THE PRECAUTIONARY PRINCIPLE PROJECT

ONLINE CONSULTATION

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Comments from ICMM

From: Andrew Parsons
Affiliation: International Council on Mining and Metals
Remote Name: faunaand-14.dsl1.easynet.co.uk
Time: 14:10:32 +0100

Comments

The document is well-written and balanced. We have the following minor substantive comments on it: The document is quite vague. Some members have expressed difficulty in understanding how it will be implemented. Point 1: Not all definitions of the precautionary principle are equal. The Rio definition is the product of extensive international negotiations and thus enjoys a privileged status that ought to be recognised in the guidance. Point 4: There is an extra "not" in the explanatory text, which should read: "...Threats to biodiversity and sustainable resource management cannot therefore be specified solely in terms of biology and ecology, but are linked with and driven by broader socio-economic factors, such as the behaviour of users and other actors; markets and political dynamics, and enforcement and management effectiveness..." Point 9: "Distributional consequences" is not a term in common use. While its meaning is clear from a reading of the issues paper, the guidance should be a stand-alone document and it is suggested that a more accessible term is used.