THE PRECAUTIONARY PRINCIPLE PROJECT
ONLINE CONSULTATION
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From: Nanki kaur
Affiliation: The Energy and Resources Institute, India
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Time: 06:58:51 +0100
The guidance provides a constructive approach to the PP as set out in guideline 1 and recognises that an integrated policy and institutional framework is required to implement the PP, of which the operational policies and management frameworks should be context specific (guideline 2 & 3). The guidelines that follow are related to processes that will ensure a constructive or positive means to assess alternatives or anticipate, prevent and mitigate threats. For instance a comprehensive assessment of uncertainty and of likely consequences of alternative causes of action and inaction would help ensure practical solutions (guideline 4 & 5). Similarly adaptive management, monitoring and efforts to reduce uncertainty (guideline 11 & 12) will ensure constructive, positive and context specific implementation of the PP. The guidance thus recognises the importance of a constructive application of the PP and highlights important processes that need to be taken into account to ensure such an application. Some specific comments include: Guideline 4: highlights the need to specify the uncertainties that precautionary measures address. In the text, no reason is provided for such a specification. This should be incorporated as such a specification is important and may ensure against arbitrary decisions and it also ensures a basis for monitoring. Guideline 6: The guidance stresses on the economic ability of concerned parties. This may not be the only aspect of determining the burden of proof, as the kind of evidence may often determine the cost of evidence. In such cases (as mentioned in Guideline 7) oral versus written evidence may be more cost-effective in determining the BOP. Secondly, if the economic ability of the concerned parties is stressed upon the guidance may need to specify that a targeted approach be taken towards economically poor people. Means to determine the burden of proof in such cases will need to be specified. Guidance 9: Guidance provided (in the text) by this guideline is not clear. Why should socio-economic costs be taken into account to address existing obstacles in the implementation of the PP (or other measures) due to existing power structures? Rather Precautionary measures should be applicable to all stakeholder groups. Socio-economic costs can be evaluated to ensure that (due to existing power structures) the impact of Precautionary implementation is not borne by marginalised groups (basis for evaluating compensation strategies; ensuring that policies address existing power structures so that costs of implementing precautionary measures are borne by drivers of conservation threats).
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