 
          
            2010
          
        
        
          AMBATOVY SUSTAINABILITY REPORT
        
        
          19
        
        
          C1. Environmental Performance
        
        
          
            Biodiversity Strategies
          
        
        
          We have taken a multifaceted approach to biodiversity,
        
        
          utilizing six main strategies:
        
        
          
            Mitigation
          
        
        
          Ambatovy is undertaking biodiversity management in a
        
        
          structured manner that follows the mitigation hierarchy
        
        
          adopted by BBOP across all aspects of biodiversity.
        
        
          
            Avoidance
          
        
        
          Where possible, the Project will avoid areas particularly
        
        
          sensitive to impact from our activities. Examples of this include
        
        
          the diversion of the pipeline route and the creation of barriers to
        
        
          protect conservation areas from construction activities.
        
        
          
            Minimization
          
        
        
          Impacts are minimized wherever possible through optimized
        
        
          planning. For example, the mine footprint corresponds
        
        
          precisely to the exploitable ore body and involves minimal
        
        
          excess forest clearance.
        
        
          
            Rescue (Relocation and Translocation)
          
        
        
          Ambatovy developed a substantial impact mitigation program
        
        
          for the construction phase that includes:
        
        
          3
        
        
          Repetition of full biological surveys prior to each clearing
        
        
          to develop taxa-specific mitigation measures such as:
        
        
          fitting lemurs with radio collars to monitor their ability
        
        
          to migrate away from impact areas and relocate to
        
        
          refuge areas; identifying plant species of concern and
        
        
          locating them off-site to avoid the risk of extinction; and
        
        
          salvaging plants to nurseries and/or propagating them.
        
        
          3
        
        
          Directional and slow-paced forest clearance, which
        
        
          allows mobile fauna to migrate away from impacted
        
        
          areas to adjacent refuge areas. For the less mobile
        
        
          fauna, manual salvaging is used to relocate animals
        
        
          into safe conservation zones. A crew of more than 80
        
        
          expertly trained technicians identifies and salvages
        
        
          all small mammals, stranded lemurs, certain birds
        
        
          and reptiles. Experts, primarily Malagasy biologists
        
        
          from various universities and non-governmental
        
        
          organizations, supervise the salvaging process.
        
        
          Relocated animals are subsequently monitored in the
        
        
          refuge areas.
        
        
          3
        
        
          For the aquatics program, large retention dams are
        
        
          used to prevent sediments from impacting downstream
        
        
          watersheds and the introduction of exotic species.
        
        
          
            Repair, Reinstate and Restore
          
        
        
          Ambatovy will conduct progressive footprint rehabilitation
        
        
          consistent with the historical ecology of the landscape.
        
        
          
            Offset and Compensate
          
        
        
          Ambatovy’s multifaceted biodiversity offsets program
        
        
          comprises a series of on-site and off-site conservation areas
        
        
          considered to be biodiversity offsets, which include:
        
        
          3
        
        
          
            On-Site Azonal Forest Habitat:
          
        
        
          Two areas of the
        
        
          azonal forest habitat growing over the ore body have
        
        
          been set aside, despite the valuable nickel ore lying
        
        
          beneath them, to preserve examples of this habitat.
        
        
          The azonal forest surface area is equal to 212.33 ha
        
        
          (26.4% of the total prime quality habitat) and will not
        
        
          be mined. During the Environmental and Social Impact
        
        
          Assessment, the azonal forest habitats were recognized
        
        
          as a rare habitat type compared to the more typical
        
        
          zonal forests of the Eastern Forest Corridor.
        
        
          3
        
        
          
            Mine Area Conservation Forest:
          
        
        
          Ambatovy has
        
        
          designated 4,900 ha as “buffer zone” around the
        
        
          mine footprint, destined to be long-term conservation
        
        
          and multiple-use forest areas. This area has already
        
        
          faced human-induced pressure. Our aim is to ensure
        
        
          local community access to medicinal plants and
        
        
          other sources of livelihood through the promotion of
        
        
          sustainable forest use. The azonal conservation zones
        
        
          mentioned above are adjacent to these areas. These
        
        
          efforts will conserve rare habitats and their fauna
        
        
          and flora and offset the Project’s impact on the mine
        
        
          footprint forest. The majority of this forest lies within a
        
        
          land lease of 7,596 ha with the Malagasy government.
        
        
          
            A Pioneering Biodiversity Offsets Program
          
        
        
          Ambatovy’s biodiversity offsets program has been designed and implemented as a pilot project within the framework of
        
        
          the Business and Biodiversity Offsets Program (BBOP), a voluntary partnership between companies, financial institutions,
        
        
          governments and civil society organizations. BBOP seeks to develop an international framework for the design and
        
        
          implementation of biodiversity offsets, particularly for use in developing countries lacking their own offsets policies and
        
        
          legislation. Other BBOP pilot projects are underway in Africa, Asia, Latin America, the Middle East and North America, and
        
        
          cover a range of sectors including oil and gas, mining, tourism and real estate.
        
        
          Ambatovy’s offsets activities are designed to adhere to the BBOP principles and guidelines and produce quantifiable
        
        
          biodiversity and socio-economic benefits. Calculations are used to determine residual losses in biodiversity due to
        
        
          Ambatovy’s activities and the gains achieved by the offsets. Socio-economic assessments are also made to determine the
        
        
          impact of offsetting on local populations and the scale of compensatory measures that may be required. Ambatovy’s offsets
        
        
          program is monitored in consultation with BBOP through annual assurance framework meetings and with the support and
        
        
          guidance of experts associated with the program.
        
        
          BBOP has published a set of ten principles on biodiversity offsets supported by the 50 member organizations of the
        
        
          BBOP Advisory Group. These principles are accompanied by interim guidance and resource papers on the design and
        
        
          implementation of offsets. These include case studies from the BBOP pilots, of which the Ambatovy Project is one of the first.
        
        
          The full case study is available at