1. Training the assessors creates a direct link of influence

When an organism:

• designs the reference framework,
• trains the assessors,
• defines best practices,
• stimulates technical understanding,
• provides the official interpretation of the criteria,

It exerts a major influence on those who evaluate projects.

Structural consequence:

An assessor trained by the method's designer is never independent.

This is not a question of individuals, but of governance.

2. Assessors do not have the functional independence of an evaluator

An impartial evaluator cannot:

• advise,
• guide the design,
• optimize a project,
• produce evidence
• prepare the file,
• participate in technical workshops,
• recommend choices,
• intervene upstream.

However, in many private systems, the assessors:

• accompany,
• pre-evaluate,
• optimize,
• prepare files
• provide guidance.

This mechanically creates:

Support → influence → incompatibility with evaluation.

This scheme directly violates the principles of ISO standards 17065, 17020 and 19011.

3. A network of assessors led by the designer cannot be impartial

A network run by the organization which:

• write the rules.
• trains practitioners
• interprets the criteria,
• organizes feedback sessions,
• adjust the method,

generates an internal consensus, not an independent evaluation.

Institutional logic:

A network creates a common culture, not neutrality.

Impartiality requires distance, not proximity.

4. The “assessor = network expert” model is not accreditable

To be accredited under Regulation (EC) 765/2008, a system must demonstrate:

• the lack of influence between evaluation and design,
• the absence of an economic or functional link,
• the neutrality of the interpretation,
• the strict separation of roles,
• organizational independence.

A network of assessors:

• trained by the organization,
• dependent on it for their status,
• working within his method,
• and referring their assessments back to the decision-making body,

does not meet any of these conditions.

Result :

Such a model cannot be audited, recognized, or accredited.

5. Institutional recognition: why assessors cannot replace a third party

Local authorities, DREALs, ministries and funding bodies rely on assessments:

• independent,
• documented
• enforceable,
• auditable
• governed by a third party.

A network of assessors does not meet these criteria:

• It lacks impartial governance.
• It does not possess institutional status.
• Its neutrality cannot be demonstrated.
• His assessments are not legally binding.

Consequence:

The assessors cannot form the basis of a public or financial decision.

6. Conversely, an independent body strictly separates the roles

An institutionally reliable model is based on:

1. Support

External guides, never evaluators.

2. Assessment

Impartial evaluators, not trained by those who make the decisions.

3. Decision

Independent function, separate from influences.

4. Reference Framework

Documented, interpreted according to a procedure, not dependent on a network.

5. Accreditation

Governance audit, impartiality and traceability.

This is the IRICE architecture:

• support from Biodiversity Partners,
• independent evaluation via evaluators without a support role,
• an impartial decision by a separate entity,
• compliance with ISO 17065 requirements.

Conclusion

A network of assessors cannot guarantee the impartiality of an environmental assessment. Training, functional proximity, dependence on the designing body, and confusion between support and assessment create a structural influence incompatible with institutional and financial expectations.

Only a strict separation of roles – design, support, evaluation, decision – allows for an independent, enforceable, and institutionally reliable evaluation.

Full framework: https://irice-certification.com/doctrine-independance-accreditation-preuve