5 101 no yes X X no
Post_19 0.47 14 16 EDH 2012 8.3 161 no yes X no
Post_20 0.50 15 15 EDH 2013 5.2 246 no yes X X no
Post_21 0.63 19 11 EDH 2012 4.24 172 no yes X no
Mean 0.55 17.14 13.71 25.10 274
Appendix 1. Listed species that are impacted in the studied EIAs.
Taxonomic group Species
Avifauna Upupa epops,Otus scops, Clamator glandarius, Circaetus gallicus, Burhinus oedicnemus, Lullula arborea, Coracias garrulus, Emberiza calandra, Milvus
migrans, Anthus campestris, Falco naumanni, Carduelis cannabina, Merops apiaster, Athene noctua, Phoenicurus phoenicurus, Lanius senator, Caprimulgus
europaeus, Tetrax tetrax, Burhinus oedicnemus, Gelochelidon nilotica, Galerida cristata, Muscicapa striata, Anthus pratensis, Sylvia undata, Strix aluco,
Passer montanus, Sylvia melanocephala, Saxicola rubicola, Lanius meridionalis, Bubulcus ibis, Egretta garzetta, Tyto alba, Circus pygargus, Saxicola
rubetra, Sylvia cantillans, Emberiza hortulana, Tachybaptus rucollis, Oenanthe oenanthe, Sylvia hortensis
Reptile Malpolon monspessulanus, Chalcides striatus, Timon lepidus, Lacerta bilineata, Rhinechis scalaris, Psammodromus hispanicus, Psammodromus algirus,
Podarcis muralis, Tarentola mauritanica, Natrix maura, Anguis fragilis, Emys orbicularis
Mammal Miniopterus schreibersii, Pipistrellus pygmaeus, Pipistrellus kuhlii, Nyctalus leisleri, Rhinolophus ferrumequinum, Pipistrellus nathusii, Myotis blythii,
Erinaceus europaeus, Pipistrellus pipistrellus, Sciurus vulgaris, Hypsugo savii, Plecotus austriacus, Tadarida teniotis, Myotis capaccinii, Rhinolophus
hipposideros, Myotis myotis, Myotis emarginatus, Castor ber
Amphibien Hyla meridionalis, Pelodytes punctatus, Pelophylax perezi, Lissotriton helveticus
Insect Saga pedo, Zerynthia polyxena, Zerynthia rumina, Cerambyx cerdo, Coenagrion mercuriale, Oxygastra curtisii, Roeseliana azami, Arcyptera brevipennis
vicheti, Macromia splendens, Ischnura pumilio, Euphydryas aurinia, Lycosa tarantula, Uroctea durandi, Zygaena rhadamanthus, Satyrium w-album,
Gomphus graslinii
Plant Allium chamaemoly, Anemone coronaria, Gagea granatelli, Leucojum aestivum, Mentha cervina, Tulipa sylvestris, Astragalus glaux, Isoetes duriei
C. Bigard et al. / Journal of Environmental Management 200 (2017) 35e4544
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... NGOs can be supportive of sustainability efforts, but not directly mitigating negative impacts, and sometimes are token actions (Cuckston 2018). For example, some interviewees stated that avoidance measures are rarely implemented in practice and are often overlooked, weakening the first and most important step of the mitigation hierarchy (Bigard et al. 2017, Phalan et al. 2018. Businesses should implement strict adherence to the mitigation hierarchy (CSBI 2015) and best practice principles (BBOP 2012), alongside appropriate monitoring and adaptive management of progress towards targets can help ensure effective outcomes from actions. ...
... However, despite this increased interest and action, biodiversity remains low on the agenda of many companies, with actions taken to address biodiversity impacts missing or negligible in sustainability strategies (Bhattacharya and Managi 2013, Addison et al. 2019, Ecogain 2021. Although action is taken across the mitigation hierarchy in some companies, the avoidance stage is often poorly implemented (Treweek et al. 1993, Bigard et al. 2017, Sahley et al. 2017, and action taken as part of strategies can be supportive of biodiversity conservation but not materially linked to the negative impact of business activities (Driesen et al. 2022). This risks substantial negative impacts on biodiversity being masked by some positive but limited action (Wolff et al. 2018). ...
... This includes actions to minimize impact within value chains (Tscharntke et al. 2015, Morgans et al. 2018), actions to minimize the impacts of development projects (Hunter et al. 2021), actions to restore through CSR initiatives and wider biodiversity strategies (e.g., tree planting programs, habitat restoration; Fleischman et al. 2020;Coleman et al. 2021). Moreover, in Environmental Impact Assessments, multiple measures are put forward to mitigate development impacts, but few assessments detail the likely success of recommended actions based on available evidence (Drayson and Thompson 2013, Bigard et al. 2017, and a lack of monitoring of mitigation outcomes is a frequently identified challenge (Treweek and Thompson 1997, Drayson and Thompson 2013, Lewis et al. 2016. ...
Full-text available
Biodiversity conservation is currently facing extraordinary challenges but remains severely limited by funding. Thus, the importance of cost-effective conservation is being increasingly realised – requiring information on both the effects and costs of actions taken to conserve biodiversity. Yet, despite progress in collating and using evidence on the effectiveness of conservation in decision-making, the recording and use of cost data has received far less attention. This PhD aims to help bridge this gap by investigating the collection and use of economic data for conservation decision making, as part of wider research into evidence-based conservation. The research presented is structured into several stages: i) investigate the current state of cost reporting and the use of evidence (including costs) in conservation decision making, ii) develop frameworks and approaches to help improve the reporting of the economic costs and benefits of conservation actions, and the use of evidence in decision-making around biodiversity impact mitigation. Lastly, I then apply this thinking to two detailed case studies where I assess the costs and cost-effectiveness of different conservation interventions. Reviewing the published literature on conservation interventions, I identified low rates of detailed cost reporting. Reported costs often lacked important contextual detail necessary to interpret the data and apply it in different contexts. Where detailed costs were provided, they showed considerable variation, with differences in how costs were reported likely to explain much of this variance. I then conducted an interview-based study investigating the use of evidence in business-biodiversity decision making. This revealed a wide range of themes including the high reliance of professionals on experts, policy and guidance as a stamp of cost-effective, evidence-based practice. Several challenges to integrating biodiversity in the private sector were also noted, including the need for better understanding the economic costs and benefits of mitigation action. Building on these studies, I then developed i) a step-by-step framework for the standardised reporting of economic costs and benefits of conservation action, and ii) a set of principles for the use of evidence (including data on costs) to guide actions that businesses and consultants can take to minimize and compensate for their impacts on biodiversity. To demonstrate the complexities and importance of using cost data in decision-making, I then provide two case studies. The first of these studies assesses the costs and cost-effectiveness of actions to avoid and minimize the impacts of power lines on at-risk bird species in Spain. The study identified large variations in the effectiveness and cost-effectiveness of different actions to prevent collisions with at-risk bird species. Changing how cost is measured, by including the costs associated with negative impacts, can improve the apparent cost-effectiveness of mitigation measures, particularly those more effective measures which avoid impact at the outset. In the second case study, I used a dataset of field-level costs of commonly applied agri-environment interventions in the UK to investigate actions to protect and restore biodiversity in farmland. I identified a high variation in costs both between and within different conservation actions. Costs and cost-effectiveness varied depending on the inclusion of several inputs (e.g., fertilizer, pesticide) during implementation, field size, as well as the types of cost and benefit included. Understanding the variability in costs within actions, and how costs and cost-effectiveness are calculated, are critical considerations when assessing the feasibility of different actions to protect and restore biodiversity.
... Several papers referred to existing guidance documents (e.g., in Environmental Impact Assessments and Strategic Environmental Assessments) that clearly describe the different steps of the hierarchy and their application (Cullen 2006;Hayes et al., 2015). Even though there is an overall agreement about the usefulness of applying the mitigation hierarchy in relevant decision-making processes (Claireau et al., 2019;Jagerbrand and Bouroussis, 2021), the review of Environmental Impact Assessments conducted by Bigard et al. (2017) highlights the avoidance stage is often disregarded, and measures "to avoid'' are often actually measures "to reduce". Furthermore, Barbe and Frascaria-Lacoste (2021) take a critical view of the mitigation hierarchy and question whether the policy goal of 'No Net Loss of biodiversity' should be based on a tool (i.e., mitigation hierarchy) that, at its core, is meant for, and largely used, only to reduce the harm caused by economic development, mainly from new projects. ...
... They further argue that "the mitigation hierarchy is insufficiently effective or relevant from the ecological perspective" (p4), a sentiment echoed by other authors. For example, Bigard (2017) maintains there is often no search for truly alternative options for avoidance in the early phases of development projects (which would allow an impact to be avoided), and there is an overreliance on smaller revisions to reduce impacts. ...
... These have played an important role in the practical integration of environmental concerns into urban land-use planning. However, the Environmental Impact Assessment has faced much criticism due to a weak structure, built upon economic and legal values, far removed from ecology (Bigard et al., 2017;Barbe & Frascaria-Lacoste, 2021). Concerns that economic interests were prioritised over conservation measures were raised in the agricultural sectors (Kovacs et al., 2016;Lakner et al., 2020), Blue Growth in the marine sectors (Markantonatou et al., 2021) and the timber sector (Mazziotta et al., 2017). ...
Technical Report
Full-text available
The Mitigation Hierarchy is the sequence of actions (avoid-minimise-restore-compensate) to anticipate and avoid adverse impacts on biodiversity and ecosystem services. The avoid or prevent stage is the first and most important stage of the mitigation hierarchy in which developers anticipate adverse impacts on biodiversity before actions or decisions are taken. Action is then taken to prevent adverse impacts by considering different options in the project location, scale, layout, technology and phasing. Avoidance is often the easier, cheaper and more effective way than trying to restore a damaged habitat or offset elsewhere. The Mitigation Hierarchy application is mandatory in France, however, the French Biodiversity Agency put a request to Eklipse to find out to what extent the adherence to and implementation of the hierarchy is correctly applied and ecosystem services are considered and well documented. 13
... This includes allocating longer time periods for field surveys (Jaeger, 2015;da Silva Dias, 2017) and undertaking biological evaluations to directly measure the amount of habitat cleared or number of animals killed during construction (Gannon, 2021). This can ensure greater attention to monitoring of gene flow or underlying ecological processes and functions that support the longterm health of a species (Bigard et al., 2017) to strengthen conclusions, and deliver more adequate mitigation measures and more positive environmental outcomes. ...
... construction access and support facilities, presence of laborers, and supply chains). For example, recent meta-analysis of biodiversity considerations in EIAs in France found that, although EIAs have recently shifted towards acknowledging cumulative impacts, they "do not propose adequate measures to reduce them" (Bigard et al., 2017). ...
Technical Report
Full-text available
The purpose of this technical report is to address ecological connectivity during the development of roads, railways and canals. To provide an overview of practical, feasible science-based strategies for Protected and Connected Area (PCA) managers, transport practitioners, industry, conservationists and other interested stakeholders. It introduces and describes the numerous solutions that are available to support biodiversity and ecological connectivity conservation in, and adjacent to, PCAs. It promotes best practices and provides details for the various phases of infrastructure development.
... By analogy, we might fear the same situation for the more accepted mitigation assessment methods (MAMs), even though their general use was recently identified in the French Biodiversity Plan (Ministry of the Environmental Transition, 2018), in 'Target 6: Improve the effectiveness of biodiversity policy', as a driver to improve the implementation of the mitigation hierarchy and promote land planning that better respects biodiversity. Both institutional partners and researchers agree that the mitigation hierarchy is inadequately applied in France, largely because of the lack of standardized methods for assessing mitigation measures (Bigard et al., 2017;Jacob et al., 2015). Disseminating these methods in the field is thus a priority to improve the implementation of the mitigation hierarchy (Bigard et al., 2018). ...
The mitigation hierarchy (avoid, minimize, restore/rehabilitate and, lastly, offset or compensate) is one of the key regulatory mechanisms that exists to include biodiversity protection in land-use planning. Implementing the mitigation hierarchy requires the use by practitioners (developers, environmental consultants and government agencies) of operational mitigation assessment methods, or offset sizing methods. This study focused on one aspect of operationality: usefulness. Through an approach based on ergonomics, we analysed practices used in the field in order to concretely identify in what way an offset sizing method is useful to developers, consultants and public officials. The findings showed that sizing offset measures is a collective process involving all these stakeholders, that these practitioners vary significantly in their level of knowledge about ecology and their degree of expertise in the mitigation hierarchy, and that each method is not equally useful for each type of stakeholder. Our conclusion is that to improve operationality, these methods must be adapted into tools that are relevant to the specific user and context.
... A variety of methods, approaches, tools, and techniques are used to gauge various environmental and social parameters that help in forecasting cumulative effects (Smit and Spaling, 1995;Morris and Therivel, 2001). Despite this, the inclusiveness of CEIA reports is often denied due to lack of scientific rigor in one or a few aspects (Burris and Canter, 1997;Tullos, 2009;Pandit and Grumbine, 2012;Pavlickova and Vyskupova, 2015;da Silva Dias et al., 2017;Bigard et al., 2017). Ecological survey and monitoring is an integral part of the CEIA study, and primarily involves the collection of baseline data on various biotic and abiotic parameters of the ecosystems located within the project area (Gontier et al., 2006). ...
Cumulative environmental impact assessment (CEIA) at river basin level for hydroelectric projects is an evolving concept and has proved to be a useful tool to assess the cumulative impact of developmental projects on the natural ecosystems. However, the generality of CEIA studies is often contested because of methodological limitations , especially in the domain of biodiversity conservation and conservation planning. Ecological niche modeling (ENM) can be a useful tool in CEIA studies for conservation planning of threatened plants in hydroelectric project (HEP) areas. We elucidate this hypothesis taking the example of Lagerstroemia minuticarpa Debberm. ex P.C. Kanjilal, a critically endangered tree species in the Indian Eastern Himalaya. Standard ecological methods were employed to document occurrence records, estimate population size, and characterize habitats. ENM was used to estimate the species potential environmental niche and distribution areas. The possible impacts of HEPs on the potential habitats were predicted by overlaying the HEPs on the potential area map as well as using the conceptual network diagram. The study revealed that the species occupies an environmental niche characterized by humid to per-humid conditions, and is distributed mostly in the Lohit and Teesta basins. Potential areas of the species with high environmental suitability coincide with 19 HEPs, which point to a potential threat to the survival of the species. Network diagram indicated that project activities might deteriorate the habitats thereby affecting the population and regeneration of the species. Our study provides a framework for developing appropriate measures for species conservation and reintroduction at basin level using ENM.
Finance is a precondition for many of the activities that harm ecosystems, but how to address this underlying driver of biodiversity loss remains a topic of debate. This paper reviews the Task Force on Nature‐Related Financial Disclosures (TNFD), a corporate‐led effort that aims to identify how changes to biodiversity may create financial risks for companies and investors. This approach is also promoted as a strategy for managing the impact of business on biodiversity, with the assumption that risk disclosure will more effectively price biodiversity‐harming activities. We assess the potential of the TNFD toward this end, and invite conservation scientists, practitioners, and policymakers to engage critically with its theory of change. We find that the relationship between disclosing biodiversity risk and redirecting finance away from environmental degradation is tenuous and unproven, making this mechanism insufficient for addressing the impact of the financial sector on nature. We question the embrace of another industry‐led mechanism that implies that a lack of information is the greatest barrier to stopping biodiversity loss. Further, there are risks that this financial sector approach to biodiversity will reinforce the highly unequal concentration of power and wealth, which is itself inimical to transformative change, as called for by the Intergovernmental Science–Policy Platform on Biodiversity and Ecosystem Services.
European ecosystems and species remain under pressure from intensive agriculture and forestry, fishing, pollution, urban sprawl, invasive species and climate change. This book provides a detailed description and critical analysis of nature conservation responses, achievements and failures, motivated by the concerning state of nature and missed biodiversity targets. It summarises Europe's nature and the impact of human activities, and then gives an overview of relevant international biodiversity treaties and the EU nature conservation policy and legislative framework. The core of the book comprises chapters written by national experts, which cover the UK and twenty-five EU Member States, providing comparative case studies from which valuable lessons are drawn. Covering wide-ranging topics such as biodiversity pressures, legislation and governance, biodiversity strategies, species protection, protected areas, habitat management, and funding, this book is of interest to a wide audience, including academics and professionals involved in nature conservation and related environmental fields.
Full-text available
Infrastructures (public constructions) are necessary for people’s lives, but large infrastructures can be harmful to local ecosystems and wildlife. The ecological mitigation practices of more than 5000 public construction projects in Taiwan were reviewed. Among these cases, the reduction practices were 38%–58%, and the avoiding, minimizing, and compensation measures were nearly 20%. However, the number of statistical measures did not reflect the actual performance. This study developed a quick and operational assessment framework to assess ecological mitigation measures. The four indicators were ecological concern areas, number of ecological conservation measures, number of ecological conservation objects, and habitat quality. The assessment indicators were applied to 54 construction cases, and their performance was classified into excellent, good, fair, and qualified. The developed assessment indicators were proven capable of serving as a preliminary tool to determine the performance of ecological mitigation practices, and the criteria standard can be adjusted as cases are updated.
Full-text available
Biodiversity impact assessments under threatened species legislation often focus on individual development proposals at a single location, usually for a single species, leading to inadequate assessments of multiple impacts that accumulate over large spatial scales for multiple species. Regulations requiring ad-hoc assessments can lead to ‘death by a thousand cuts’, where biodiversity is degraded by many small impacts that individually do not appear to threaten species’ persistence. Spatial prioritization methods can improve the efficiency of decision-making by explicitly considering cumulative impacts of multiple proposed developments on multiple species over large spatial scales. We present an assessment approach and a unique case study in spatial prioritization tools were used to support strategic assessment of a large development plan in Western Australia. The application of the approach helped identify relatively minor alterations to development plans that resulted in significant reductions in predicted biodiversity impacts and directly influenced a proposal to expand the protected area network. Using these tools to assess tradeoffs between conservation and development will help identify planning footprints that minimize biodiversity losses.
Full-text available
The compensatory measures come from more or less acute conflicts linked to the presence of an impacting facility. They are seen as a way to improve the acceptability of externalities and nuisances generated by the facility (noise, pollution, risks…). Consequently, these measures have different shapes and try to solve the “scalar disjunction” (disequilibrium between the negative impacts, suffered by residents and local communities, and the positive effects which don’t concern them very much). Besides they can sometimes tackle the environmental inequities and take part to a better recognition of some populations.
Biodiversity conservation policies incorporating a no net loss (NNL) principle are being implemented in many countries. However, there are linguistic and conceptual inconsistencies in the use of terms underlying these NNL policies. We identify inconsistencies that emerge in the usage of eight key terms and phrases associated with NNL policies: biodiversity, frames of reference (i.e. baselines, counterfactuals), no net loss, mitigation hierarchy, biodiversity offset, in-kind/out-of-kind, direct/indirect and multipliers. For each term, we make recommendations to support conceptual convergence, reduce ambiguity and improve clarity in communication and policy documentation. However, we also warn of the challenges in achieving convergence, especially given the linguistic inconsistencies in several of these key concepts among countries in which NNL policies are employed. Policy implications. The recommendations made in this article, on improving clarity and supporting convergence on key no net loss (NNL) concepts, should help eliminate ambiguity in policy documentation. This is crucial if policymakers are to design robust policies that are (i) transparent, (ii) translatable into practice in a consistent manner and (iii) sufficiently understood and supported by stakeholders to be effective in practice.
The rising popularity of biodiversity offsetting as a tool for balancing biodiversity losses from development with equivalent gains elsewhere has sparked debate on many fronts. The fundamental questions are the following: Is offsetting good, bad, or at least better than the status quo for biodiversity conservation outcomes, and what do we need to know to decide? We present a concise synthesis of the most contentious issues related to biodiversity offsetting, categorized as ethical, social, technical, or governance challenges. In each case, we discuss avenues for reducing disagreement over these issues and identify those that are likely to remain unresolved. We argue that there are many risks associated with the unscrutinized expansion of offset policy. Nevertheless, governments are increasingly adopting offset policies, so working rapidly to clarify and—where possible—to resolve these issues is essential.