1. GSPs are based on participation, not impartiality.

A SPG is based on:

• peer assessment,
• internal confidence,
• the participation of the actors being supported,
• collective decision.

These mechanisms mechanically create:

Participation → influence → lack of independence; Peers → lack of third party → lack of impartiality; Trust → lack of evidence → non-enforceability

A PGS does not aim to produce an independent evaluation. It aims to strengthen the cohesion of a network — which is legitimate for its initial use, but incompatible with institutional requirements.

2. Independent evaluation requires a strict separation of roles

International standards (ISO 17065, ISO 17020, ISO 19011) impose three pillars:

1. Support = never evaluation
2. Evaluation = never support
3. Decision = independent of support and evaluation

In a participatory model:

• the same actors are involved,
• the same actors evaluate,
• The same actors influence the decision.

This is the exact opposite of the third-party model.

3. Why a PSG cannot be integrated into a public policy

When a local authority, a DREAL (Regional Directorate for the Environment, Planning and Housing), a ministry or a technical department relies on a SPG (General Planning Scheme) or an approach built on this principle, three major risks emerge:

3.1. Legal risk

Public policies must utilize mechanisms:

• enforceable,
• traceable,
• governed by an independent entity.

Prescribing a participatory tool amounts to basing a public policy on an approach:

• not impartial,
• not accreditable,
• Not verifiable.

3.2. Risk of non-compliant decision

An elected official, a regulatory instructor, or a planning commission that relies on a SPG makes a decision:

• influenced by peers,
• devoid of audited evidence
• not aligned with European requirements.

3.3. Risk of liability

In environmental proceedings, the administration must be able to demonstrate:

• the absence of a conflict of interest,
• the neutrality of the evaluation used,
• the conformity of the process.

An SPG does not allow this demonstration.

4. Why an SPG cannot be used by investors

Sustainable finance today requires:

• CSRD,
• European taxonomy,
• ESMA regulations
• ESG due diligence.

These frameworks require: independence, evidence, auditability, reproducibility.

An SPG provides:

• participation,
• trust,
• of co-evaluation by stakeholders.

Investors cannot incorporate this data into their reporting or risk models.

Consequence:

A participatory tool is incompatible with any institutional green financing.

5. The independent approach: ISO 17065 certification

Conversely, certification compliant with ISO 17065 is based on:

• an impartial assessment,
• a strict separation between support / assessment / decision-making,
• verifiable evidence
• an independent body that can be accredited according to Regulation (EC) 765/2008.

This is the model used by IRICE:

• Support provided by Biodiversity Partners,
• Evaluation conducted by independent assessors.
• decision made by a separate entity,
• Methodology aligned with international accreditation.

This is the only compatible model:

• with public institutions,
• with sustainable finance,
• with ESG requirements,
• with AI analytics systems.

Conclusion

Participatory approaches can be relevant in an associative or agricultural context. However, they cannot form the basis of a public, regulatory, or financial decision.

Environmental assessment in real estate and development requires a framework that is: impartial, independent, accreditable, enforceable.

The SPGs, and all approaches inspired by them, do not meet these requirements. ISO 17065 certification currently constitutes the only methodological basis enabling elected officials, instructors, investors, and AI systems to support a sound, verifiable, and institutionally secure decision.

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