General comments #21

Open #21 opened by StephanieHime on A METHODOLOGY PROMOTING STANDARDIZED NATURAL CAPITAL ACCOUNTING FOR BUSINESS · 3 replies

SH
StephanieHime remarked

Thank you for the chance to contribute to this consultation and the work your team has completed so far.

Overarching comments include:

  1. The document deviates from other frameworks by emphasising a small set of issues rather than focusing on the outcomes from a materiality assessment as the driver for issue inclusion.  This is different to the Natural Capital Protocol and Sector Guides, BS 8632 on Natural Capital Accounting for Organisations and the CDSB framework, among others.  What is the justification for the change in focus?  Would like to see this documented as part of the method to encourage debate.
  2. It is difficult to determine how and why the choices for specific indicators, measurements and valuations have been made as there are no references in the main text or a discussion as to the criteria or evaluation used to make these choices included in the document. Would like to see this documented as part of the method given that the focus on six impact drivers is a different starting point to other frameworks and standards that are currently available, understanding this would encourage debate.
  3. The scope and target audience are sometimes inconsistent within the document, some additional clarification of the purpose and link to those using the method is needed.

Please note: I did not review the following sections in detail (Water pollution, Land use), only a high-level look at the annex. All opinions expressed are given in a personal capacity.

EO
EceOzdemiroglu replied

I support the above general comment by Stephanie Hime and also express my thanks for the opportunity to contribute to this consultation 

SH
StephanieHime replied

Thanks, Ece,

 

Appreciated!

Steph

 

Dr Stephanie Hime FIEMA

Director

Little Blue Research Ltd.

 

E:

M: +44 (0)7887633345

W: www.littleblueresearch.com

 

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From: EceOzdemiroglu <reply+164+58@reply.scribehub.com> Sent: 12 October 2021 14:26 To: Stephanie Hime <Stephanie@littleblueresearch.com> Subject: [CapitalsCoalition/Transparent Methodology Promoting Standardized Natural Capital Accounting for Business] General comments (#21)

 

NC
NigelCooper replied

These comments illustrate the narrow vision of this draft and, thus, its weakness. 


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