Chapter 3
Eligible Preparers of EIS and IEE




Section 8.0 of Article III: Eligible Preparers

The EIS may be prepared by the proponent�s technical staff or a professional group commissioned by the proponent, provided that only EIS preparers duly accredited by the EMB in accordance with its accreditation procedures shall be allowed to actually prepare the EIS.

Section 18.0 of Article III: Eligible Preparers

The IEE may be prepared by the proponent�s technical staff or a professional group commissioned by the proponent, provided that only IEE preparers duly accredited by the EMB in accordance with its accreditation procedures shall be allowed to actually prepare the IEE.

NOTES:

  • Only those accredited by the DENR, in accordance with the prescribed accreditation criteria and procedures, can prepare an IEE or EIS. Starting 1 January 1998, DENR will only accept IEE or EIS prepared by accredited preparers.

  • Any individual or organization (e.g. single proprietorship, partnerships, firms, environmental units of government agencies or local government units) can apply for accreditation as an eligible EIS/IEE preparer. At the minimum, any individual who has attained a Bachelor's degree in engineering, natural, physical or social sciences can apply for accreditation.

  • The EMB shall establish the levels of accreditation, accreditation criteria and accreditation mechanics for eligible EIS/IEE preparers including grounds and procedures for withdrawal of accreditation . DENR Regional Offices shall receive applications, accredit preparers and withdraw accreditation as may be prescribed by EMB.

  • Accreditation by EMB or DENR Regional Offices shall be recognized nation-wide and shall be valid unless withdrawn in writing in accordance with procedures prescribed herein.

  • EMB shall establish a system for public information and dissemination on eligible preparers which will be updated regularly with inputs from DENR Regional Offices.

  • In order to assist proponents of small projects, a system of IEE submission using the checklist format shall be established by DENR for certain sectors. Such checklist may be submitted by proponents themselves without the need to engage the services of an eligible preparer.

To maintain the integrity of the EIS system, the DENR is implementing a system of accreditation to screen individuals/professionals who are eligible to actually prepare an EIS/IEE.

Not just anybody can prepare an IEE/EIS. Only those accredited by DENR, in accordance with the prescribed accreditation criteria and procedures, should prepare an IEE/EIS.

Section 7.0, Article IX of DAO 96-37 also strongly prohibits the participation of any DENR personnel, in any manner whatsoever, directly or indirectly, in the preparation of the EIS or IEE. A violation of this provision is subject to administrative sanctions and penalties in accordance with Civil Service regulations, without prejudice to criminal proceedings under the Anti-Graft and Corrupt Practices Act and other relevant laws.

Accreditation of Individual EIS/IEE Preparers

In the accreditation of individual preparers, EIA consultants shall be ranked according to three (3) levels, namely:

  • Associate Environmental Professional
  • Environmental Professional
  • EIA Team Leader

The Associate Environmental Professional (AEP) shall be referred to as Level 1, the Environmental Professional (EP) as Level 2 and the EIA Team Leader as Level 3. The accreditation critera for an EIA consultant are shown in Table 3.1.



Table 3.1. Qualification of Consultants

 Level of Consultant            Qualification Criteria

Level 1:  Associate                Educational Attainment
Environmental            must have a Bachelor's degree in  the
Professional             engineering,  natural,  physical   or
                         social  sciences (refer to Table  3.2
                         as guide)
                                          or
                         must  have participated in  at  least
                         three  (3)  seminars,  workshops   or
                         training on EIA or any related  field
                         such as those identified in Table 3.2
                         
			 Other Requirement:*
                         must  have  knowledge & understanding
                         of DAO 96-37.

Level 2:  Environment              Educational Attainment:
Professional**           must  have  a Bachelor's  or  Masters
                         degree  in the engineering,  natural,
                         physical or social sciences (refer to
                         Table 3.2 as guide)
                         
			 Work Experience:
                         
			 must   have  at  least  3  years   of
                         practical  experience in any  of  the
                         following:  (a)  EIA  work   in   any
                         module/study area identified in Table
                         3.2;  (b)  env. appraisals & reviews;
                         (c)   environmental  management;  (d)
                         natural resource management;  or  (e)
                         specialized studies
                         
			 Seminars/Trainings Attended:
                         
			 must have participated in at least  5
                         seminars,  workshops or trainings  on
                         EIA  or in any related field such  as
                         those identified in Table 3.2.
                         Membership in Professional  Assn.  or
                         Organization
                         
			 must   be  an  active  member  of   a
                         recognized  professional  association
                         or    organization    (locally    and
                         internationally)
                         Other Requirements*
                         must    have    full   knowledge    &
                         understanding of DAO 96-37

Level 3:  Team Leader    must  possess  all the qualifications
                         for an EP, except that practical work
                         experience should be at least 5 years
                         Managerial Effectiveness***
                         must  have the ability to coordinate,
                         manage  and direct the activities  of
                         an interdisciplinary team
                         
                         must  have  the technical ability  to
                         integrate the activities and  desired
                         outputs required of the EIA modules
                         Training Experience
                        
			 must   have   acted  as  trainer   or
                         resource   person  in  at   least   2
                         training courses related to EIA



* Knowledge on DAO 96-37 shall be attested to be the applicant in the application form.

** The consultant's expertise will be evaluated according to the relevant study area he/she specialized in.

*** These can be gauged by his/her experiences in team management and program/project coordination work and validated by actual performance on EIS and related environmental planning and management work.

In addition, Level 2 preparers should have certain fields of specialization such as those indicated in Table 3.2 in order to be able to carry out the different modules or study area in the conduct of an EIA. The field of specialization could be acquired through formal education, training and work experience.

Table 3.2 serves as a reference guide for the various fields of specialization per module or study area. The table is not intended to serve as basis for exclusion. EMB shall review and update the table, particularly the fields of specialization, as necessary.

     
Table 3.2   Sample Specializations per Module or Study Area

Module/Study Area Field of Specialization 1. Air Quality Environmental Engineering Air Pollution Control Environmental Science/Studies and Management Natural Sciences 2. Atmospheric Environment Climatology Climate Environmental Science/Studies Weather Meteorology Physical Sciences 3. Hydrology/Lakes Environmental Engineering Environmental Science/Studies Hydrology Limnology Natural Resources Management 4. Water Quality Analytical Chemistry Water Pollution Control Chemical, Civil and Environmental and Management Engineering Environmental Science/Studies Geochemistry Hydrogeology Microbiology Natural Resources Management Physical Sciences Sanitary Engineering 5. Ocean Environment Chemical Engineering Environmental Engineering Environmental Science/Studies Geology Marine Science Oceanography Physics 6. Forests Agriculture Terrestrial Ecology Biology Upland Areas Botany Ecology Environmental Science/Studies Forestry Natural Resources Management Wildlife Biology Zoology 7. Aquatic Ecology Environmental Science/Studies Coastal and Estuarine Ecology Marine Resources Fishery Biology Hydrobiology Limnology Marine Biology Natural Resources Management 8. Geology Agriculture Geomorphology Environmental Science/Studies Land Use Development Planning Soils Geology or Soil Science 9. Urban and Environmental Planning Regional Planning Environmental Science/Studies Regional Planning Urban Planning Environmental Planning 10. Local and Cultural Anthropology Communities Community Development Social Demography Acceptability Environmental Science/Studies Social Impacts Rural Development Socio-economics Sociology 11. Environmental/Health Risks Environmental Engineering and Impacts Environmental Health Public Health Occupational Health Environmental/Health Risk Assessment 12. Noise/Sonic Environmental Engineering Environment Environmental Health Environmental Science/Studies Mechanical Engineering Occupational Health Public Health 13. Economic Economics Feasibility Study Environment and Natural Resource Accounting Financial Analysis Resource Economics 14. Environmental Environmental Management * Science/Studies/Assessment/ Management 15. Population and its Demography Interrelationships Sociology Anthropology

* The EIA Environment Professional who qualifies for accreditation in the area of Environmental Management must have the capability to evaluate the technical inputs (impact identification, prediction, assessment, mitigating measures, etc.) of the various modules and integrate these into a consolidated EIS document.

The mechanics for accreditation are:

  1. The EMB and DENR Regional Offices (ROs) will be responsible for accrediting and upgrading individual experts on EIA through the assignment of rank. The ranks are as follows:

    • Associate Environmental Professional (AEP) - Level 1;
    • Environmental Professional (EP) - Level 2; and
    • Team Leader (TL).

  2. The DENR ROs can act on Level 1 applications or the rank of AEP. However, it shall undertake preliminary screening of applications from the regions for Levels 2 and 3 to ensure completeness of documents and information required for accreditation. Application forms submitted to the EMB will be evaluated at the EMB office.

  3. In evaluating all applications, EMB and the ROs shall make use of the qualification or accreditation criteria provided.

  4. An accreditation group shall be created by the EMB and ROs. Its functions are:

    • develop evaluation mechanics to include manner of validating and/or cross-checking of support documents;
    • review, evaluate, process and approve application forms for accreditation/upgrading of accreditation;
    • issue accreditation certificates to individual experts on EIA;
    • drop, after due process, from the roster of accredited EIA consultants any expert who has been found amiss in the delivery of impact assessment studies; and
    • assign technical advisers for specific batch reviews.

  5. The composition of the accreditation group in EMB is as follows:

    • Director/Assistant Director of EMB;
    • Division Chief/Head of EIA Unit;
    • Two (2) members-at-large from within EMB to be designated by the EMB Director
    • One (1) representative from the Office of the DENR Undersecretary for Environment and Programs Development. On the other hand, the composition of the accreditation group at the RO is as follows:

      • DENR Regional Executive Director; and
      • RTD - EMPAS
      • Head/Chief, EIA Unit/Section/Office/Division

    • The accreditation group shall be chaired by the EMB Director for EMB and the RED for the ROs. The Assistant Director shall act as Co-Chair in EMB, while the RTD- EMPAS shall act as Co-chair for the ROs.

    • The accreditation group may, at its discretion, have two (2) technical advisers, who may not necessarily be accredited preparers. The advisers may be selected from among organizations or institutions whose main thrust is on the professionalization of environmental management or from the academe. However, a person cannot be invited as technical adviser if he or she has a pending application for accreditation.

    • The assignment of technical advisers shall be made per batch review in order to assure objectivity in evaluation. They shall sit as non-voting members of the accreditation group.

    • The accreditation group shall be assisted by a 3-member Secretariat to be headed by a senior staff of the EIA group for EMB and a senior staff of the EMPAS for the RO. The functions of the Secretariat are as follows:

      • conduct a preliminary screening of submitted forms and supporting documents for accreditation/upgrading of accreditation;
      • submit recommendations with regards to processing for accreditation;
      • notify all concerned of evaluation sessions with prior consultation from the head of the accreditation group; and
      • provide necessary documentation in all aspects of accreditation.

    • Accreditation certificates issued by the EMB and RO shall remain valid until such time as may be withdrawn by DENR or other competent authorities.

Procedures for Accreditation of EIS/IEE Preparers

In order to be accredited, an applicant need only submit the application form (Annex 3-A: Accreform 1) and the documents he/she listed in Accreform 2 (Annex 3-B). Likewise, the applicant must not have been convicted of any crime against public interest (e.g., falsification, forgery, other falseties) nor found liable in an administrative proceeding involving EIS/IEE for the past five years.

The procedures for accreditation are as follows:

  1. Three (3) copies of the duly accomplished form (Accreform 1) and supporting documents (as listed in Accreform 2) shall be submitted to the Director of the EMB or to the Regional Executive Director of the respective ROs.

  2. The applicant pays a fee in the amount of P 500 (five hundred pesos).

  3. Preliminary screening of forms shall be done for all levels. Completeness of documents submitted shall be the basis for processing. In cases when processing could not proceed due to incomplete or insufficient documentation, the applicant shall be notified within thirty (30) days of receipt of his application forms to allow him/her to submit additional documents or to complete the documentation.

  4. . Applications that pass the preliminary screening will be endorsed to the EMB and RO accreditation group as may be appropriate.

  5. The application forms shall be evaluated based on the prescribed accreditation criteria.

  6. The accreditation group shall evaluate the application forms with attached supporting documents using Forms 3 and 4. (Refer to Annex 3-C and Annex 3-D, respectively).

  7. The acceptance of applications will be all year round, but the processing or evaluation of applications for accreditation shall be scheduled quarterly.

  8. Individual experts, whose applications for accreditation have been approved, shall be issued an accreditation certificate by the EMB or the ROs and shall be included in the roster of professionals and individual experts on EIA.

  9. Upgrading of accreditation to a higher level, Environmental Professional (EP) or Team Leader (TL) shall be done upon submission of required forms and/or documents. Processing shall be done in accordance with the accreditation mechanics and procedures described herein.

Accredited preparers must inform the accrediting office, in writing, every three (3) years if he/she wishes to continue the inclusion of his/her name in the directory.

The granting and withdrawal of accreditation by the ROs shall be recognized nation wide.

Accreditation of Non-Individual EIS/IEE Preparers

Non-individual preparers are privately or government owned and operated entities. One of the main thrusts of operation of these entities is the conduct and management of environmental impact assessments or studies for both private and government sector projects. Government-owned or operated entities refer to the Environmental Units (EUs) of the national government departments or agencies (such as the Department of Energy, the Department of Health, or a local government unit) and government banks (such as the Land Bank of the Philippines) created pursuant to E.O. 291 (1996).

Non-individual preparers must satisfy the following requirements:

For single proprietorship:

  • the owner of the entity must be a citizen of the Philippines;
  • the entity must be registered with DTI; and
  • the owner must be an accredited environmental professional.

For partnership:

  • at least sixty percent (60%) of the partnership�s interest must be owned by citizens of the Philippines;
  • must be properly registered with SEC and authorized to engage in consulting services, one of which is contracting of EIA studies; and
  • at least one (1) partner of the entity must be an accredited environmental professional.

For corporation:

  • at least sixty percent (60%) of both the subscribed and paid- up capital must be owned by citizens of the Philippines;
  • must be properly registered with SEC and authorized to engage in consulting services, one of which is contracting of EIA studies; and
  • at least one (1) principal officer of the corporation must be an accredited environmental professional.

    For environmental units:

    • must be properly established through the appropriate administrative issuances; and
    • at least one (1) senior staff of the EU must be an accredited environmental professional.

    In consideration of the multi-disciplinary nature of EIA undertakings, the entity or organization must have access to the services of a number of accredited environmental professionals with varying fields of specialization either as regular staff or as part-time (on-call) consultants.

    The non-individual preparers shall be evaluated according to the capability and/or performance on EIA projects. The criteria are as follows:

    • a pool of experts who are capable of satisfying the requirements of DAO 37;
    • track record or experiences of pool of consultants and/or the firm;
    • must not have been convicted of any crime against public interest (e.g., falsification, forgery, other falseties) or found liable in an administrative proceeding involving EIS/IEE preparation for the past five (5) years; and
    • environmental management must be part of its corporate goals and objectives.
The following procedures for accreditation shall be observed:

  1. Submit a letter of application, together with the supporting documents, to the screening committee formed by the EMB.

    The required supporting documents are as follows:

    • SEC and/or DTI registration papers (or copy of administrative issuance for EUs);

    • Background materials about the organization, such as corporate mission/goals, organizational set-up, officers, EIA capability and experience, list of EIA experts and staff with brief biographical information - for EIA experts who are not employee of the firm/unit, a letter or certificate of commitment must be included;

    • Record of previous EIA study engagements with focus on quality of performance and geographical distribution of engagements for the past three (3) years, if any;

  2. The organization pays an application fee in the amount of P 2,500 (two thousand five hundred pesos) to the EMB.

  3. Documents (submitted in No. 1) shall be forwarded to the accreditation committee for evaluation and final decision.

  4. In support of the document screening and evaluation of the committee, the committee shall conduct a background investigation of the non-individual preparer�s previous EIA study engagements. It may also schedule an interview session (optional) with the applicant within 30 days from receipt of application to validate data resulting from background investigation. The EMB shall notify the applying entity on the date of interview at least three (3) days prior to date of interview. In cases where the president or chief executive officer of the firm/unit could not be present during the interview, the company/office may execute a power of attorney, board resolution or any appropriate instruments giving the representative full rights and authority to represent the firm/unit.

  5. The committee shall render a decision on the application for accreditation within sixty (60) days.

  6. For approved applications, the EMB shall inform the non- individual preparer in writing on the approval of their application for accreditation within three (3) working days and shall accordingly issue a certificate of accreditation.

Accredited preparers must inform the accrediting office, in writing, every three (3) years if the preparers wish to continue the inclusion of their names in the directory.

IEE and EIS Preparation

In some cases, one (1) duly accredited individual preparer is already sufficient to prepare an IEE. However, the proponent is strongly encouraged to hire the appropriate number of accredited preparers depending on the type of project. A small number of preparers may be engaged provided the critical impact receptors are within the preparer�s area of specialization.

Although the proponent has the final decision on whether the IEE will be prepared by an individual or a team of preparers, DENR reserves the right to reject such IEE, if in its opinion, the preparer is not capable of preparing the IEE single-handedly.

For projects requiring EIS, a multi-disciplinary team of preparers must be engaged to prepare it. At the minimum, the team must have at least one (1) accredited Team Leader (Level 3). Furthermore, critical or sensitive impact receptors must be assessed or handled by the appropriate expert (of at least Level 2 accreditation).

Withdrawal of Accreditation

To maintain the integrity of the EIS system and ensure professionalism and quality of EISs and IEEs being submitted to DENR, a system for withdrawal of accreditation is hereby instituted. Hence, an accreditation, once awarded to a preparer, does not preclude DENR from cancelling or revoking it once any of the following is committed by the preparer:

  • the individual or office signed agreements or contracts with proponents that puts the release of payment of fees or any part of the professional fee contingent upon the release of the ECC;

  • the accredited preparers personally follow-up the release of the ECC or puts pressure on EMB to release the ECC;

  • the individual or office has been proven to offer bribes to at least one (1) EIARC member or EMB/DENR personnel who is processing, reviewing or handling the preparer�s submissions.

  • the individual or office used data that have been copied or plagiarized without proper citation of sources;

  • the individual or office assisted the proponent in any form of misrepresentation or in misleading the public by providing false or inaccurate information about the project; and

  • the individual or office assisted the proponent in shortcutting the EIS process by not going through the scoping process properly and adequately and not fully observing public participation as provided in the EIS Procedural Manual

An accredited individual or non-individual preparer shall be subject to inquiry or investigation by the DENR accreditation committee for commiting any of the above actions upon receipt of a written and signed complaint. Or, the committee may initiate investigation at its own initiative when reasonable grounds exist. The procedure for inquiry or investigations are as follows:

  1. Upon receipt of a written statement or on its own volition, the Accreditation Committee, through the Chairman, informs the preparer of the charges or complaints.

  2. The Committee gives the preparer 15 days to respond to the allegation or complaint from date of receipt. The Committee furnishes the complainant, if any, a copy of the response.

  3. The Committee schedules an investigation of the issue. The Committee shall conduct an inquiry through the use of, but not limited to, hearings, interviews and review of documents.

    The Committee�s actions are summary in nature and therefore is not obligated to strictly adhere to the technical rules of evidence. Likewise, the Committee is not obligated to conduct adversarial hearings to hear the testimonies of the respondent (preparer) and complainant.

  4. Within a maximum of 30 days after the receipt of the response, the Committee should come-up with a decision regarding the matter and inform both the complainant and the preparer. The decision of the Committee shall be considered final and executory.

System of Public Information and Dissemination

To avoid having project proponents from claiming that they are not aware of who are the accredited or eligible EIS/IEE preparers, a system of disseminating the list of accredited EIS and IEE preparers shall be provided.

The official list of DENR (EMB and ROs) accredited EIS/IEE preparers shall be disseminated or made available to the public through EMB and DENR field offices (such as DENR RO, PENRO and CENRO).

The list shall also be published as often as practical in major and local environmental publications and mass-based publication.

An accredited preparer must inform EMB every three (3) years in order to be continually included in the directory/listing.





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