Why a comment function is necessary in the EIA portal
A comment function in the portal makes it quick and easy to submit a statement or objection. In this way, the authorities also receive all comments on an EIA in one place. Furthermore, in some EIA portals (e.g. in Kazakhstan) it is possible to read the comments submitted by other citizens and react to them with emoticons such as “thumbs up/down”. This allows citizens to see which topics have already been addressed in comments, so that the authorities may receive fewer comments with the same arguments. In addition, the authorities can use the emoticons to recognise whether the comments from the public are met with approval or rejection. Overall, the comment function is important to make the submission of comments more user-friendly for the public and to simplify the process for the authorities.
Currently, not many EIA portals have a comment function or comment field to enter and submit comments directly in the portal. Instead, the public usually has to send their comments to the responsible authorities by email. This is also the case in the German EIA portal, for example. In the portal, the e-mail address and telephone number of the competent authority can often be found in the description of the project.
In countries where there is no EIA portal, it is often also necessary to search for the e-mail address or contact details on the website of the competent authority that publishes the project documents. In some cases, comments can also be submitted by post or telephone. In some countries, this leads to a confusing situation if each authority decides for themselves how the comments should be submitted (in writing, electronically or in person).
Well-implemented comment functions in EIA portals can be found in Spain, Kazakhstan, Canada and a regional portal in Germany (Brandenburg participation platform), among others.
Good practice examples
Spain
In the Spanish EIA portal of the responsible ministry MITECO (Ministerio para la Transición Ecológica y el Reto Demográfico), comments can be submitted directly via a comment field. Citizens write their comments directly in the box provided for this purpose, with no limit on the number of characters and with the option of attaching a document with a maximum size of 10 MB (a sufficient size for submitting non-technical comments). In addition, only the e-mail address of the person who wishes to submit the opinion needs to be entered as personal details. No complicated identification and registration procedure is necessary.
The comment field looks like this:
Source: Spanish EIA portal of MITECO (Ministerio para la Transición Ecológica y el Reto Demográfico).
Kazakhstan
The comment function is also well implemented in the Kazakh Ecoportal, which was launched in 2021. EIA procedures and other procedures are published on the Ecoportal. To be able to submit comments, citizens must first authorise themselves with an electronic digital key, which every citizen in Kazakhstan receives. As soon as citizens are authorised, comments can be submitted easily via a comment field in the portal.
Source: Screenshot of the comment field on the Kazakhstan Ecoportal
Kazakhstan also has a government website on which all laws must be published. After citizens are authorised they can also submit comments and read the comments of other citizens. This allows citizens to see which topics have already been addressed in comments, so that the authorities may receive fewer comments with the same arguments. Moreover, the users can respond to comments with emoticons such as “thumbs up/down”. Authorities can also use the emoticons to see whether projects or new laws are received positively or negatively by the public. In addition, the operators of the portal can also respond directly to comments on the portal and this is also visible to all users, which facilitates communication between the authorities and the public.
Source: Kazakh Legal Acts Portal
Canada
A good comment function has been implemented in the Canadian portal (Canadian Impact Assessment Registry). Citizens must first log in to the portal and authorise themselves. They can then submit comments themselves, either as a citizen or on behalf of an organisation. They can also read all the comments that have already been submitted and view the opinions and feedback from indigenous groups, experts, project developers and authorities. Citizens also have access to training courses on environmental impact assessment.
Source: Screenshot of the Canadian impact assessment registry
Germany (region of Brandenburg)
Another good practice example of successful implementation of the comment function can be found on the Brandenburg participation portal. The participation platform was developed by Brandenburg’s environmental NGOs in collaboration with UfU to facilitate the joint processing of comments. Members of the environmental NGOs can log into the portal and use a text field to submit statements and comments in the portal. The portal also shows how many comments have already been submitted on a project. The regional association of environmental NGOs then collects the comments and objections received and can use this as a basis for drawing up a joint statement supported by all environmental NGOs and submitting it to the authorities. This makes co-operation between environmental NGOs and authorities much easier and is also appreciated by the authorities. Participation platforms based on the same concept were subsequently also set up in the federal states of Berlin and Lower Saxony.
