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Mainstreaming biodiversity conservation into Russia's energy sector policies and operations
Commissioning Unit: Russian Federation
Evaluation Plan: 2011-2017
Evaluation Type: Project
Completion Date: 12/2017
Unit Responsible for providing Management Response: Russian Federation
Documents Related to overall Management Response:
 
1. Recommendation:

There’s more work to be done.  The project has built the foundations, planted the seed.  There is much still to be done – but, importantly, there are opportunities to do it.  The Business and Biodiversity Platform needs to continue – and it will probably be led by non-state actors (e.g., WWF-Russia and the IUCN – if and when they open an office in Russia).  In whatever time remains, the project should seek to support everything possible to continue the momentum that has been generated through the project.

As suggested above, the project team has a responsibility to take the story forward.

Management Response: [Added: 2018/05/11]

The final project Steering Committee meeting on 11 December 2018 recommended to the RF Ministry of Natural Resources to consider establishing the Business and Biodiversity national platform as a measure to ensure sustainability and upscale of the Project outcomes.

In course of three months of Project closing, the team undertook measures aimed at creating the organisational and legal environment to support the establishment of the Business and Biodiversity platform in Russia.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Prepare analytical review on the legal possibilities of creating the B&B platform; update the previous version of concept for platform creation.
[Added: 2018/05/11]
Project Manager 2018/03 Completed
Hold a workshop to present the B&B platform concept in Russia
[Added: 2018/05/11]
Project Manager 2018/02 Completed
2. Recommendation:

Demonstrate and illustrate the mitigation hierarchy.  As has been mentioned, it was apparent that understanding of the mitigation hierarchy was not complete; there was still confusion and misunderstanding.  Whenever possible and drawing off the examples from the project, where activities and results sit in the mitigation hierarchy should be made clear.  In other words, the project should demonstrate where activities that have been carried out fit into the mitigation hierarchy, thereby illustrating the mitigation hierarchy, so as to enhance understanding of the mitigation hierarchy.  In addition, the report by Suzie Brownlie needs to be translated into Russian and widely disseminated (perhaps a summary on paper and the rest of the report electronically).

Management Response: [Added: 2018/05/11]

The Project Team fully shares the mitigation hierarchy ideology, and continues making every effort to demonstrate this hierarchy in Russia, both on cases from practice (both Russian and international), and by distributing the General Guideline on Biodiversity Assessment, the Mitigation Hierarchy and Offset Principles for Russia’s Energy Sector prepared by Suzie Brownlie under the Project. 

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Prepare a new chapter ‘Mitigation Hierarchy and the Outcomes of the UNDP/GEF - RF Ministry of Natural Resources Project’ explaining the Project activities from the point of view of the ARRO hierarchy.
[Added: 2018/05/11]
Project Manager 2018/03 Completed
Ensure translation into Russia of the Guideline on Biodiversity Assessment, the Mitigation Hierarchy and Offset Principles for Russia’s Energy Sector
[Added: 2018/05/11]
Project Manager 2018/03 Completed The Guideline has been published on the Project website and on the B&B website of the Russian Federal Agency for Oversight of Natural Resource Usage.
To ensure presentation and ownership of the Guideline by the targeted energy sector stakeholders
[Added: 2018/05/11]
Project Manager 2018/03 Completed The Guideline was presented at RusHydro and further adopted as a set of practical tools for the special RusHydro working group on BD conservation that would established to cover all RusHydro’s HPPs.
3. Recommendation:

Look for opportunities to disseminate and communicate results and good practices. There are opportunities and the project team should seek these out to share and disseminate the results and lessons from the project.  For example, the IUCN, other NGOs (e.g., the RSPB) and other organisations have business and biodiversity programmes. 

Management Response: [Added: 2018/05/11]

The UNDP PSO made arrangements for drafting 4 success stories about the Project, which will be published at established intervals on the UNDP website.  The Project also prepared the materials for UNDP to possibly present at the CBD COP-14.

The Project Manager worked with IUCN and the UNEP to make sure the following decisions are taken:

  1. IUCN will be pleased to contribute to reviewing the WWF Rating system
  2. IUCN will provide comments to the B&B Concept
  3. IUCN will contact the CBD Secretariat to promote the dissemination of the leanings of the UNDP/MNR-GEF project during the Business Forum (which will take place right before COP14) given the successful mainstreaming outcomes of the project in the same sectors that will be the focus of COP 14.
  4. A Side meeting will be organized with Rustam Sagitov, the Membership Unit and Boris during Council.

IUCN focal point will remain for all these actions and circulate as appropriate documents and information.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
4 success stories published and promoted by UNDP
[Added: 2018/05/11]
UNDP PSO 2018/04 Completed
4. Recommendation:

Close out various processes.  There are a number of processes that require completion before the project formally closes; the project team should ensure that as much as possible is elegantly closed and not left hanging.

Management Response: [Added: 2018/05/11]

The Project team and Project Support Office in Russia are making arrangements for the technical and financial closure of the Project 

Key Actions:

Key Action Responsible DueDate Status Comments Documents
For the UNDP PSO to ensure project closure in accordance with UNDP NIM rules and procedures
[Added: 2018/05/11]
UNDP PSO 2018/04 Completed
5. Recommendation:

Tackle financial institutions and lenders.  To build on the foundations that the project has built, the institutions that finance energy sector development projects (and other sectors) should integrate environmental aspects (including biodiversity) – akin to the Performance Standards of the IFC.  With the issue of the federal level legislation, this represents the most significant gap in the project.

Management Response: [Added: 2018/05/11]

The Project team agrees with the idea, however, the Project mandate does not provide for interaction with financial or lending institutions to mainstream in their work the criteria for evaluating infrastructure projects by the degree of biodiversity conservation issues implementation. The future B&B national platform might be able to tackle this topic, provided it is established in Russia.

Key Actions:

6. Recommendation:

Improve ESIA transparency.  While ESIAs (“EIA”) is obligatory, apparently the ESIAs themselves and the responsive Environmental Management Plans (EMPs) are not accessible in perpetuity.  This means that it is difficult to monitor and evaluate the degree to which they are implemented.  These documents need to be made available online in perpetuity.

Management Response: [Added: 2018/05/11]

In accordance with the Memorandum on the Transfer of Ecoratings of Oil-and Gas Companies and Mining Companies signed between the Project and WWF-Russia, the latter undertakes to develop the environmental responsibility ratings and refine their methodology.

One of the areas for  improvement is the inclusion of the criterion whether the EIA is available during the life of the project. The Project organised interaction between the WWF and UNEP: They agreed to work together to organise activities aimed at refining the ratings.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Hold a meeting to discuss improvement of the rating methodology
[Added: 2018/05/11] [Last Updated: 2018/10/23]
WWF-Russia, UNEP 2018/05 Completed History
7. Recommendation:

Expand eco-ratings to other sectors.  The project catalysed the expansion of the eco-rating system to the mining sector (thereby capturing the coal sector); there are other sectors to which the rating system could be expanded including, for example: i) the power-generation sector, and ii) the financial sector – thereby capturing the lenders and financiers.

Management Response: [Added: 2018/05/11]

In accordance with the Memorandum on the Transfer of Ecoratings of Oil-and Gas Companies and Mining Companies signed between the Project and WWF-Russia, the latter undertakes to develop the environmental responsibility ratings and refine their methodology. In this connection, WWF-Russia intends to use the methodology developed with the Project to create an environmental responsibility rating of the wool processing sector and for power generation companies. At the same time, WWF-Russia has been expanding its ratings to other countries, in particular, CIS countries. It has already prepared a rating of environmental responsibility of oil-and-gas companies in Kazakhstan.

In future, ratings may be developed for oil-and-gas or energy companies for the CIS countries (which may be of some interest for the UNDP-Russia Trust Fund).

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Drafting a rating for oil-and-gas companies of Kazakhstan on the basis of the methodology developed by WWF with the Project.
[Added: 2018/05/11]
WWF Russia 2018/01 Completed
Draft proposals on improvement of the rating methodology (were IUCN is concerned)
[Added: 2018/05/11] [Last Updated: 2018/10/28]
WWF Russia IUCN 2018/05 No Longer Applicable [Justification: The project is completed. Follow up to the recommendation is secured by third parties (WWF, IUCN), relevant consultations have been conducted with the WWF and IUCN, MOU signed.]
History
8. Recommendation:

Replicate to other regions.  While the project took on an additional two regions (from the originally proposed six regions), there are many other regions in the country.  This begs the question of how the processes of mainstreaming will be replicated in the absence of the project to catalyse the process. [There are some processes that operate at a national level but the project has demonstrated that operating at a regional level was productive and beneficial.]  It would, as a result, be worthwhile for project partners to reflect on how this replication may be best done and to initiate the process before the project closes (or transfer the responsibility to whoever is best placed to catalyse the replication).

Management Response: [Added: 2018/05/11]

This recommendation is appreciated as being highly relevant. At the same time, it is indeed difficult, in the conditions of the closing Project, to identify practical steps along the lines proposed.

We believe that of the tasks of the B&B platform, should it be established in Russia, is to support regional public initiatives within the B&B scope, unite such initiatives into a single network for sharing experience, knowledge, and initiatives. To start with, this network should include the regions of the Project’s presence. This will help regional Project experts and consultants (already continuing to implement the Project) to reunite into a single movement and to coordinate their activities. Then, with the assistance from these people, the network could start expanding to other regions, too.

The respective ideas were included in the updated B&B platform concept.

Key Actions:

9. Recommendation:

Synergies among the many projects.  As has been suggested in various places in the report, the project builds upon previous projects and was implemented in synergy with another set of projects.  In order to demonstrate and illustrate this, the project should make efforts to map these synergies and include this map in the project’s final report.

Management Response: [Added: 2018/05/11]

This recommendation is valid. The project Final Report now includes a new chapter, which clarifies the connection between the Project’s aims and purposes, and its outcomes, with CBD targets, Aichi goals, as well as with the NBSAP. A diagram illustrating these ties was prepared. The diagram was presented in the working meeting of the IUCN, which appreciated this approach very much and recommended using it for preparing materials for the COP-14 of the CBD.

The general report delivered by UNDP PSO on UNDP/GEF projects implemented in Russia is to offer an integrated picture of the contribution made by UNDP/GEF projects into Russia’s ecological development, the connections between the projects, and the synergies achieved. 

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Preparation of a new chapter in the final report ‘Outcomes of the UNDP/GEF - RF Ministry of Natural Resources Project and the Biodiversity Conservation Strategy in Russia’; preparation of a diagram depicting the connection between the Project outcomes and the CBD tasks.
[Added: 2018/05/11]
Project Manager 2018/03 Completed
10. Recommendation:

UNDP procedures.  Notwithstanding the comments made earlier about the inefficiencies of UNDP administrative systems – from a business perspective (see Section 3.3.3), there is a rationale for the way that they are (not least that UNDP is a global organisation and needs a system that is applicable across the many developing countries of the world).  Rather than just expect project partners to comply and adhere to the systems, UNDP should provide training to explain the rationale of why the administrative system are the way they are.  This would probably improve compliance and at least create goodwill among partners.

Management Response: [Added: 2018/05/11]

The recommendation to provide clarifications and carry out trainings to experts implementing UNDP/GEF projects as part of national implementation is very important and relevant. The 20-year experience of UNDP project implementation in Russia clearly demonstrates the efficiency of both the existing approaches and the UNDP procedures. We hope that the Russian experience and the experience of this Project in particular will be useful in other countries, too.

Key Actions:

11. Recommendation:

Licensing remains an issue.  The project also did not broach the licensing issues.  It is a global issue, apparently, with licensing agencies considering that social or biodiversity issues are not their responsibility.  They are simply concerned with the subsoil resources and allocate licenses on their basis – irrespective of what lies on the surface.  There is the assumption that the systems (e.g., ESIA, EMP, CSR, etc) that should follow the allocation of a license are sufficiently robust to cater for the above-soil issues.  However, as we have seen, this assumption is flawed; and, therefore, it is more that the licensing authorities are shirking their responsibilities and not abdicating them.  In the long-term, having the licensing authorities join the ranks of responsible peoples would be ideal.

Management Response: [Added: 2018/05/11]

The issue with the content of licenses for natural resource use (for the purposes of this Project, licenses for oil, gas and solid minerals) is one of the topical problems both of the present-day legislation and practice. In view of this, the Project took the following view throughout its term:

- Decisions about the location of infrastructure projects must be shifted to earlier phases, ideally to the phase of drafting the social and economic development strategy. To this end, the Project held two SEAs and prepared three corresponding guidelines.

- It is necessary to increase the weight of regional authorities, municipalities and public in the decision-making process regarding the granting of licenses for subsoil resource development by providing the latest information on the state of BD in the respective regions. To this end, three regional GISs have been developed that can be accessed on world-wide-web free of charge.

- Procedures for practical implementation of nature conservation activities specified in the licensing agreement and listed in the EIA must be improved. To this end, six practical guidelines and four national standards have been prepared.

These documents are freely available and can be used both in the regulatory activity and in practical work.

The members of the Project team will build on these ideas in the future, each at their job. 

Key Actions:

12. Recommendation:

Extend thinking to ecosystem services and ecological processes.  The project focused on biodiversity, the definition of which usually includes ecosystems, populations, species and genetic variation.  However, it does not include either ecosystem services or ecological processes.  Ultimately, our thinking should expand to include these and not remain focused on biodiversity alone.

Management Response: [Added: 2018/05/11]

The Guideline on Biodiversity Assessment, the Mitigation Hierarchy and Offset Principles for Russia’s Energy Sector contains the necessary information with regard to the aims and objectives of the Project. At the same time, we need to think out-of-the-box and think long-term. In this connection, it would seem advisable to inform the RF Ministry of Natural Resources about this recommendation as part of preparation of the next National Report on Biodiversity Conservation in Russia, and as part of preparation of the next Biodiversity Conservation Strategy and Action Plan for Russia. This information will be presented together with the final reporting materials to the RF MNRE.

Key Actions:

13. Recommendation:

Using all the tools available to improve levels of compliance.  Conservationists can be quite naïve.  This is probably best seen in the sphere of providing benefits to offset the apparent costs of conservation.  The thinking goes along the lines of this: the application of regulations to conserve an aspect of biodiversity, x, will have impacts on community, y.  Find a mechanism, most often some small financial benefit to be distributed among community, y, and the problem will be solved.  There is a plethora of assumptions that underpin (and often undermine) such thinking.

A cursory glance at the tools that businesses and government use to improve compliance or increase uptake among human communities and it quickly becomes apparent that as conservationists, we are both limited and naïve in our use of the tools that are available.  We should be applying all the tools available.  Here are two examples: i) the impact of social media on human behaviour is only now becoming apparent, ii) for some years, the Government of the United Kingdom has been applying behavioural sciences to improve compliance or increase uptake – or as they state it “to encourage people to make better choices for themselves and society”.

Management Response: [Added: 2018/05/11]

We support this conclusion. The Project team has made a similar conclusion in the final report. We believe that the ‘social license’ is a phenomenon of our days, resulting from the world technological and information revolutions. It is becoming an important driver of the environmentally proactive conduct by the companies worldwide, including Russia. “Social license” is a weighty counter-evidence to the “administrative recourse”.

Key Actions:

14. Recommendation:

Testing impacts of eco-ratings. The misfortune of the eco-ratings system is that it is (almost) an experiment where n = 1.  However, at present, the oil and gas ratings are applied to 33 companies: while these are the largest and most important companies (both from the perspective of their economic but also ecological footprints) there are some companies that are currently not rated.  It would be good to test the impact of the eco-ratings system by examining those that are rated vs. those not rated.

Management Response: [Added: 2018/05/11]

In accordance with the Memorandum on the Transfer of Ecoratings of Oil-and Gas Companies and Mining Companies signed between the Project and WWF-Russia, the latter undertakes to develop the environmental responsibility ratings and refine their methodology. Under this Memorandum, WWF-Russia has received this proposal of the Final Evaluation, and welcomed it.

Key Actions:

15. Recommendation:

The scope of regional GEF projects.  As the GEF withdraws from Russia, much to the dismay of many people, other people have pointed out another issue with GEF funding: that is that potential regional projects that include non-recipient states cannot be formulated.  This is probably best illustrated by an idea: it would not be possible to formulate a regional GEF project that addresses grey whale conservation because some of the range states are not eligible for GEF funding.  While there is some logical to this, there could be a good argument for using a GEF grant to catalyse such a regional project while eliciting significant co-finance from those range states that are otherwise donors to the GEF.  Such a scheme would, of course, simply be harnessing the catalytic strengths of the GEF.

Management Response: [Added: 2018/05/11]

The Project, in the course of its activities, has worked a lot with the IUCN WGWAP, so it can support this recommendation as reasonable and useful. At the same time, the Project has drafted the Principles and Guidelines for the Monitoring and Mitigation of Impacts on Large Whales from Offshore Industrial Activity in Russian Waters, which the RF MNR approved in February 2018, and which are now being prepared for formal adoption in April 2018. As a result of this Project, it can be confirmed that Russia does have the scientific, administrative and public capacity for implementing the proposed project and other international projects, and a wide range of stakeholders will definitely support this. 

Key Actions:

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