Integrating Ecology into Land Planning and Development: Between Disillusionment and Hope, Questioning the Relevance and Implementation of the Mitigation Hierarchy

Round 1

Reviewer 1 Report

This opinion paper covers a highly germane subject area that while focused on the French context, the challenges of implementing the mitigation hierarchy are of international relevance. The paper was interesting, and the authors have attempted to bring together an impressive number of ideas and concepts, but in my view the paper fails to deliver on the title or add much to the existing literature. In its current form the paper is more of a review or collation of other author’s positions (and is overly heavy with direct quotations) than an opinion piece. My main criticism is that the paper brings together a lot of concepts and perspectives, yet not all are well explained and the paper becomes more of a collation of ideas at the expense of a cohesive presentation of the authors perspective, or ideas to advance resolution of the known issues. The paper lacks a) clear framing of the concepts, b) explanation of the issues in greater depth to enable shedding light in a more detailed way on the French context and specific issues, and c) clearly articulated proposed solutions, or pathways for improved practice. I think this can still be approached within the format of an opinion piece but it is my view that in its current form, the paper misses an opportunity to make a greater contribution to the existing (and growing) literature on this subject.

 

Additional comments:

 

Line 33: suggest referring to ‘the hierarchy’ here rather than ‘this tool’. The hierarchy is referred to as a tool throughout the paper, but in my mind the mitigation hierarchy represents a step-wise planning and action process (supported by policy directions) rather than a tool. Each step must be worked through and indeed various ‘tools’ are used to implement each of the elements of the hierarchy (e.g., accounting systems and models to calculate losses and gains in offset proposals).

Line 35: missing ‘adverse’ (unavoidable adverse impacts)

Line 37: ‘internationally applied’ rather than international

Lines 38 & 39: was offsetting a component of the hierarchy in France since 1976?

Lines 50-52: I do not understand this sentence. The mitigation hierarchy is a framework outlining a step-wise process to manage adverse effects from development, not a vision of the world.

Line 53: For many ecological aspects quite a lot is known

Line 64: Here to you mean intended objective rather than legal objective?

Lines 101 & 102: who is considering offsetting as a biodiversity preservation tool par excellence? Is the point cautioning against over selling what offsetting actually achieves in terms of biodiversity outcomes?

Lines 103 & 104: agree this is a critical question, but can it not be argued that the ‘avoid’ step of the hierarchy intends to do?

Line 118 and elsewhere: in some jurisdictions there are steps after offsetting, e.g., additional ecological compensation; although I agree that, generally, offsetting is considered the last step. However, I think it is key that the intention is a ‘last resort’ step, that applies only after efforts to implement the previous steps have been exhausted; and is the step of ‘least preference’ (not a go-to step) and ‘avoid’ is the step of greatest preference. This is not well explained in the framing of this paper. Of course, critique of the implementation of the hierarchy and the extent to which effort is extended to each step, and how far away from the intention of the hierarchy practice is totally valid (and a challenge of international relevance).

Lines 129–130: So, is there no standard national policy or practice guidelines in effect? Is this an issue of lack of policy or purely implementation? Both?

Line 131: this statement would benefit from examples of how the law can be exploited.

Line 156: ecology rather than ecological research?

Lines 177–178: does this reflect a lack of political will to shift the onus onto the developer?

Lines 156–160: is this suggesting that biodiversity offsetting is being used in France inconsistently with the fundamental (and internationally recognised) principles of offsetting?

Section 4: I think this section would be stronger if the authors presented a summary of the key identified issues (ill-informed / non-expert decision-makers; vested interests of territories with a stake in development projects; single focus can lead to other negative outcomes…) and provide examples and validation of the authors position for each

Section 5: I agree with the arguments set out in this section and the frustration with the offsetting as a conservation intervention. However, the argument – and in particular the French context– might be clearer if the steps of the hierarchy are teased apart – at which step (might be them all) is French practice failing? I also think the objective of offsetting (in this case NNL) is getting confused with the application of the hierarchy as a process for effects management. No net loss implies there is some loss, so indeed it is not a policy for protection but rather an attempt to reduce the adverse impacts on (at least some aspects of biodiversity) and promote more sustainable development. I agree offsetting is flawed and fraught, but throughout this paper it is not entirely clear if the authors are arguing against the use of offsets, or the general approach to effects management (the mitigation hierarchy and all mitigation, offset, and compensation actions).

Line 246: why does it make little sense to apply a NNL goal at a project level?

Line 249: again, new ideas presented with little substance, explanation or validation of concept. How would a less procedural/ridged/complex approach improve outcomes? How would it be any less played?

Lines 221–225: the meaning of Ko au te Awa, ko te Awa ko au (I am the river and the river is me) is much deeper than the authors present. Whanganui iwi have a genealogical linkage (whakapapa) to the river, a direct line of descent, reflecting an interdependence between people and the environment (as denoted in Ko au te Awa, ko te Awa ko au). As such Whanganui uri (descendants) have an obligation to protect the health of the river. The authors correctly identify the Te Awa Tupua law legally recognises the inseparability between people and the environment (but at line 225 remove ‘legal’ before inseparability and place it before ‘recognition’); however only Whanganui uri whakapapa to the river, not others.

Line 265: some explanation as to why it is difficult to pick up landscape effects in an ecological assessment would be useful – is one of the changes required a policy / standard practice to ensure these components are included in assessment of effects? Can they be?

Line 280: so the authors advocate a change to the way spatial planning is conducted in France?

Line 285: another example of a new concept (soil-based approach – what is this? what “compartment”? which disrupts the flow of the paper somewhat. This section gives the impression that the issues in a French context are much bigger and broader than the mitigation hierarchy. Where would the hierarchy sit within a reframed broader context? Or not at all? The author’s proposition is not clear.

Line 316: what are “relational values”?

Lines 397–410: what does this paragraph mean in the context of the paper? Feels like a collection of words and phrases that are disjointed from the messages of the paper.

Lines 434: ‘question the “goodness” of biodiversity – yet another example of yet another concept / idea that is thrown into this paper, but not well integrated or the relevance of it to the messaging of the paper made clear.

Lines 436–438: this is true, there is a wealth of literature on uptake and adoption of environmental practices and participatory processes to work with stakeholders and communities. Again, new topics and ideas which are not well supported, referenced, or integrated into the paper.

Lines 469–474: can the authors provide examples of these? Certainly, it makes sense to not oblige an outcome that does not make ecological sense. In terms of impact assessment and defining impacts – if the French process is not guided by standard practice or ecological guidelines, have the authors looked to other jurisdictions to see if there are existing practices that could be recommended for adoption or adaption for application in France?

Author Response

Please see the attachment.

Author Response File: Author Response.pdf

Reviewer 2 Report

The manuscript coded as sustainability-1409722 raised serious concern on integrating ecological issues in land planning and development beyond merely biodiversity. This is critical for sustainable development. The manuscript is well written and my only suggestion is to integrate more relevant references from the field of Ecology to enhance the points on the ecological issues surrounding land planning and development.

Possible ones are given bellow:

1. Theobald, DM,  Spies, T, Kline, J, Maxwell, B,  Hobbs, NT,  Dale, VH. 2005. Ecological support for rural land-use planning. ECOLOGICAL APPLICATIONS  15: 1906-1914.
2.  Gaaff, A,  Reinhard, S,2012. Incorporating the value of ecological networks into cost-benefit  analysis to improve spatially explicit land-use planning. ECOLOGICAL ECONOMICS 73: 66-74.
   
   
3. Jalkanen, J,  Toivonen, T, Moilanen, A. 2020. Identification of ecological networks for land-use planning with spatial  conservation prioritization. LANDSCAPE ECOLOGY  35; 353-371.
   
   
4. Werdiningtyas, R., Wei, Y., Western, A.W. 2020. Understanding Policy Instruments as Rules of Interaction in Social-Ecological System Frameworks. Geography and Sustainability. 2020, 1(4): 295-303. https://doi.org/10.1016/j.geosus.2020.11.004.
5. Yu, G., Piao, S.,Zhang, Y., Liu, L., Peng, J., Niu, S. 2021. Moving toward a new era of ecosystem science. 2021, 2(3):151-162. https://doi.org/10.1016/j.geosus.2021.06.004

Author Response

Please see the attachment.

Author Response File: Author Response.pdf

Round 2

Reviewer 1 Report

I thank the authors for their considered response to my previous review comments and explanations. The paper has been substantially revised and improved, largely addressing the issues I raised. I note that the authors have sought editorial input, but suggest that paper does however require further minor editing for typographical errors and the odd sentence where language and style can be improved.

Author Response

The authors would like to thank the reviewer for the response and very thorough review of our manuscript which resulted in substantial improvements. The manuscript was proofread again this Tuesday, November 9 by a professional (Victoria Grace from English Publications) to improve the English. The new version we are sending incorporates all of her corrections. We hope this will make the manuscript a little more pleasant to read. We are open to further help with the English language.