LPN agrees with the importance of simplifying licenses and procedures for companies in the environmental area, in order to improve efficiency, giving more space to the Public Administration in environmental monitoring, co-responsibility and self-monitoring by economic operators.
However, some of the proposed changes presented in the draft decree-law under consideration do not guarantee effective compliance with environmental protection rules, paving the way for increased pressure on natural resources. This is a process that requires more justification and rigor.
LPN believes that the overall result of the application of this legislation, in its current version, would be a reduction in the requirements of the current RJAIA, and not a simplification of licenses and procedures for companies in the environmental area.
The EIA cannot be seen as a "waste of time", a "project greening" or a "bureaucracy". It is an important, and unique, tool for considering the environmental impacts of a project at its preliminary stage and consequently improving its design and defining mitigation measures. The response to administrative difficulties and delays should not be to eliminate this essential stage of impact assessment and mitigation on a case by case basis, but rather to strengthen the resources, whether human or financial, allocated to the various responsible entities.
By reducing the mandatory or indispensability of EIA processes and, consequently, public participation in decision making, outside sensitive areas but also in sensitive areas (e.g. solar renewable power plants with an area <10 ha), environmental and social safeguards are reduced, thus weakening the effectiveness, robustness and coherence of this fundamental instrument [RJAIA] for the preventive defense of the environment, of natural resources vulnerable to economic activities and of the sustainable development policy.
As a final note, it is necessary to extend the Public Consultation period for a total period of no less than three months to allow for serious analysis and constructive input from citizens and their representative organizations.
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