Among the environmental themes of an infrastructure project, biodiversity occupies a particular position. It is both the most technically visible (one sees the felled trees, the drained wetlands, the fragmented corridors) and the most difficult to translate into comparable figures. A hectare of secondary forest cannot be replaced by a hectare of recent plantation. A temporary pond that shelters an endemic species cannot be assessed in m² of surface area.
This complexity makes biodiversity a topic regularly under-treated in technical feasibility studies. The issues are mapped summarily, species listed without assessment of their status, sensitive areas identified from existing maps without field validation. The result is an ESIA that raises no alarm when reviewed by the national authority, and which explodes in lender due diligence.
I have seen several projects go through this sequence. The file passes the national stages, the financing agreement is under negotiation, the lender's E&S team triggers a specialist mission, and the finding falls: critical habitat not identified, species of conservation concern present on the footprint, ecological corridor fragmented. At this stage, the options are narrow and costly: reposition the route, dimension a compensation programme, sometimes abandon a project component.
This article presents the four pitfalls that explain these late discoveries and the method that allows them to be avoided from the scoping phase.
What lenders examine as a priority
International frameworks converge on how to treat biodiversity. IFC Performance Standard 6, AfDB Operational Safeguard 3, World Bank Environmental and Social Standard 6 share three structuring requirements.
Firstly, the classification of habitats. Habitats are distinguished into three categories: modified habitats (heavily transformed by human activity), natural habitats (functioning according to their own ecological dynamics) and critical habitats (presenting exceptional biodiversity value, defined by precise criteria such as the presence of threatened species, unique ecosystems, concentrations of migratory species). Requirements rise sharply between the three levels.
Secondly, the mitigation hierarchy. Any identified impact must be treated according to an imposed sequence: avoid the impact first, minimise next, restore what can be, compensate as a last resort. Recourse to compensation (biodiversity offset) is only legitimate after having exhausted the first three options.
Thirdly, the objective of no net loss. In a natural habitat, the project must aim for zero net loss of biodiversity. In a critical habitat, it must demonstrate a net gain in biodiversity, which implies active conservation measures beyond avoidance alone.
These requirements, set out by PS6 (paragraphs 13 to 19), are repeated in equivalent frameworks and structure the analysis of any serious lender.
Pitfall 1: confusing inventory and assessment
The first classic pitfall stems from a methodological confusion. A biological inventory (the list of species present on the site) is not an ecological assessment. The inventory describes, the assessment judges.
A consultancy that delivers a list of species with their Latin names and observation dates, without analysing their conservation status (IUCN Red List, national lists, international conventions), their functional role in the ecosystem, their specific vulnerability to project impacts, produces a document that will struggle to pass a technical review.
The assessment must answer three questions per identified species or habitat. What is its conservation value? What will be the intensity of the project's impact on its viability? What realistic measures can reduce this impact? Without these three answers, the ESIA remains descriptive and the lender will request a supplement.
Pitfall 2: underestimating seasonality
Biodiversity varies over time, on several scales. Seasonal migrations bring species that are only present for a few weeks a year. Reproduction concentrates populations in specific areas at certain periods. Hydrological conditions radically modify wetland habitats between dry season and rainy season.
An assessment conducted on a single field visit, in dry season for example, misses by construction everything that depends on other periods. This flaw is common in studies produced under schedule pressure.
The practical rule, for a project at stake, is to cover at least two contrasting seasons, and to make explicit in the report the periods sampled. In wetlands and in regions with marked seasons, three or four campaigns may be necessary. When the schedule does not permit this, it must be stated, the study accompanied by a margin of uncertainty and a protocol for updating during construction phase proposed.
Pitfall 3: forgetting the area of influence
The project's direct footprint is the easiest part to characterise. Lenders also examine the area of influence: zones that are not physically occupied by the project but that undergo indirect pressures linked to its existence.
This area includes temporary access routes used for the construction site, material sourcing zones (quarries, loans, borrowings), worker accommodation sites, induced hydrological modifications, permanent openings of tracks that facilitate subsequent penetration by other actors.
Indirect impacts on biodiversity are often more significant than direct impacts. A dam modifies the hydraulic regime over tens of kilometres upstream and downstream. A road in tropical forest opens the way to informal clearances that may concern areas of the order of several times the initial footprint. A high-voltage line multiplies avifauna collisions along its route and beyond.
The assessment must make explicit the area of influence perimeter retained and justify it. A perimeter reduced to the route alone is rarely accepted in review.
Pitfall 4: relying on compensation before having exhausted avoidance
Biodiversity compensation (offset) is a mechanism recognised by international frameworks, but strictly framed. It assumes that residual impacts, after application of avoidance, minimisation and restoration, are compensated by the creation or protection of equivalent ecological value elsewhere.
The conditions for an offset to be valid are demanding: demonstrated additionality (the compensatory value would not exist without the project), ecological equivalence (the gains truly correspond to the losses), assured permanence (the measures hold for the duration of the impact, or longer), and measurability (the gains and losses can be quantified according to a reproducible method).
The recurrent error consists in invoking compensation before even having seriously studied avoidance. Lenders detect this flaw immediately: they then demand proof that a repositioning of the route, an adjustment of the schedule or an alternative technology would not allow the initial impact to be reduced. If this proof is not provided, the discussion returns to square one.
Method: scope early, validate continuously, document
The operational issue, for a project owner who wants to avoid unpleasant surprises, lies in three practices.
Firstly, scope the biodiversity issues from the opportunity study, even before the final choice of site. An initial sensitivity analysis, based on existing databases (Key Biodiversity Areas, Ramsar, IUCN Red List, national protected areas), allows certain options to be eliminated or a more ambitious study schedule to be planned for the options retained.
Secondly, deploy seasonal field campaigns, conducted by qualified ecologists. The cost of these campaigns is marginal compared to the cost of a moratorium or late repositioning. The campaigns must be documented according to reproducible protocols, with georeferenced photos, signed surveys and dated reports.
Thirdly, maintain continuous dialogue with the competent national authorities (ministry of environment, park agencies, forestry authorities) throughout the study phase. These interlocutors hold information that does not always appear in international databases and their early involvement prevents subsequent blockages.
Biodiversity demands in-depth work that few projects accord at the right level of seriousness in study phase. The return on investment of rigorous work, measured in project advancement, in relationship with lenders and in public reputation, is nevertheless one of the clearest in the entire E&S field.
The rule I apply holds in one sentence: if the biodiversity study does not allow the lender's boxes to be ticked without additional effort, it is not finished. Any savings made at this stage costs five to ten times more when the lender requests a supplement, and sometimes weeks of schedule that the project cannot afford.
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