Loss-Gain Analysis to support policy drafting in Sabah, Malaysia

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1 Loss-Gain Analysis to support policy drafting in Sabah, Malaysia Amrei von Hase and Erin Parham BBOP Webinar Series, Forest Trends & Sabah Forestry Department

2 Focus on Sabah, Malaysia Sabah s Environmental Policy 2017: includes a commitment to work towards the adoption of a Net Gain policy. Forest Trends work* with the Sabah Forestry Department (SFD) involved: - Gap analyses (Policy, Capacity, Data) - Policy options and recommendations - Loss/gain analysis at the state-wide level to determine feasibility of Net Gain (NG) - Drafting of appropriate Policy * As part of SFD project under UNDP GEF GoM Biodiversity Conservation in Multiple-Use Forest Landscape, Sabah, Malaysia

3 Level of ambition? A No Net Loss or Net Gain approach, defined for a specific set of impacts and against a frame of reference. Initial premise An alternative compensation approach that contributes to meeting a defined conservation target (e.g. to protect at least 30% of the original extent of each forest type). NG of what? All or some biodiversity? Forests? NG relative to what?

4 NNL/NG relative to what? To what state or trend are we comparing losses and gains? Need to decide on reference scenario clarifies expected outcome of a policy Choice for L/G analysis: - Based on change - Incl. averted loss - In line with govt s ambitions

5 Approach to the L/G Analysis 1. Set out framework for analysis 1. Define scale, timeframe, scope, etc. 2. Consider policy options (scope and ambition: NG rel. to?) 2. Collect and produce good data layers 3. Do analysis and build scenarios to inform decision-making: Establish trend against which to compare loss and gain Include avoidance of impacts Project losses and offset requirements Estimate potential gains averted loss and restoration. 4. Review feasibility of NNL/NG presently? 5. Investigate alternative approach (e.g. framed around thresholds). 6. Make recommendations for policy

6 Data layers Forest types Forest cover/ land cover Forest condition Forest connectivity Areas where impacts should be avoided (based on laws & stds) Anticipated forest changes given information on: Land use rights and designations (e.g. plantation concessions) Land use plans (e.g. Sabah Structure Plan 2033) Rates of land use change Past land use changes to identify unregulated impacts Restoration potential of forests in Sabah Natural trends

7 Forest formations Forest formations (ecosystems) Forest connectivity Forest cover and condition Planned infrastructure Avoidance areas Land use designations

8 Approach to the L/G Analysis 1. Set out framework for analysis 1. Define scale, timeframe, scope, etc. 2. Consider policy options (scope and ambition: NG rel. to?) 2. Collect and produce good data layers 3. Do analysis and build scenarios to inform decision-making: Establish trend against which to compare loss and gain Include avoidance of impacts Describe starting situation Project losses and offset requirements Estimate potential gains averted loss and restoration. 4. Review feasibility of NNL/NG presently? 5. Investigate alternative approach (e.g. framed around thresholds). 6. Make recommendations for policy

9 NNL/NG: Establishing a plausible dynamic reference scenario Key elements to combine and steps to take: Distinguish impacts subject to NG Policy from those not covered by the policy ( scheduled vs unscheduled /exempt impacts and losses) Estimate exempt losses, based on adapted past rates of change, etc. Differentiate betw. prior to/ after introduction of NG Policy Estimate natural trajectory if no human intervention in landscape (e.g. forest condition/extent could improve in some areas and decline in others). Integrate existing commitments to protect or restore areas of forest to which gains from offsetting should not contribute (e.g. Aichi targets). What would this trend and outcome - look like over time? NB in Sabah: relatively comprehensive scope of policy

10 NNL/NG: Establishing a plausible dynamic reference scenario Sabah-wide (but there is variation across space and time!) Forest extent and condition Based on unscheduled (exempt) impacts /losses and natural forest trajectory Limited potential for using averted loss offsetting: More scope for gains from restoration / improvement

11 Working out likely forest losses: Inputs Mask out areas where impacts are to be avoided, incl Protected Areas Estimate forest loss (condition & extent) from various land use change drivers Industrial Oil Palm plantations Industrial timber plantations (ITP) Mosaic plantations Natural Forest Management (NFM) Infrastructure establishment + rates of change

12 Results: Loss projections (by land use driver) Projected is ~9% reduction in current forest cover relative to now

13 Estimating potential gains 1. Averted loss/ degradation: Preventing anticipated loss of unscheduled exempt impacts (i.e. those not subject to the NNL/NG policy) 2. Restoration and other positive conservation interventions: Improving forest condition, distribution) Variation in space and time BUT: Impact : Offset ratios high (1:12 ++) Greatest opportunity early on (averting large exempt impacts) Overall, limited opportunity for averted loss gains: may address 10-20,000 ha of scheduled impacts! Mostly in lowland and moderate-low condition forests: Several 100,000 ha of areas with restoration potential BUT COST?

14 NNL/NG: the findings Over a 20-year timeframe Gains from averting loss Projected losses due to scheduled activities & impacts Gains from restoring forest areas A Net Gain outcome is not feasible.

15 Reduce impacts Net Gain possible Over a 20-year timeframe Gains from averting loss of exempt activities & impacts Projected Projected losses losses due to due to scheduled scheduled activities & = activities impacts& impacts??? Gains from restoring degraded areas

16 Considering an alternative approach A No Net Loss or Net Gain approach, defined for a specific set of impacts and against a frame of reference. A compensation approach that contributes to meeting a defined conservation target or not to breach a minimum threshold (e.g. to maintain and protect at least 30% of the original extent of each forest type): Managed retention No complicated reference scenario / counterfactual No claim of NNL or NG A level of net loss accepted but loss is capped

17 Biodiversity value (currently forest extent) Managed retention 100% Remaining forest extent ~52% Some possible trajectories of net forest loss up to the threshold Compensation: - Is assessed relative to the current state of biodiversity and the target/threshold, - Current state must be above the target/threshold for Managed Retention to be appropriate, - contributes to meeting the target/not breaching threshold, - can involve averted loss or improvement/ restoration. 0% Currently conserved area: ~26% of Sabah s land mass Example of a minimum target/ threshold: formally conserve at least 30% of each of Sabah s ecosystems /9 Time

18 Outcomes from a Managed retention approach Starting point: Intact ecosystem Project-level approach: for every 1 ha impacted, 3 ha of forest protected Outcome: 25% of the ecosystem developed, 75% conserved. Ratios can be set to achieve a defined outcome in the landscape Starting point: ½ of ecosystem s original extent intact Project-level approach: for every 1 ha impacted, 3 ha of forest protected Outcome: 63% of the ecosystem developed, 37% conserved.

19 Outcomes from a MR approach IF e.g. >70% of original extent of ecosystem remains: Least Concern If <70% but >50% remains: Vulnerable If <50% but >20% remains: Endangered If <20% remains: Critically Endangered Ecosystem Threat Status % of remaining habitat protected Outcome of offsets Ratio of offset (x:1) 2:1 offset: 67% of remaining habitat secured 3:1 offset: 75% of remaining habitat secured 5:1 offset: 83% of remaining habitat secured 10:1 offset: 91% of remaining habitat secured 20:1 offset: 95% of remaining habitat secured 30:1 offset: 97% of remaining habitat secured

20 Managed retention approach Inputs used to derive illustrative results: Forest formations Conservation target/ minimum threshold of 30% of original extent of each forest formation Proportion currently protected Remaining forest extent (relative to original) We did two things: 1. Rapid classification of ecosystems according to threat status 2. Work out compensation ratios that would ensure no ecosystem declines below 30% of its original extent

21 First draft ecosystem threat status FRC Forest formations 2 Critically Endangered, 6 Endangered, 4 Vulnerable and 12 Least Concern forest formations

22 Initial results To be set!

23 Implications and recommendations for Sabah Applying a managed retention approach at least in a first phase: - Could achieve good outcomes for biodiversity / forests in Sabah - Is feasible (i.e. outcomes can realistically be achieved) - Easier system initially to put in place with lower capacity requirements to establish and run - Over time the system can be refined and improved, with a possible transition to Net Gain system at later stage (phase 2)

24 Some key messages o Policies based on dynamic reference scenarios are challenging because counterfactuals v complicated to construct, can be gamed. o Aligning compensation policy with existing conservation targets or desired outcomes improves consistency and allows for greater clarity of outcomes from compensation. o Honest communication around goals and likely outcomes is important: what can/will compensation achieve? o Thorough preparatory work (gap analyses, L/G analysis, scenario building) provides important information and reveals underlying assumptions, highlights what is possible or not, and is powerful for choosing between options and crafting sound policy.

25 Please note: The way forward regarding revised mitigation and compensation requirements and the Net Gain policy is subject to approval by the Sabah State s authority!

26 THANK YOU! Forest Trends team: Dr Amrei von Hase, Erin Parham Dr Agnes Agama Kerry ten Kate Michael Crowe With the Sabah Forestry Department As part of a GoM-UNDP-GEF funded project

27 Predicted impact (PI) Predicted impact (PI) The Mitigation Hierarchy including offsets + Biodiversity Impact No Net Loss (NNL) Net Gain Offset Additional Conservation Actions No Net Loss Offset Offset - Biodiversity Impact Restore Minimise Minimise Residual Impact Avoid Avoid Avoid Source: BBOP, adapted from Rio Tinto and Government of Australia 27

28 Biodiversity value Predicting and assessing the impacts of offsets Trend and outcomes WITH the conservation action WITHOUT the action The benefit of a conservation action is the difference between two scenarios, i.e. with and without the action. T = 0 (e.g. NOW) Time T = 1 (e.g. in two years time) (Adapted from Maron, Rhodes & Gibbons, 2013)

29 Biodiversity value Biodiversity value NNL compared to what? Choosing a counterfactual/ baseline as reference: e.g. NNL compared to a trend of biodiversity decline e.g. NNL compared to NOW Now Time Now Time 29