This is a guest post by Céline Jacob, PhD Stu­dent on Marine and Coastal Bio­di­ver­sity Off­sets at CREOCEAN — Cen­ter for Func­tional and Evo­lu­tion­ary Ecol­ogy in Mont­pel­lier (France). This com­ment is the expres­sion of the author’s thoughts and expe­ri­ences and as such is acknowl­edged as a fruit­ful con­tri­bu­tion to the dis­cus­sion on bio­di­ver­sity off­sets. If you want to react or clar­ify your own posi­tion (under­pin or dis­prove Céline’s rea­son­ing), please leave a reply below!

I remem­ber dis­cussing with some col­leagues why I was strug­gling to work on marine bio­di­ver­sity off­sets. Of course, the con­cep­tual frame­work of mit­i­ga­tion hier­ar­chy applies both to ter­res­trial (by ter­res­trial I also take into account aquatic ecosys­tems and wet­lands) and marine ecosys­tems: con­cepts are the same, objec­tive of no net loss prin­ci­ple is pur­sued in both cases. Why both­er­ing me with this sub­ject when I can work on ter­res­trial off­sets on which a large amount of sci­en­tific arti­cles is avail­able, where I can get a few decades of feed­backs on imple­mented measures?

There are a num­ber of opportunities:

• While wit­ness­ing the imple­men­ta­tion of the Marine Strate­gic Frame­work Directive…
• While wit­ness­ing the pro­posal of the Direc­tive estab­lish­ing a frame­work for mar­itime spa­tial plan­ning and inte­grated coastal management…
• While wit­ness­ing the devel­op­ment of the No Net Loss Ini­tia­tive, pro­mot­ing a wider no net loss approach to bio­di­ver­sity and ecosys­tem ser­vices to achieve the over­all objec­tive of the EU Bio­di­ver­sity Strategy…
• We can’t set aside issues related to marine bio­di­ver­sity off­sets, wait­ing for bet­ter knowl­edge, bet­ter instru­ments, more incentives…

We are to use these oppor­tu­ni­ties and to take the steps needed to bridge the gap between marine and ter­res­trial bio­di­ver­sity off­sets imple­men­ta­tion and even go above and beyond.

Marine bio­di­ver­sity off­sets in the scope of EIA in France

To study marine bio­di­ver­sity off­sets, I have cho­sen to rely on the imple­men­ta­tion of a reg­u­la­tory pro­ce­dure: the Envi­ron­men­tal Impact Assess­ment (EIA). In France, as in other coun­tries, an EIA must observe the mit­i­ga­tion hier­ar­chy, i.e. propos­ing mea­sures that would avoid and / or reduce the adverse effects on ecosys­tems in order to min­i­mize the resid­ual impact. If a sig­nif­i­cant resid­ual impact remains, the EIA must define com­pen­satory measures.

Accord­ing to arti­cle R.122–2 of the French Envi­ron­men­tal Code, marine projects sub­mit­ted to EIA are: works, and infra­struc­tures real­ized on the mar­itime pub­lic domain (port and port facil­i­ties, con­struc­tion or exten­sion of coastal infra­struc­tures cov­er­ing a total sur­face equal or higher than 2000 m2), all power gen­er­at­ing facil­i­ties (off-shore plants, water tur­bines), all dredg­ing, efflu­ents, and oil platforms.

But how are these prin­ci­ples trans­lated into practice?

I have started with the review of around fifties French EIA con­cern­ing all types of project and ecosys­tems encoun­tered in the French waters.

In marine and coastal EIA, the impact assess­ment exer­cise appears to be par­tic­u­larly intri­cate lead­ing most of the time to con­clude at the absence of sig­nif­i­cant impacts. The rare mea­sures pro­posed to off­set resid­ual impacts could be ques­tioned in terms of equiv­a­lency and appro­pri­ate­ness (also see Vaissiere and al., 2014).

In fact, these EIA are mostly based on qual­i­ta­tive analy­sis (except for species or habi­tats with a pro­tec­tion sta­tus). Com­pen­satory mea­sures often com­pen­sate for a loss of uses related to an eco­nomic activ­ity and not for a bio­di­ver­sity loss. Com­pen­satory mea­sures often involve data col­lec­tion pro­grams (mea­sures that would have been refused in EIA on ter­res­trial ecosys­tems) and not in-kind compensation.

Thus, one of the main pit­falls of the mit­i­ga­tion imple­men­ta­tion for coastal and marine projects Ade­line Bas (PhD Can­di­date with EDF-EN) and I iden­ti­fied, is the weak­ness of the method­olo­gies used to assess losses due to a devel­op­ment project and gains cre­ated by a com­pen­satory measure.

More to come…