3rd Entry

Posted by andre at Sep 06, 2012 11:41 AM |
Filed under: ,
Work continues at NEPA with the continuous update of draft guideline documents for the Wastewater and Sludge Regulations (2012). For the past few weeks, new developments have made the revisions easier: The regulations have now been approved by the Chief Executive Officer of NEPA, and the original Word documents of the two guideline documents have been made available for direct revision. Working on the guideline documents for an evolving piece of legislation had been a challenge.

When making changes to the guidelines, one would need to either assume that the associated regulation would remain intact, or be able to foresee the eventual changes in the regulation, adapting the guidelines accordingly. This could easily become a game of divination, where one must factor in the behavior and interests of other commenting parties in order to make simple, relevant changes. Would the monitoring department decide to require global positioning coordinates from each waste treatment plant? Would the legal department agree some of the language in a certain section is overly vague? Wait until the commentary period is concluded and the regulations updated- Some changes could only be flagged and revisited at a later date.

The recent availability of the guideline Word files has additionally improved the pace of editing. Prior to their availability, all editing recommendations were entered into a log for review and- sometimes- adoption. The process required the simultaneous manipulation of several documents to locate mistakes and presented the challenge of properly describing the location of the error within the document with the corresponding recommended change. This must have been one of the most difficult tests of my communication skills that I have ever faced; however, compiling page after page of recommendations in this way required development of a thorough knowledge of the regulations and a deep evaluation of each change I was requesting. This led to better recommendations and made the direct editing of the guidelines much easier since I would eventually have available a detailed log of recommendations.

As the revision process winds down, my attention has been turned to a new project. Simply, this new project is a search for a suitable methodology for classification of marine waters into one of two classes. This classification is a requirement of the LBS Protocol to the Cartagena Convention, with the two classes entailing distinct limits on the parameters monitored in effluent discharged to the marine environment. More vulnerable waters are categorized “Class I” while all other water are designated “Class II.” What features determine class, and where to delineate the boundary between the two is somewhat open to the contracting party to the Protocol. Because of this openness, development of a unique classification methodology for each nation can require an immense amount of research. The challenge now is evaluating what has been implemented by other nations and deciding what methodology, or mix of methodologies, is proper for Jamaica.

I look forward to this challenge as my internship winds down. The project promises a potential wealth of lessons to be learned that will undoubtedly be valuable in my continuing education and future career.  

Challenges faced: Now that NEPA has submitted final commentary, this challenge has been made de facto non-existent. The editor knows what will be in the regulations and has all that is needed for drawing up a comprehensive guideline.

Lessons learnt:  The lesson here could be that government agencies move slowly. Patience is required; however, attention can be refocused on the details which are already known, preparing one for the agency’s eventual movement forward.