Performance Standard 6
Biodiversity Conservation & Sustainable Natural Resource
Management
Stakeholder Feedback
Frequently Asked Questions
IFC Response
Why does the definition of modified habitats not
include wetlands?
This has been corrected in the current draft of PS6. The last
sentence in paragraph 11 now reads “Modified habitats may
include areas managed for agriculture, forest plantations,
reclaimed coastal zones, and reclaimed wetlands”.
Why is IFC not using a more traditional definition of
‘habitats’? Why is the ‘ecosystem’ terminology not
used instead of habitat? And, why is IFC not using
an HCV (High Conservation Value) approach?
These questions are presented under one heading as their
answers are related. PS 6 purposely provides a broad
definition of habitats as ‘land areas’ (or ‘geographical units).
Modified, natural and critical habitat refers to the biodiversity
value of the land area as determined by species, ecosystems
and ecological processes. We understand that this is quite a
departure from a technical ecological definition of habitat (i.e.,
the place or type of site where an organism or population
naturally occurs). The reason for this is because projects are
discussed in the vernacular as being ‘in’ or ‘out’ of modified,
natural or critical ‘habitat’, which must account for other
ecological aspects in addition to species.
Some argue then to discard the habitats language in favor of
ecosystems; however, project areas may span more than one
‘ecosystem’, and the scale of an ecosystem itself is also not
easily definable. Although defining the project site in terms of
ecosystems is a valid approach as part of the biodiversity
assessment, this language also does not lend itself well to
communicating with the client’s non-ecologists (e.g., project
operators). Other stakeholders then opt for the High
Conservation Value (HCV) terminology and approach. The
problem with this approach is that HCVs are usually defined in
managed agricultural and forestry landscapes, and the
concept does not always lend itself to other types of areas or
project types (e.g., in protected areas, linear infrastructure).
Many industries with whom IFC works are also not familiar
with this terminology. Lastly, HCV areas would not be a direct
substitute for natural or critical habitat as a number of HCV
types are focused on ecosystem services. The requirements
for HCV Types 1 – 6 span across those currently found in
natural habitat, critical habitat and ecosystem services.
Moreover, client requirements for ecosystem services are
cross-cutting through Performance Standards 4, 5, 6, 7 and 8,
which are more appropriate places to cover some of the HCV
types.
In sum, we decided to remain with the habitats terminology for
this revision of the Performance Standards. IFC is trying to
navigate within a very wide range of clients, sectors,
governments, etc. The Performance Standards have been
operational for only four years, and the users of PS 6 have
familiarized themselves with this term. We will however
explain in GN 6 how HCV types overlap with PS 6
requirements.
What is the difference between set-asides and
biodiversity offsets?
Set-asides and biodiversity offsets are related, but different
concepts. Set-asides are land areas, usually within the project
site or in other adjacent areas over which the client has
management control, that are “…excluded from development
and… targeted for the implementation of conservation
enhancement measures”. Biodiversity offsets are usually
more robust than set-asides as they should be designed to
compensate for significant residual impacts only, and must
demonstrate no net loss, and preferably net positive gains of
biodiversity. Set-asides are the equivalent to “avoidance
measures” along the mitigation hierarchy and are sometimes
prescribed by the government to be a certain percentage (e.g.,
20 percent) of the land area to be converted. In order to
design a biodiversity offset however, practitioners would need
to carry out an assessment to determine that the loss of
biodiversity on-site is compensated for with the gains in
biodiversity at the offset site. Biodiversity offsets must be
designed to conserve the same biodiversity values that are
being impacted by the project (an ‘in-kind’ or ‘like-for-like’
offset).
Set-asides are a common form of mitigation in the industries of
agribusiness and forestry. The terminology is less familiar to
mining and oil & gas operators. Set-asides may also be areas
of HCV, a mitigation approach referenced in many of the
international voluntary international standards, such as Forest
Stewardship Council (FSC). We have incorporated the setaside terminology in PS 6 to be more consistent with some
forms of governmental legislation and with mature and
evolving international standards. Although mining and oil &
gas operators do not typically subscribe the ‘set-aside’
terminology, the practice is essentially the same. In areas of
natural habitat, certain areas of higher biodiversity value are
avoided and ‘set aside.’
The last bullet in the original paragraph 10 (under
natural habitat) has been eliminated –
“compensation to direct users of biodiversity.” Is
this covered elsewhere?
This was eliminated from PS 6 for several reasons: (a)
requirements for ecosystem services have been separated
from those for biodiversity/habitat. “Users of biodiversity” are
essentially “beneficiaries of provisioning and cultural
ecosystem services”, which is addressed elsewhere in PS 6;
(b) the topic of compensation (for biodiversity, natural
resources or for any other asset) is not well understood by the
primary practitioners of PS 6). Compensation is a topic that is
covered in depth under PS 5 and by social specialists. In the
upcoming revision of the Performance Standards, we will be
drawing stronger links between PS 5 and PS 6 to make this
more evident.
What is the meaning and purpose of the original
footnote 16?
Footnote 16 was meant to indicate that not all legally protected
areas and designated areas were by default critical habitat.
Only those areas whose “primary management
objectives…are comparable with the management objectives
as described for IUCN Management Categories Ia, Ib and
Category II” (footnote 16) were, by default, critical habitat.
However, we re-evaluated this during the second stakeholder
consultation, and this footnote will be removed. There will be
no pre-assigned determination of which legally protected and
designated areas will or will not be critical. An assessment will
take place in all areas to determine if they are critical habitat
per IFC’s definition. The bullet points in paragraph 17 will
apply to all legally protected and designated areas.
Why are the words ‘over time’ added to the end of
the second bullet of paragraph 15 in the critical
habitat requirements?
Those words were added to make it clear that some loss of
species may occur in the short-term at the project site, but the
mitigation measures should be defined to ensure that there will
be no net loss at the global/regional/national populations,
where applicable, in the long-term. Many stakeholders who
commented on this section stated that the “over time” wording
was redundant of “net”.
When is a Biodiversity Action Plan (BAP) or a
biodiversity assessment required?
A BAP will be required for all projects in critical habitats. A
BAP will be required on an as-need basis in natural habitats
and this will be explained in GN 6. Regarding biodiversity
assessments, this should be integrated into the initial ESIA per
PS 1. If it is not, or if this assessment is inadequate
depending on the nature and scale of the project, we will
request a supplemental biodiversity assessment.
In the Management of Renewable Natural Resources
section, why is IFC not requiring just ISEAL
compliance, which would remove questions on
whether other standards were credible or
independent?
The use of private voluntary standards is increasingly
important to IFC and its clients, particularly in the conservation
of biodiversity and stewardship of ecosystem services. IFC
has and will continue to support the development and
application of internationally-recognized and independentlyverified standards for living natural resources. Both ISEAL's
Code of Good Practice and ISO Guide 65 are included in the
PS as normative references. There are many standards
however, that are in development or in use that have proven
effective in managing PS 6 risks which are not "ISEAL
compliant" or even members of the ISEAL Alliance. IFC will
continue to carefully review international, regional and national
standards for conservation and strongly encourage clients to
verify their conformity with acceptable standards to manage
E&S risks.
Comments
IFC needs to integrate the concept of ecosystem
services throughout the other Performance
Standards. References are made to PS 5 and PS 8 in
PS 6 that have no follow-up requirements in either of
these two Performance Standards.
We agree, and have incorporated this cross-cutting topic
throughout the Performance Standards. In the other
Performance Standards, we will be using language that makes
sense to the practitioners of those particular standards.
The modification of the critical habitat definition
appears to be ‘watered down’, especially with
respect to the elimination of ‘biodiversity of
significant social, economic, and cultural
importance to local communities’. There are
currently no requirements in the other Performance
Standards on this topic that equal the level of
protection it once was afforded in PS 6. This topic
should be re-inserted into the definition of critical
habitat.
‘Biodiversity of significant social, economic, and cultural
importance to local communities’ is a subset of ecosystem
services. The previous placement of this topic was in critical
habitat, which is implemented almost exclusively by
biodiversity specialists who are usually not familiar with the
means to identify or assess natural resource-based assets in
terms of their value to local communities. Other social
scientists and cultural anthropologists however do this
routinely. We believe that this topic is better served if it were
mainstreamed throughout the Performance Standards.
IFC should significantly strengthen their
requirements for biodiversity offsets, and provide
better explanation for when offsets should be
considered. IFC should adopt Offset Principles as
established by the Business and Biodiversity Offset
Program (BBOP) and integrate them into PS 6
requirements.
We partially agree. To clarify, biodiversity offsets are not by
default a requirement in all projects in critical habitat.
Biodiversity offsets are however a valid option to mitigate
significant residual impacts if a suitable offset could be
designed and implemented in a manner that meets the other
critical habitat requirements defined in paragraph 15. The
definition of an offset is provided in footnote 6, which makes it
clear that offsets are to be used to mitigate significant adverse
impacts “…after appropriate avoidance, minimization, and
restoration measures have been taken”. We will not singularly
adopt BBOP’s principles and methods in determining the
suitability of proposed offsets. BBOP’s acquired experience
over the last several years is extremely valuable, and we
make reference to their guidance materials in the revised GN
6. These references will remain as guidance and we will
utilize other norms and practices as they develop.
The risks and identification process should include
‘cumulative’ impacts in addition to direct and
indirect impacts.
We partially agree, but cannot fully accommodate this
recommendation. The topic of cumulative impacts is covered
under client requirements in a project’s ‘area of influence’ as
defined in PS 1. The assessment of cumulative impacts will
not be included as a specific requirement of PS 6.
Clients should be required to manage and monitor
impacts through a system of adaptive management.
This should be a client requirement for projects in
critical habitats.
We agree, but we feel that this concept is already integrated
into PS 1 as part of the client’s ‘Social & Environmental
Management System’. We understand that the terminology
‘adaptive management’ is well-accepted among managers of
natural resources and biodiversity, but it is less familiar to
other users of the Performance Standards. We see the value
however in stressing the adaptive management concept in
particular for this Performance Standard.
The application of the Management of Renewable
Natural Resources section is not clear, and some of
the terminology used in this section, such as
‘plantations’, is confusing. The section should be
revised.
We appreciate the desire for clarity, and have sought to
address this in Version 2 of PS6.
Note: IFC’s responses to questions and comments are based on the current draft (Version 2) of IFC’s
Sustainability Framework. They are subject to change as the Framework is further revised. No text in
the Framework or in these interim comments and responses is final until approved by IFC’s
Management and Board.