Final Call for Feedback on the FAST-Infra Open Consultation
Have your say in the open public consultation on the FAST-Infra Initiative! The deadline is 31 August.
We have now entered the final days of an open public consultation on the FAST-Infra (Finance to Accelerate the Sustainable Transition-Infrastructure) Initiative. The consultation gathers insight into the application of the Sustainable Infrastructure Label (SI Label) and the Sustainable Infrastructure Framework (SI Framework) introduced by FAST-Infra.
CEEweb for Biodiversity and its partners from the SaveGREEN project encourage all interested parties to submit their responses to this consultation, which closes on August 31st 2021.
About the Consultation
FAST-Infra has been formulated by the Climate Policy Initiative (CPI), the Organisation for Economic Co-operation and Development (OECD), HSBC, the International Finance Corporation (IFC), and the Global Infrastructure Facility (GIF). The consultation into the SI Label/Framework is led by the SI Label Working Group (WG), co-chaired by the GIF and Macquarie.
The SI Label measures the positive sustainability performance of infrastructural projects. It aims to enable sponsors, developers, operators, and owners to demonstrate infrastructural assets’ sustainability, and attract investors who seek sustainable projects. As a result, the SI Label aims to transform sustainable infrastructure into a mainstream and liquid asset. Meanwhile, the SI Framework outlines requirements and guidance for market participants who seek to apply the SI Label to their infrastructural assets. For more information, please download the official consultation documents here.
After closely examining the Initiative, consultation, and accompanying questionnaire, CEEweb for Biodiversity, along with its partners of WFF-Ro/CEE and CDV Transport Research Central, are providing advice on appropriate responses to the consultation and questionnaire form, particularly in relation to biodiversity, Green Infrastructure, eco-corridors, eco-friendly solutions, and environmental mitigation measures. Our main responses and recommendations for specific questions can be found below.
SI Framework
Question 1: “Do you agree that there should be a labelling scheme to help identify “Sustainable Infrastructure?”
a) Strongly agree.
Question 2: “How likely are you to consider using the FAST-Infra SI Label?”
b) Somewhat likely to consider using the FAST-Infra SI Label.
Question 3: “Which of the following benefits do you believe the FAST-Infra SI Label could bring to your organisation? Please select all that apply.”
b) Complementing or informing your existing reporting on ESG, SDGs, QII and/or Paris Agreement alignment.
d) Ensuring that your responsible investments will maintain a positive sustainability performance.
- help to analyse which grey infrastructure supports nature protection;
- support policy work on TEN implementation;
- provide a system for feedback on and risk assessment of overall activities;
- provide a framework for engaging with infrastructure developers, implementers, and service providers;
- provide guidance as to what must be considered when building, implementing, and maintaining infrastructure.
Question 4: “What type of SI asset would most benefit from being awarded the FAST-Infra SI Label?”
c) Both of the above.
For developed countries, FAST-Infra would be even more important. It could assist in providing feedback on the sustainability of infrastructural projects. However, further details on the SI Label and Framework are required for this to be realised.
If you have any additional comments on the SI Framework, please communicate these below.
We request the creation of an open knowledge hub platform to demonstrate best practice, or at minimum, a collection of valuable websites on tools and best practice.
For future elaboration of the labelling system, we suggest implementing a tutorial board for taking first steps, developing knowledge exchange tools and a community building program, and developing a joint audit system based on this labelling.
SI Labelling – Sustainability Dimensions and Criteria
Question 5: “Do the criteria adequately capture performance across each of the four FAST-Infra SI Label dimensions (environmental, adaptation & resilience, social, and governance)? Please select all that apply.”
b) Somewhat, though the FAST-Infra SI Label needs additional criteria within the environmental dimension.
e) Somewhat, though the FAST-Infra SI Label needs additional criteria within the governance dimension.
We would like further information on how an infrastructural development project can meet these criteria, and whether this is possible on an actual technological level. Perhaps it would be more important to require appropriate mitigation measures.
We also query:
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Are there thresholds for environmental impacts?
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What are interventions that enhance biodiversity and the natural environment?
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How can we enhance biodiversity in affected areas, where infrastructure has caused significance disturbance?
In the “Dimensions & Criteria” document, the “Environmental Dimension: Promotion and Enhancement of Biodiversity & the Natural Environment, Baseline Requirement”, we suggest adding “including affected freshwater, terrestrial and marine habitats and their connectivity” to the end of “the project will meet the baseline requirements for this criterion by achieving overall net gain* for natural and modified habitats, as well as critical habitats.”
Besides mentioning tools that are already in place, such as environmental impact assessments, monitoring plans, and stakeholder engagement/consultations, we recommend emphasising the Strategic Environmental Assessment and the Environmental Impact Assessment within the label. It is necessary to have a detailed environmental examination over the entire duration of the project. Furthermore, sustainable projects with SI label should present an analysis of their impacts, such as direct/indirect threats and their underlying causes, and develop appropriate mitigation measures where possible.
In the “Governance Dimension”, we suggest that stakeholders should be involved when all options are still open, as early as possible. Engagement should continue throughout the entire project duration.
Question 8: “Is the indicative list of indicators sufficiently complete?”
b) No, more need to be added.
In addition, GI is de facto completely missing in Annex 1 except for the call for nature-based solutions. As such, we suggest that this table header should be renamed to “Nature-based solutions and Green Infrastructure”. The bullet point "maintaining a sufficient degree of permeability of the landscape for relevant animal groups" should also be added.
Under the “Governance criteria on corruption”, we believe that some indicators need to be added.
It is necessary that this SI label strengthens and promotes laws, policies and principles that successfully protect rivers. Regarding Annex 1, “Renewable Energy”, we request that the “Indicative & Non-exhaustive List of Sustainable Infrastructure Assets” excludes the phrase that allows small hydropower, i.e. “hydro (<5MW)”, to be designated as a sustainable asset. Dams and reservoirs hugely contribute to connectivity loss in rivers around the world, leading to the subsequent loss of diverse benefits for people and nature provided by healthy rivers.
We urge caution in using green land for power production and recommend the use of already-used land. There are many abandoned formerly industrial areas. Motorways can also be used for solar energy production.
If you have any additional comments on the Sustainability Dimensions and Criteria, please communicate these below.
The planning and development of a sustainable asset must ensure that newly proposed infrastructure has little to no overlap with the national ecological network (such as protected natural areas, wilderness areas, and ecological corridors).
With regard to the next paragraph, “3. Minimum Safeguards & Risk Management: Publish in the public domain an Environmental and Social Impact Assessment (ESIA) produced by a qualified independent firm or consultant", we suggest that the parties responsible for realising and funding the ESIA are publicly indicated. There should also be demonstration that the process was independently and correctly carried out, without any conflict of interest.
SI Label – Governance and Reporting
Question 11: “In an effort to minimize regulation and put more agency in the market to decide whether further verification is needed, the FAST-Infra SI Label allows for self-declaration but with independent external review highly encouraged, but not required. Do you agree with this approach?”
b) No.
SI Label – FAQ Document
Question 13: In your view, are there any questions that should be added to the FAQ document?
a) Yes.
Many thanks to Gabriella Nagy (CEEweb for Biodiversity), Andrea Danci (WWF-Ro), Hildegard Meyer (WWF-CEE), and Ivo Dostál (CDV Transport Research Central) for their insights into the consultation.