I have just read the project for the modernization and reorganization of SENACE, and I have some observations based on my experience in relevant areas. For reference, SENACE is the national authority that evaluates Environmental Impact Studies.
On Axis 1: “Modernizing the Environmental Certification Process” with the goal of strengthening and simplifying the certification process:
- I agree that enhancing the use of shared baseline data can simplify information collection in many cases. However, the rigid information requirements presented in the Terms of Reference make baseline preparation a costly chapter to produce, and in many cases, the information contained does not aid in the development of the remaining chapters, given that each project ultimately has a different context. Moreover, given the emphasis that has recently been placed on ecosystem services, it would be an excellent moment to adjust information requirements in an efficient way that allows these services to be evaluated more effectively. I believe that a degree of flexibility in the information required would optimize both baseline preparation and impact assessment.
- Regarding the standardization and systematization of technical criteria, I find this feasible for objective disciplines, such as physical and biological sciences. However, applying rigid criteria to subjective disciplines can be highly problematic, as these are open to interpretation and perspective. If standardization is to be implemented, it would be essential that these criteria be openly scrutinized by the professional community.
- Concerning the strengthening of the National Register of Environmental Consultancies, which is based on a hierarchy of consultancies, I understand that the objective of this measure is to ensure study quality and “streamline” the evaluation process of cases. However, the streamlining of this process ultimately depends on the quality and volume of information, as well as on the evaluators’ criteria and perspectives. From a market efficiency perspective, this hierarchy can function as an official mechanism for discrimination against certain consultancies. The measure clearly favors larger, established consultancies, which could potentially limit the range of options available to project holders. In practice, detailed Environmental Impact Assessments (EIA-d) for large projects already tend to fall to these large consultancies, as conducting complex EIA-ds requires substantial financial backing. Ultimately, this measure could become a barrier for small- and medium-sized consultancies to participate in projects that require EIA-ds but are not socially or geographically complex.
On Axis 2: “Technological Innovation and Modernization” with the goal of adapting and modernizing processes:
I am fully supportive of these initiatives, which will ultimately improve SENACE’s operational efficiency and information distribution to the community.
On Axis 3: “Modernization for Institutional Strengthening”:
I have no opinions on this subject, as I am unfamiliar with SENACE’s internal operational challenges.
Reference: MINAM Oficio 00573-2024-MINAM
https://naturaecova.link/ys2
