Photo by Tyler Casey published in Unsplash.
On March 17, 2025, through RM 00078-2025-MINAM, the Ministry of the Environment (MINAM) published the draft “Guidelines for the identification and incorporation of climate change adaptation and mitigation measures in investment projects subject to the National Environmental Impact Assessment System (SEIA)”.
The main objective of these guidelines is to guide and standardize the integration of the climate change approach in Environmental Impact Assessments submitted to the SEIA, focusing on two key dimensions:
- Management of climate change-related risks
- Identification of greenhouse gas (GHG) emissions from a project
We believe it was only a matter of time before this requirement was formally introduced into environmental evaluations. Several countries in the region have already begun incorporating climate-related considerations into their environmental impact assessments. Even international capital markets have taken the lead by establishing standards that value resilient, low-carbon projects and companies. With this draft, SEIA aligns with this global trend.
What does the draft propose?
The document outlines methodological guidelines focused on two main areas:
- Climate change adaptation
Projects must identify and manage climate-related risks that could affect them throughout their life cycle. This requirement applies to all levels of environmental studies:
- Environmental Impact Declaration (DIA)
- Semi-detailed Environmental Impact Study (EIA-sd)
- Detailed Environmental Impact Study (EIA-d)
- Climate change mitigation
Projects must identify GHG emission sources and quantify their emissions. This applies to EIA-sd and EIA-d, and also requires the inclusion of mitigation measures in the Environmental Management Plan.
How does it affect the industry?
We anticipate that the most exposed sectors will be infrastructure and agriculture, mainly due to their location in areas vulnerable to extreme weather events such as heavy rains, droughts, or landslides. These industries will need to incorporate more detailed climate-related information in their technical documentation—from hazard assessments to resilience estimations.
In the case of the mining sector, the focus will be on the inventory of GHG emissions, primarily related to electricity use and fossil fuel consumption. Fortunately, this analysis is typically part of operational planning in the mining industry, so it should not represent a significant additional technical burden.
How does it affect environmental consulting firms?
For consultancies, the impact will be both organizational and technical:
- They will need to hire or train specialists in climate risk assessment and GHG quantification.
- Their methodologies will need to align with standards such as ISO 14064, IPCC protocols, and use official data sources like SENAMHI.
- They may need to expand their teams or build multidisciplinary partnerships to meet these new requirements with technical rigor and within expected timeframes.
Comments and open questions
- Mitigation measures in Environmental Management Plans
The draft requires projects to propose mitigation measures for GHG emissions but does not specify clear criteria for selecting or prioritizing these measures. Will priority be given to energy efficiency, nature-based solutions (NbS), or financial mechanisms for compensation? Clarifying this would be essential to align expectations, assess feasibility, and ensure coherent implementation. - Economic valuation of GHG emissions
The document does not indicate whether GHG emissions must be monetized as part of cost-benefit analysis. Will a carbon shadow price be used? Will emissions be incorporated as negative externalities in the economic valuation of impacts? Providing guidance on this aspect would strengthen the integration of climate impacts into decision-making.
Final thoughts
We believe this measure is in line with the global trend of incorporating climate-related considerations in the evaluation of a project’s or company’s value.
In the case of infrastructure projects exposed to climate risks, these guidelines could be especially useful during the planning phase. While the preparation of the technical dossier may become more costly, we consider this additional cost to be a worthwhile investment, as it reduces vulnerabilities and enhances the project’s adaptive capacity.
Regarding GHG reporting, although the draft does not explicitly state it, it is understood that emissions estimation is limited to Scopes 1 and 2—that is, direct project emissions and those associated with energy consumption. This is a reasonable decision at an early stage.
Including Scope 3 emissions—those related to the supply chain—would introduce a significant level of complexity and require technical capabilities and data that are not currently required by national regulations.
