Guide for preparing comments on behalf of EIANZ

Published 30 June 2014

One of the key areas in which members of EIANZ become involved is in preparing comments on draft plans, policies, regulations and other matters on behalf of EIANZ. This volunteer input is critical to EIANZ engaging on matters of good environmental practice, and is greatly appreciated. Members often ask for guidance in preparing such submissions and this article aims at demystifying some aspects of preparing submissions.

Firstly, there is a need to make a decision on whether to prepare a submission. This decision might involve consideration of the following: 

  • Is the document of direct relevance to environmental practice? EIANZ does not comment on policy matters or individual projects, but seeks to influence the standards of environmental practice.
  • Is it an area that EIANZ is interested in?
  • Are sufficient people available and do these people have appropriate experience in the subject area? If you are seeking assistance from members, you can approach your division/branch committee and an email can be sent out to the membership in the relevant jurisdiction. If the document is of interest across Australia and New Zealand, contact the General Manager or executive to check whether anyone else is making a submission and let them know that you are preparing a submission. If the document is of State or regional interest, contact the relevant Chapter / Division committee. 

Once a decision has been made to proceed and a group assembled, the following points might assist in drafting a suitable submission:

  • Comments must be in line with EIANZ‘s overall vision of excellence in environmental practice and the Code of Ethics
  • EIANZ represents environmental practitioners and promotes excellence in environmental practice. It is a non-political organisation.
  • Comments are made on the basis of professional interest, not personal interests or views.
  • Our members come from all areas and spectra of practice and we must ensure that comments made will generally be acceptable from all of the various professional viewpoints of our members.
  • EIANZ does not take a position on the merits of individual projects or actions, and generally avoids commenting on, for example, Terms of Reference or Environmental Impact Statements for particular projects. If comment was to be made, such comment would need to focus on the integrity and transparency of the assessment process and possibly on the quality and veracity of the assessment as a basis for making an informed decision, not whether or not the project should proceed. 
  • EIANZ does not align with any particular political party or viewpoint
  • EIANZ is not a conservation group, and is neutral on development. Our concern is with sound policy making and decision making.
  • Comments should focus on whether the particular document reflects sound environmental practice and supports achievement of sustainable outcomes.
  • Consider the evidentiary basis on which conclusions are based and recommendations made. Is this sound? Are arguments logical? Is data used and analysed appropriately? Are there information sources that have been missed?

Once the submission is drafted:

  • Obtain EIANZ letterhead from the Central Office.
  • Provide contact details if further information is required (this could be the EIANZ General Manager or a Division/Branch President).
  • Forward to the committee most relevant to the jurisdiction for review and signature. Submissions on Australia/New Zealand wide issues should be signed by the President or Vice President (Australia or New Zealand). Submissions on a State or regional issue can also be signed by the relevant Division president. Members may not make submissions on behalf of EIANZ without endorsement from the Executive or relevant Chapter / Division committee. 

Members may also wish to make submissions in their own name, rather than on behalf of EIANZ. Members are reminded that membership requires adherence to the EIANZ code of ethics in all professional dealings. In individual submissions there should also be a clear statement that the views of the individual member do not necessarily reflect those of EIANZ. Some examples of recent submissions are available on the website. Send copies of your submissions to the Central Office for uploading so others can benefit from your insights.

Thank you to all those members who volunteer their time to prepare submissions.