In the report prepared by Marlene Laros of MLA Sutainability Matters, the role of the Environmental Assessment Practitioner (EAP) is explored. Areas where the role of the EAP is not clear were identified, and then a wider list of problems defined.
The role of the EAP is not clear in these respects –
• Should EAPs be informing the decision making process with a real consideration of the no-go option
• Should EAPs be making a recommendation – i.e. offering a reasoned professional opinion - to the authorities
• Should EAP be promoting the best outcome for sustainable development , the environment and society, or should EAPs be neutral?
Problems identified include -
• EAPs are judged for the inefficiencies of the assessment process.
• The regulatory system has emphasised the need for independence rather than quality assurance.
• There is too much emphasis on independence, and insufficient focus on objectivity.
• EAPs are often engaged when a development proposal is already well-conceived and there is little opportunity to influence the project.
• There is too much emphasis on the administrative aspects, and too little on the outcomes of the regulation of the environment.
• The quality of decisions and assessments cannot be verified because compliance monitoring and feedback are inadequate.
• Public participation frequently questions the objectivity and independence of EAPs because of the employment relationships.
• The person best qualified is not always appointed as EAP on a project because the person is not independent. The option to apply for exemption to the regulation is seldom exercised because of the risk of vexatious legal challenges from IAPs.
• Environmental Management Programmes/Plan compiled by someone without on-site environmental management experience may compromise quality in favour of independence.
• The absence of a mechanism to sanction EAPs for unethical or unprofessional conduct hinders quality assurance.
• While core competencies and certification criteria have been established by EAPASA, there may be a requirement for specialisation in the future. While core competencies and certification criteria have been established by EAPASA, there may be a requirement for specialisation in the future.
• There are specialist inputs into the Assessment process by professionals for which there is presently no quality assurance e.g public participation practitioners, social impact assessment practitioners.
• Practitioners engaged in monitoring and inspection – EMI, building inspectors, etc. – have no registration body.
• There is no registration requirement for practitioners implementing authorizing aspects
• There is no requirement for other professionals who have an important role in environmental impact management to comply with environmental standards and ethics – e.g. spatial planners, civil engineers, etc.
• Training lacks a co-ordinated content specific skills development programme.
• Training offerings at tertiary institutions need to be accredited to the qualification standard.
• Accreditation of a qualification standard could be extended to include planning, landscape architecture, sustainability and engineering programmes.
• Learnerships are needed to bridge the experience and competence gap in recent graduates in order that they can meet the requirements for registration
• There should be a range of learnerships to enable competence in specific areas, for structured leaning.
• There is a need for internship and mentoring programmes.
• There is no opportunity for review to improve the efficiency of the system (as review presently tends to be from a regulatory perspective).
• Reviews which take place after the assessment process are least effective, yet this is the tendency.
• Review is not being institutionalised in the system, and it is an effective quality assurance mechanism.