RE: EA Response19 Dec 2018 03:51
DYOR but what I was sent was the following as the outcome from the EA, the original notice is I’m Slovenian and translation is below, however please all DYOR.
III. Conclusions
1. The Commission determines that Director General of ARSO, _____________, violated the principle of independence and autonomy of the agency and the work of its officials by allowing _____¬¬¬¬_______ ___, General Manager of the Environment and Nature Protection Office as a representative of ARSO, to attend the meeting on 8.8.2018 at the Ministry of the Environment and Spatial Planning regarding actual procedures, i.e. environmental permits. The circumstance in question poses a high degree of risk and exposure to potential allegations regarding impartial management and decision-making processes of the officials in this procedure. By doing so he also severely exposed the reputation of the agency in public. The worst allegation or complaint the commission summarized by reviewing the situation and public response is the fact that the persons from abroad apparently do not find it unacceptable and contentious putting pressure on Slovenian officials and are willing to repeat them.
2. The Commission determines that public relations in ARSO are not organized in a way to ensure professional communication with the public. By allowing the possibility of an unauthorized PR individual to form the text of the actual messages in administrative procedures, they present the work of the agency improperly and in a way that is potentially legally disputable.
3. The Commission determines that the General Manager of the Environment and Nature Protection Office, ____________, asserted doubt about the independence and autonomy of the agency by attending the meeting and giving information regarding the actual procedure, and allowed the public to interpret the matter in a way that blackened the agency's reputation and its officials in public.
4. The Commission also determines that Director General, _____________, has established the line of work inconsistent with fundamental principles of the General Administrative Procedure Act, by personally interpreting actual administrative procedures and informing his superiors about the manner of decision making process regarding the issue in question before rendering the decision.
5. The Commission suggests that the Director General of the Environment Directorate should forward the report of the meeting held on 8.8.2018 so as to comply with the provisions of the Integrity and Prevention of Corruption Act. It further suggests that the legal basis for convening the meeting be verified in the light of the Ministry competence.
6. The Commission suggests that compliance analysis of the current arrangement about following BAT principles (best available technology) be made when issuing the environmental permit, along with professional expertise and competence of the individuals, producing the documents
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