Mind the procedure-substance gap: Biodiversity consideration in the analysis of alternatives in EIA – The case of Uganda

In this paper, the authors reflect on whether the analysis of alternatives in Ugandan Environmental Impact Assessment (EIA) effectively supports biodiversity mainstreaming. This is based on a systematic review of 108 Environmental Impact Statements (EISs), completed between 2001 and 2023. Using a literature-informed checklist aligned with CBD guidance and national regulations, the alternatives section of each report is evaluated in terms of the breadth of alternatives considered, whether they were assessed in similar ways, use of biodiversity criteria, and application of the mitigation hierarchy. Evaluation scores are converted into a Biodiversity Inclusion Index for Alternatives (BII-ALT). Additionally, the results of semi-structured interviews with 18 EIA practitioners are presented, capturing their professional perspectives on how biodiversity is considered in the analysis of alternatives. While the no-action alternative is often presented, biodiversity-sensitive alternatives related to timing, process, and mitigation are mostly overlooked. Performance varies by sector, with higher-scrutiny sectors, such as oil and gas, and mining performing better than others. Biodiversity considerations are rarely decisive in selecting alternatives, and opportunities to avoid negative impacts at source are often missed. Practical entry points are offered for operationalising the mitigation hierarchy through biodiversity-centred decision-making. • Developed a Biodiversity Inclusion Index for Alternatives (BII-ALT). • Reviewed 108 Ugandan EISs for biodiversity in alternatives analysis. • Found that alternatives perform poorly in mainstreaming biodiversity. • Found that there has been no improvement despite recent regulatory improvements.