Overarching comments #113

Open #113 opened by EceOzdemiroglu on A METHODOLOGY PROMOTING STANDARDIZED NATURAL CAPITAL ACCOUNTING FOR BUSINESS · 0 replies

EO
EceOzdemiroglu remarked
  1. There is a reference list at the end of the document but it’s not clear how they link to the body of the text and why these particular references have been selected. The draft provides no reference to the literature it borrows from when referring to ‘standardised methodologies’ which is odd.  This includes:
    1. Impact pathways and economic valuation evidence and
    2. Natural capital accounting – in fact the document is more about (a) not about natural capital accounting
  2. The level of detail provided in the draft is at odds with its intended use by its intended audience. It is not practical to expect accountants to pick this document up and undertake impact assessments
  3. The draft is very prescriptive about which impacts should be included and how. There is no justification as to why this list is selected and the very important step of ‘materiality assessment’ in NCP is ignored. Thereby, the draft
    1. Misses the opportunity to involve the businesses in the process of understanding their impacts & dependencies and risks turning this whole practice into a box ticking one
    2. Confirms the key (and often, but not in this case, misguided) criticism of monetary valuation that it focuses only on what can be measured and valued
  4. Of course it is never possible to measure and value everything. But we need to be transparent about what is / is not included in the scope of our analysis and how we decided on that scope. We need to be transparent about how we measure and value impacts that are within scope, and just importantly, what is left out of the scope, why and what are the implications of exclusions on how the impact assessments or accounts are interpreted 
  5. The report is about impact measurement. It is not about natural capital accounting
  6. I provided detailed comments until land use but only had a cursory look after that. Comments made prior to that point apply after it too. 

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