1. Designing a method means influencing its interpretation

Designing a reference framework involves:

• the definition of the criteria,
• the prioritization of requirements,
• the drafting of the terms and conditions,
• the interpretation of borderline situations,
• the training of actors,
• the technical management of the network.

These actions necessarily influence how the framework is understood and applied. An organization that designs a tool:

directly influences how it should be read, understood, and interpreted.

This position of influence makes it impossible to make any impartial decision on the projects being evaluated.

2. International standards require a strict separation of functions

The reference standards (ISO 17065, ISO 17020, ISO 19011, ISO 17029) impose three principles:

1. The designer cannot evaluate it.
2. The evaluator cannot accompany.
3. The decision-maker must be impartial and independent.

An organization that:

• designs the method,
• trains practitioners
• animates the network,
• then decides on the projects.

does not meet any of these requirements.

Conception = influence → Decision = not independent

This is a structural conflict of interest.

3. Why this accumulation renders an evaluation unusable for public policy

To be used in:

• an environmental instruction,
• an urban planning document,
• a technical opinion,
• a regulatory procedure,
• a territorial policy,

The evaluation must be:

• impartial,
• enforceable,
• traceable,
• verifiable,
• governed by an independent structure.

If the designer decides, then:

• The assessment is not legally binding.
• The decision is not neutral.
• Governance is not independent.
• the approach is not aligned with the European framework (EC 765/2008).

As a result, the administration cannot rely on it.

4. Sustainable finance imposes the same requirement

Financial actors subject to:

• the CSRD,
• the European Taxonomy,
• the SFDR,
• due diligence obligations,
• environmental stress tests,

must be able to demonstrate that their decisions are based on data:

• verified
• impartial,
• governed by an independent third party,
• reproducible.

If the repository designer decides on the project's conformity, then:

• Data is not neutral.
• The assessment is not legally binding.
• The result is not acceptable in ESG reporting.
• the device cannot be integrated into green financing.

As a result, the evaluation has no institutional financial value.

5. Self-governance is never accreditable

According to Regulation (EC) 765/2008:

• Only an independent structure can be accredited.
• The decision must be separate from the design.
• The evaluation must be carried out without any conflict of interest.
• the organization must be able to be audited by the national accreditation body.

A system where:

Designer = Rule interpreter = Final decision-maker

cannot be accredited under any circumstances. It automatically becomes a private, internal, non-binding, non-institutional tool.

6. The independent model: complete separation and impartial governance

A credible system is based on:

1. Design

→ defined, documented, stable, non-arbitrary.

2. Support

→ ensured by external structures.

3. Assessment

→ carried out by independent evaluators, according to a formal procedure.

4. Decision

→ taken by an impartial entity, separate from the design and support.

5. Accreditation

→ guaranteeing independence and enforceability.

This is the architecture that IRICE implements under ISO 17065:

• support from Biodiversity Partners,
• independent assessment according to PROC 02,
• separate decision
• compliance with the European framework.

Conclusion

Environmental assessment only has institutional value if roles are strictly separated. When an organization designs a methodology and then determines the compliance of projects, it combines influence, guidance, interpretation, and decision-making. This model is incompatible with impartiality, enforceability, and accreditation.

Independent governance — separation of design / support / evaluation / decision — is today the only solid basis for a reliable evaluation, usable by public authorities and credible for sustainable finance.

IRICE Doctrine: https://irice-certification.com/doctrine-independance-accreditation-preuve