Enperitus Pty Ltd

Ask the Right Question Series for Approvals #3

How? Puzzle Shows Different Ways Or Methods To Solve Problems

Question the methodology!

The Precautionary Principle is applied because sometimes there are knowledge gaps with regard to the potential for a species to be impacted by an activity. It really is a great fall back position and one that promotes conservative decision making (to the benefit of the environment) when there is a lack of evidence but where there is the potential for impact on a species or habitat.

When the Precautionary Principle is applied, the first course is to determine if you can live with the decisions made during the Approvals process, or ultimately conditions of the licence. If not, then the next steps are to initiate a research program that will fill those knowledge gaps. The research program is often determined in consultation with government departments and the scientific community.

Be careful here because the research program should specifically address the knowledge gap. Question whether or not the problem is being addressed. It is common for these research programs to address the interests of the scientific community and in sheer desperation to resolve the problem, the proponents representative will simply accept what has been decided amongst the consultants, government advisors and scientists.

Yes, I have been in this situation where I simply said, ‘No, this research program does not address the knowledge gap”. The research program was based on the assumption that there was going to be an impact, and therefore genetic studies would be undertaken to determine the significance of the impact on the total known populations of the species.

I found a consultant that would design a research program that specifically addressed whether or not the activity would impact this particular species. We designed the research program in consultation with our external stakeholders. The outcomes of the research program were that the activity would not impact the species. It turned out to be both cost-effective and reduced the time it took for an outcome.

Be involved in these decisions, and be bold enough to question whether or not the methodology proposed is addressing the knowledge gap.