# Environmental Screening Tool — Officer Manual *Pilot v0.1 · L.I. 2504 (2025) / Act 1124 (2025) · scoping.resilicity.com* This manual is for assessment officers using the Screening Tool day-to-day. For admins setting up Earth Engine credentials, see `GEE_SETUP.md`. For methodology + data lineage, see `METHODOLOGY.md`. For running the historical-decisions validation harness, see `VALIDATION_HOWTO.md`. --- ## 1. What the tool does For any project location in Ghana, the Screening Tool composes three independent analyses into a single auditable output: | Layer | What it produces | |---|---| | **Regulatory pathway** | Verdict (requires_eia / requires_registration / requires_sea / no_permit_required / refused), legal citations from L.I. 2504, indicative fee band (Act 1080), permit lifecycle, public-hearing triggers (Reg 24), transboundary flag (Reg 32), required baseline studies. | | **Spatial environmental profile** | 20 indicators evaluated at the project location: flood, wetland, river, protected area, road setback, slope, seismic, soil, infrastructure, HT electricity ROW, galamsey, coastal erosion, contamination, groundwater. Each returns red/amber/green with a source citation. | | **Plausibility cross-check** | Detects physical impossibility and order-of-magnitude scale mismatches (e.g. cement plant footprint vs declared production) using ~14 sourced benchmark entries. | Every output is **decision support, not an Authority determination.** The legal force of any decision derives solely from your formal act under Act 1124 and L.I. 2504. --- ## 2. Signing in > **Pilot Open-Access note (2026-06-25 – EPA billing decision).** During > the pilot, `OPEN_ACCESS_MODE=1` on the server suspends the sign-in > gate. You can go straight to https://scoping.resilicity.com and use > the tool without login. All work is attributed to a shared > `pilot-visitor` audit identity. Admin routes (user management, ruleset > edits) remain gated even in Open-Access. The workflow below is what > the officer experience becomes once the Authority green-lights > billing and the sign-in gate is re-enabled (a 2-env-var flip on the > server, no code change). 1. Open https://scoping.resilicity.com 2. Enter your `@epa.gov.gh` email address. 3. Tick **Remember me on this device** (default, 90-day session). Untick on a shared computer (8-hour session). 4. Click **Send sign-in link**. You receive a passwordless magic-link email — no password is ever stored or sent. 5. Open your inbox, click the link. The link expires in 15 minutes and can only be used once. 6. After click-through you land in the officer dashboard with your email + role badge in the top-right. ### If something goes wrong | Symptom | Fix | |---|---| | No email after 1 min | Check spam. Try again — only the newest link works. | | "Invalid or expired" on click | Link is older than 15 min or already used. Request a new one. | | "Account is disabled" | Ask your admin to re-enable you under **Manage users**. | | Email not on the allowlist | Only `@epa.gov.gh` addresses can sign in. Two operator overrides exist for the pilot maintainers; ask your admin if you legitimately need a different address. | --- ## 3. Dashboard at a glance ``` ┌─ Cases │ Analytics ────────────────────────────────────────────────┐ │ Workspace sidebar │ Stat cards (Overdue · Due 5d · Due 10d · TRC) │ │ ▣ Active │ View pills (My queue / All / Overdue / TRC) │ │ ▣ Test │ Filter row (sector · decision · district …) │ │ ▣ Archive │ │ │ ▣ Deleted │ Cases table — click any row for detail │ └───────────────────┴────────────────────────────────────────────────┘ ``` - **Workspace folders** behave like email folders. **Active** is your live queue. **Test** is for sandbox screenings (won't show in the Director's reports). **Archive** is closed cases retained for precedent / audit. **Deleted** is a soft-delete bucket that an admin can permanently purge (non-signed-off cases only). - **My queue** is the default view — cases assigned to you. Switch to **All** if you're admin and need to see every officer's queue. - **Overdue** highlights cases past the 25-day screening clock. - **TRC-ready** filters to cases ready for the next Technical Review Committee meeting (status = `in_review`, decision flagged for manual review). --- ## 4. Running a screening — the five steps ### Step 1 — Locate the project You can locate a project four ways: 1. **Search** a place name (any Ghana town, market, school, address). 2. **Paste GPS coordinates** in any of these formats (the tool parses all): - Decimal: `5.6037, -0.1870` - DMS: `5°36'13"N 0°11'13"W` - Decimal minutes: `5°36.22'N 0°11.22'W` - Labelled: `lat: 5.6037, lon: -0.1870` - **Google Maps URL** — long form OR short link (`maps.app.goo.gl/…`) — server-resolves the redirect. - **Apple Maps URL** — `https://maps.apple.com/?ll=5.6,-0.187` - **OpenStreetMap URL** — `#map=15/5.6/-0.187` - **Plus Code** — `6FR4G6V8+RC` 3. **Use my current location** (GPS). Great for in-the-field officers on the PWA. 4. **Click the map**. The cursor drops a pin where you click. For multi-site projects, switch to **Boundary box** mode and enter two opposite corners — the tool screens the centroid. > ⚠ The map is for visual reference only. Satellite imagery date varies > and is not evidence of legal boundaries, ownership, or approval. ### Step 2 — Capture project details Sector + sub-type + scale drive the regulatory pathway. The sub-type dropdown changes based on the sector: | Sector | Common sub-type field | |---|---| | Agriculture | `crop_type` (cassava, maize, rubber …) | | Manufacturing | `process_type` (cement, steel, paper …) | | Mining | `mineral_type` (gold, bauxite, sand …) | | Oil & gas | `fuel_type` (lpg, diesel, crude …) | | Real estate | `building_type` (residential, commercial …) | | Health | `facility_type` (clinic, hospital, lab …) | | Energy | `process_type` (solar_pv, wind, hydro, ccgt) | | Waste management | `treatment_method` (landfill, incinerator, mrf) | | Transport | `transport_type` (road, rail, airport, port) | | Water & sanitation | `waterworks_type` (intake, treatment, stp) | Without sector + scale, the rule engine returns `insufficient_information`. ### Step 3 — See the merged verdict Click **Open Full Report**. You'll see, in order: 1. **Verdict banner** — the decision (e.g. SCHEDULE 2 — FULL EIA), colour-coded by class, with the L.I. 2504 reg citation. 2. **Critical conditions strip** (amber) — only renders when at least one of: reclamation bond required / manual review / public hearing probable / transboundary impact. 3. **§1 Regulatory grounding** — every rule that fired, with rule ID + statutory ref + plain-English explanation. 4. **§2 Required permits & agencies**. 5. **§3 Indicative fee + lifecycle**. 6. **§4 Process & timeline** — 25-day screening + 90-day total clock. 7. **§5 Required baseline studies** — one card per study with parameters, method, duration, Ghana Standard reference. 8. **§6 Scoping topics for the EIS/EMP**. 9. **§7 Spatial risk profile** — overall + 20 indicators. 10. **§8 Plausibility flags**. 11. **§9 Penalty exposure if unregistered** — financial + imprisonment + Authority powers + reputational. 12. **§10 Methodology & provenance**. 13. **§11 Disclaimer**. ### Step 4 — Save as a case Click **Save as case**. The case enters status `created` (or `assigned` if you set yourself as officer). The reference number is auto-generated (`SCT-YYYY-NNNNNN`) and the 25-day screening clock starts. ### Step 5 — Issue determination + decision letter Click **Download determination PDF** for the 11-section auditable document. Click **Reg 29 decision letter** for the L.I. 2504-compliant letter (pre-filled with the case ref, project title, sector, grounds, scoping topics, conditional clauses, Reg 30 appeal-rights paragraph, and two signature blocks). > Every PDF you download today carries a **diagonal DRAFT watermark**. > The watermark prints only on the digital version — when you transcribe > onto official the Authority letterhead and sign in ink, that becomes the > Authority's determination. The watermark exists to prevent unsigned > drafts from being mistaken for issued letters. --- ## 5. The 20 spatial indicators — quick reference For each indicator: what fires it, what status means, what the EIS/EMP should address. | # | Indicator | Red (avoid / blocker) | Amber (mitigate) | Source | |---|---|---|---|---| | 1 | **Flood** | Inside JRC 10-yr return period OR mapped flood polygon | 100-yr / 500-yr envelope, drainage stress | OSM + JRC GSW (Pekel 2016) + GHSL R2023A + GLO-30 + JRC LISFLOOD-FP | | 2 | **Wetland** | Inside Ramsar Site OR OSM wetland polygon | JRC GSW wetness % > 5 within 200 m | Ramsar Sites Information Service (6 Ghana sites) + OSM + JRC GSW | | 3 | **River corridor** | Inside statutory riparian setback (60 m river / 30 m stream) | Inside advisory buffer (120 m / 60 m) | HydroSHEDS HydroRIVERS v1.0 + WRC Riparian Buffer Policy | | 4 | **Protected area** | Inside WDPA polygon | Within 1 km of WDPA boundary | WDPA 2024 (UNEP-WCMC / IUCN) | | 5 | **Road setback** | Inside statutory road reservation | Within GHA advisory buffer | OSM Geofabrik Ghana | | 6 | **Slope** | > 15 % (steep — erosion / landslide risk) | 5–15 % | Copernicus DEM GLO-30 (2019; ±4 m), Horn 3×3 | | 7 | **Seismic** | PGA ≥ 0.20 g (high) | 0.10–0.20 g | Ahulu et al. 2018 PSHA, *J. Seismology* | | 8 | **Soil** | Expansive clay / problematic | Sandy / moderate | ISRIC SoilGrids v2 + WoSIS Dec 2023 | | 9 | **Infrastructure** | > 10 km from grid / urban centre (off-grid build) | 3–10 km | GSS urban + OSM power lines | | 10 | **HT electricity** | Inside statutory ROW (15 m for 161 kV / 20 m for 330 kV) | Inside ICNIRP advisory setback (30 / 50 / 100 m by class) | OSM HV grid + ICNIRP 1998/2010 + L.I. 542 / L.I. 1737 | | 11 | **Galamsey** | Confidence ≥ 0.6 with Sentinel-2 confirmation | 0.3 ≤ confidence < 0.6 (Tier-1 capped at 0.7) | 97 documented hotspots + HydroRIVERS Pra/Ankobra/Tano basin + ~80-district prevalence + Sentinel-2 NDVI delta (Forkuor 2020) | | 12 | **Coastal erosion** | Segment retreat rate > 5 m/year within 5 km of coast | 1–5 m/year | Asare-Bediako 2025, Angnuureng 2023, Ankrah 2024, Appeaning Addo 2016, Boateng 2012 | | 13 | **Contamination** | Inside curated contamination site polygon | Within 1 km of one | Pure Earth Pollution Atlas + Authority records | | 14 | **Groundwater** | HAND < 2 m OR inside BGS coastal sedimentary basin OR JRC max-extent fired | HAND 2–5 m, flat terrain near drainage | BGS Africa Groundwater Atlas + JRC GSW + GLO-30 HAND | | 15 | **Dam-spillage envelope** | Inside a documented spillage-inundation envelope (Akosombo · Kpong · Weija · Bui · Bagre · Tono · Vea) | Within 500 m of the envelope | VRA / BPA / SONABEL / ICOUR spillage bulletins, Akosombo Spillage Committee Report 2025 | | 16 | **Recent flood events (2015-present)** | Inside a NADMO / HSD / CEMS documented flood polygon | Within advisory buffer of the polygon | 40 curated events (NADMO, Hydrological Services Department, Copernicus EMS, DREF MDRGH018, FloodList) | | 17 | **Urban drainage** | Inside Tier-1 hand-curated GA drainage-stress polygon, or ≥ 2 Tier-2 OSM channels within radius, or Tier-3 S1 SAR signature | Advisory buffer / single OSM channel | AMA + GAMA drainage master plans + OSM + Sentinel-1 SAR | | 18 | **REGSEC predictive high-risk** | Inside one of the 12 REGSEC-flagged Greater Accra grouped zones | Adjoining a zone | 10 June 2026 Greater Accra REGSEC statement | | 19 | **Cultural heritage** | Inside cordon of UNESCO WHS Forts/Castles, Asante Traditional Buildings, or GMMB-gazetted national monument | Inside advisory buffer | UNESCO WHS 1979/1980 inscriptions + GMMB National Monuments + NLCD 387 | | 20 | **Government / institutional lands (state-vested)** | Inside a state-vested parcel (universities, CSIR, MoFA, CRIG, GAF public installations, prisons, teaching hospitals, GAEC / VRA / BPA / TDC / GWCL / Achimota) | Within 200 m of the parcel boundary | 76-feature curated catalogue (2026-07-02) + Lands Act 1036 [state-vested provisions pending gazette section confirmation] + State Lands Act 125 + Constitution Art 258 | Every red or amber finding auto-generates a **scoping topic** the EIS/EMP must address, linked to the responsible agency. --- ## 6. Case lifecycle ``` created ──► assigned ──► in_review ──► signed_off │ ├──► rejected └──► withdrawn ``` | Status | Means | |---|---| | `created` | Case exists but no officer is assigned yet. | | `assigned` | An officer has the case. The 25-day screening clock is running. | | `in_review` | Officer is preparing for TRC sign-off. Use this filter to find your meeting-prep cases. | | `signed_off` | TRC has signed; compliance schedule auto-generated. Clock stops. | | `rejected` | Application refused. Clock stops. | | `withdrawn` | Proponent withdrew. Clock stops. | **Statutory clocks** (per L.I. 2504): - **25-day screening clock** — initial determination (Reg 6). - **90-day total clock** — full decision (Act 1124). Suspends when a public hearing is required (Reg 17(b) / 24). The dashboard's stat cards surface clocks in real time: **Overdue screening clock**, **Due in 5 days**, **6–10 days**, **11–15 days**. --- ## 7. After sign-off — the compliance schedule The moment you set status `signed_off`, the tool auto-generates six dated obligations per L.I. 2504 Reg 30: | Obligation | Date | |---|---| | Appeal window closes | sign-off + 30 days | | Initial EMP submission due | + 18 months | | Permit renewal notice window opens | + 21 months | | First EMP update due | + 54 months | | Decommissioning notice window opens | + 60 months | | Second EMP update due | + 90 months | Each obligation tracks status (pending / received / waived / overdue) and surfaces on the dashboard's lifecycle widget. Update the status inline as proponents submit; tick **received** when the submission is verified, **waived** when the Authority's discretion is exercised. --- ## 8. Field verification (PWA companion) Install the tool on your phone: 1. Open https://scoping.resilicity.com in Chrome (Android) or Safari (iOS). 2. **Install on this device** in the menu (Chrome) or **Add to Home Screen** (Safari). 3. The icon lands on your home screen; opening it goes straight to the dashboard. For on-site verification: 1. Open the case detail page. 2. **Add field verification** → captures GPS coordinates, lets you note discrepancies (e.g. *"declared location was 350 m off"*) and attach a photo (up to 20 MB). 3. If the on-site GPS is **> 200 m** from the declared coordinates, the dashboard surfaces a red GPS-discrepancy alert above the case detail with a one-click **Re-screen at on-site coordinates** action that re-runs `/screen` against the verified point. --- ## 9. TRC meeting prep — the bundle PDF The Wednesday TRC ritual: pick 5–10 cases, generate one stack. 1. In the cases list, tick the checkboxes next to the cases you want. 2. **Bulk action bar** appears at the bottom of the screen. 3. **Generate TRC bundle PDF** → produces a single PDF containing: - Meeting cover (date + location + attendees) - Agenda (one row per case with verdict + critical conditions) - Per-case summary slide + the full determination PDF spliced in 4. Print one stack; pass round the room. (Admins can bundle any case; officers can only bundle their own; the bundle silently skips cases the user can't access.) --- ## 10. Bulk operations The bulk-action bar (visible when you tick ≥ 1 case in the table) lets you apply the same action to many cases: - **Assign** to one officer - **Set status** (created / assigned / in_review) - **Move workspace** (to test / archive / deleted) - **Generate TRC bundle PDF** Bulk operations reuse the single-case audit + refusal logic — the bulk endpoint cannot do anything a single-case path can't. --- ## 11. Precedent finder Open any case → **Precedent finder** panel → returns the most-similar prior cases ranked by: 1. Same sector 2. Same sub-type 3. Same district 4. Same spatial risk class Click any row to open that historical case in a new tab. Useful for two scenarios: - *"How did the Authority handle the last cement-plant application in Cape Coast?"* - *"This galamsey-flank Obuasi case looks identical to SCT-2025-XXXX — what was the determination there?"* Test-workspace and deleted cases are excluded. Archive cases (signed-off + archived) are included — they're the most useful precedents. --- ## 12. Region / district analytics The **Analytics** tab gives you bar charts + tables grouped by: - Sector - District - Decision class - Spatial risk - Workspace - Officer For each bucket: total cases, decision distribution (stacked), average days-to-sign-off, active-overdue count. Filter by date range. Export as CSV for head-office monthly reports. --- ## 13. Reconcile a scoping report If a proponent has submitted a scoping report and you want to cross-check what they wrote against the spatial evidence at the project location: 1. From the landing page, **Reconcile a Scoping Report**. 2. Paste the report text (or upload a PDF). 3. The extractor parses location, sector, scale, and the topics the report addresses. 4. The tool runs the screening at the extracted location and compares: - For each red/amber indicator at that point, is it addressed in the report? → **gap** if not. - For each plausibility flag, does the report's declared scale match the benchmark? → **discrepancy** if not. 5. Output: three columns + officer-ready next steps + 1–2 sentence summary suitable for the case file. --- ## 14. Common pitfalls - **Insufficient information verdict** — the rule engine returned nothing because sector / sub-type / scale wasn't set. Open the case, click **Amend inputs**, fill in the missing fields, and the tool re-runs the orchestrator. - **Tool says red, your judgement says amber** — that's expected. The tool surfaces evidence; *you* decide. Document your reasoning in the case notes; the audit log captures it. - **Galamsey amber when Tier-1 confidence is high but Sentinel-2 isn't active** — by design, Tier-1 caps confidence at 0.7. Red status requires Sentinel-2 confirmation. Activate Sentinel-2 by configuring GEE credentials (see `GEE_SETUP.md`). - **Ramsar Site flagged red** — the tool refuses to colour Ramsar sites amber even when other indicators are mild. Convention Article 3.2 obliges joint the Authority + Forestry Commission Wildlife Division approval; most development inside a Ramsar Site will be refused outright. - **Coastal erosion shows segment rate ±2× the locally observed rate** — local seawalls, groyne fields, and sand mining cause large variation. Verify with a certified coastal engineer. --- ## 15. Audit trail Every action you take generates a SHA-256-chained audit entry: ``` hash[n] = sha256( canonical_json(payload[n]) + hash[n-1] ) ``` Each payload embeds the **data lineage** at decision time — platform version, ruleset version, spatial-data release, and dataset versions. A tampered row breaks every downstream hash. To verify a case's audit chain integrity, open the case → **Audit trail** → **Verify chain** (or the API endpoint `GET /cases/{id}/audit/verify`). The tool re-computes the chain and reports the first invalid entry if any. --- ## 16. FAQ **Q: I've signed off the wrong case. Can I undo it?** A: An admin can move it back to `in_review` via PATCH. The audit log captures both the original sign-off and the reversal — nothing is hidden. **Q: Can I share a case with a colleague?** A: Only an admin can reassign cases between officers (the audit log captures the reassignment). For collaboration without reassignment, the case detail page has a **Notes** field both officers can edit. **Q: How do I purge a case permanently?** A: Admin-only. Cases must first be in `Deleted` workspace. Signed-off production cases can never be purged (regulatory record). **Q: How do I generate a determination for a one-off screening I haven't saved as a case?** A: After the report renders, click **Download determination PDF** at the top of the report card. The ref label is `SCT-YYYY-MM-DD-PRELIM`. **Q: What if EIAfinder or SafeGround is down?** A: The tool returns a degraded verdict (`insufficient_information` + `error`) and the `upstream_status` block in the response tells you which engine is down. Try again in 5 minutes; if it persists, contact your admin. **Q: How fresh is the data?** A: WDPA quarterly · OSM continuously · JRC GSW updated annually · GLO-30 from 2019 (no newer global DEM exists at this resolution) · Sentinel-2 imagery 14-day cache for the galamsey detector · Ramsar inventory cross-checked 2024-01. **Q: Can the tool be used outside Ghana?** A: No. The rule engine is jurisdiction-bound to L.I. 2504 and the spatial layers are clipped to the Ghana bbox. Coordinates outside Ghana return a 422 error with a clear message. --- ## 17. Getting help - **Pilot maintenance**: support@resilicity.com - **Methodology questions**: see `METHODOLOGY.md` - **Admin / credential setup**: see `GEE_SETUP.md` - **Validation against historical decisions**: see `VALIDATION_HOWTO.md` --- ## 18. Fee Estimate + Act 1080 lookup ### 18.1 What it does Every determination now cites a fee under the **Fees and Charges (Miscellaneous Provisions) Act, 2022 (Act 1080)** — the Authority's authoritative fee schedule. PDF §3 runs a fee probe on the case's sector + sub-type and prints: - The gazetted line item (row + section number) when the match is unambiguous, - The band range (from-to) when the sub-type could match multiple rows (e.g. hotels have 4 room bands), - A `/fees` pointer when the match is too ambiguous to auto-quote — the officer looks it up manually before invoicing. The engine **never invents a fee**. If the schedule doesn't cover the activity (rare — 653 line items across 9 sectors), the report says so plainly. ### 18.2 Standalone fee lookup Officers can open **`/fees`** at any time (top-nav → "Fee lookup") to search the schedule without running a screening. Type the activity ("brewery", "hotel", "clinic", "solar farm") and the engine returns the matching Act 1080 rows with their sector, sub-category, unit basis (per room / per bed / per MW / per m² / per litre / per ton / flat), and fee. - Light plural/gerund stemming — "breweries" matches "brewery", "processing" matches "process". - Case-insensitive. - Currency: fees are quoted in **GHS**. When the schedule prices in USD the engine converts using the current declared rate (visible on the lookup page). ### 18.3 The 9 canonical sectors Mining · Energy · Manufacturing · General Construction · Agriculture · Health · Tourism & Hospitality · Telecommunication · Pesticides. Older cases still using the 11-sector taxonomy (oil_and_gas, real_estate, transport, waste_management, water_and_sanitation) resolve through legacy aliases — see §21. --- ## 19. Reconsideration / Enhanced-Mitigation pathway ### 19.1 When to use it A refused case is not always the end of the road. The Netherlands "living on water" precedent shows that hard-refused-by-default undertakings sometimes gain conditional consent when the proponent comes back with **certified enhanced-mitigation design**. This tool tracks that pathway explicitly. Two tracks: - **Standard Reconsideration** — for refusals where the underlying spatial override carries a documented exception clause (e.g. flood-resilient public infrastructure inside a dam-spillage envelope; certified culvert / flyover across a river corridor). Any officer with case access can open the track. - **Hard-Case Override** — for refusals against *non-negotiable* triggers (constitutional-level protections: Ramsar Sites, UNESCO WHS core zones, National Park core, nuclear-security cordons). **Restricted to Regional Directors and the CEO.** Not delegable. ### 19.2 How to open one On any refused case's detail screen you'll see a **Reconsideration** panel with a green "Open standard reconsideration" button. Regional Directors and the CEO additionally see a red "Initiate Hard-Case Override" button. Both open a modal asking for: - The specific indicator that triggered the refusal - The exception clause you're invoking - Justification (the *why*, in your words — this becomes part of the public register) ### 19.3 The 30-day time-lock Once opened, evidence upload runs for at least **30 calendar days** before sign-off is available. This is a tool policy (not statute) to prevent same-day rubber-stamping. The clock is enforced by `reconsideration_time_lock` in the statutory-durations registry. ### 19.4 Evidence Upload each required certified-design document or custodian letter individually via the "Upload evidence" button. Each file: - Caps at **25 MB** (split or compress bigger ones) - Is hashed (SHA-256) and the hash chained into the audit trail - Is tagged with a `kind` (design, custodian_release, etc.) — the tool tracks which required kinds remain outstanding Sign-off is **blocked** with `outcome='approved'` unless every required kind has at least one uploaded file (evidence-completeness gate). ### 19.5 Sign-off - **Standard track**: Regional Director signs first, then either the CEO personally OR a CEO-designated Deputy Executive Director. The DED cannot sign for a case in their own region (cross-region check). - **Hard-case track**: Regional Director countersigns; CEO signs personally — **no delegate**. Each sign-off requires an `outcome_reason` of at least 100 characters (no rubber stamps). ### 19.6 Sunset Hard-case override consents carry a **5-year sunset** (`hard_case_sunset` clock). At that date the consent expires and the case must be re-reviewed from scratch with fresh evidence — no automatic renewal. ### 19.7 Voice-note capture Every reconsideration evidence row now shows a **🎙 Voice note (30-60 s, officer narration)** button. This uses the browser's microphone (requires HTTPS + your permission) to capture a short narration that uploads as evidence with `kind='voice_note'`. The blob's SHA-256 chains into the audit trail alongside the text justification. Why this matters: a typed 500-character justification can be template-copied and pasted by any officer. A 30-second voice narration in the officer's own voice is a distinctive audit-chain signal that is hard to forge. If the case is ever contested, the voice recording is part of the record. ### 19.8 Discretionary reasoning that shouldn't become public record If as a signing officer (RD, CEO, or DED delegate) you have reasoning that supports a decision but that shouldn't itself appear on the public register or become RTI-eligible, do NOT put that reasoning into the `outcome_reason` field — that field is chained to the audit log character-by-character and is discoverable. Instead: 1. Type in `outcome_reason` only what the public record needs to see — the exception clause invoked, the certified-design evidence referenced, the statutory route. 2. Record the discretionary reasoning **out of band** in a signed internal letter to Authority Legal + the Board (deliberative privilege), filed in the case's paper folder. 3. On the sign-off form, note that "further discretionary reasoning is recorded in the internal case file per RD/CEO practice" — the audit chain then records that such reasoning exists without publishing its content. This protects both the officer's discretion and the audit chain's integrity. The tool intentionally does not offer a "hidden reasoning" form field because any field the tool captures becomes discoverable. ### 19.9 What this pathway does NOT do - No proponent self-service — the tool is officer-side only - No fee waiver — Act 1080 fees still apply - No override of international treaty obligations (Ramsar, UNESCO WHS) — the hard-case pathway routes to the treaty-body notification track, it does not skip it - No override of Lands Commission title clearance for institutional-land cases --- ## 20. Public Register Every conditional consent (from a reconsideration) and every hard-case-override outcome is published at **`/register`** — a plain HTML table plus JSON + CSV bulk downloads (`/api/register.json`, `/api/register.csv`) — in alignment with the **Right to Information Act, 2019 (Act 989)** proactive-disclosure obligations. ### 20.1 What's public Opened date · consent / rejection date · track (standard / hard-case) · status · trigger indicator · sector · district · sunset date. ### 20.2 What's not - **Project title** — anonymised because it typically embeds a private-citizen proponent's name (conservative PII default under RTI + Ghana DPA Act 843) - **Proponent identity** — same reason - **Officer identity** — kept in the underlying audit chain (SHA-256 hashed, retrievable on written RTI request), not in the public view ### 20.3 How outcomes enter the register - Hard-case cases are auto-listed at *creation* (public visibility of the track's use is part of the anti-corruption tripwire) - Standard-track cases enter on approval --- ## 21. Sector taxonomy (Act 1080 canonical + legacy aliases) The intake sector picker now offers the **9 Act 1080 canonical sectors** as primary choices, plus a "legacy" group for the 5 older tool-specific sectors kept for existing-case queryability. | Legacy sector (pick when re-opening old cases) | Routes to | Note | |---|---|---| | oil_and_gas | Energy | Petroleum sub-categories in Act 1080 §B | | real_estate | General Construction | Housing units in §D | | transport | *(no clean mapping — officer re-classifies)* | Facility → General Construction; equipment → Manufacturing | | waste_management | Manufacturing | Recycling categories C5 / C16 / C25 | | water_and_sanitation | *(no clean mapping — officer re-classifies)* | Facilities → General Construction; industrial WW → Manufacturing | New cases should pick from the Act 1080 canonical group. The tool resolves legacy values transparently for fee lookup, Impact Scale classification, and PDF citation. --- ## 22. Statutory durations at a glance Every clock the tool cites resolves through a single registry so the numbers stay consistent across the report PDF, the decision letter, the Reconsideration + Hard-Case screens, and the case-lifecycle scheduler. | Clock | Value | Reads | |---|---|---| | Screening determination | 25 working days | authority practice | | Scoping decision after TRC | 25 working days | needs verification | | EIS review (Authority) | 90 working days | needs verification | | EIS decision after TRC | 25 working days | authority practice | | Public hearing notice | 21 calendar days | authority practice | | **Appeal window** | **30 calendar days** | **L.I. 2504 Reg 45(1) (gazetted)** | | EMP initial submission | 18 months | authority practice | | EMP update cycle | 36 months | authority practice | | Permit — construction phase | 24 months | authority practice | | Permit — operation phase | 60 months | authority practice | | Reconsideration time-lock | 30 calendar days | tool policy | | Hard-case sunset | 5 years | tool policy | The PDF §4 Statutory Clocks table shows each clock with its verification badge (`statute` · `authority_practice` · `needs_verification` · `tool_policy`) so a reader can immediately see which numbers are gazetted-cited and which are practice-observed. No silent laundering. --- ## 23. Impact Scale advisory (how to read the amber callout) When a case declares a specific scale metric (hotel rooms, hospital beds, MW capacity, floor area, storage volume, livestock head, or land area) the tool classifies it against **Act 1080's Impact Scale bands** — Large / Medium / Small / Minor / Micro — and displays an amber advisory callout at the top of the on-screen report and in PDF §1. ### 23.1 What the callout says - The Impact Scale band the case falls into, and the metric that put it there - The activity-classification engine's binding verdict - A plain statement that the tool **has NOT downgraded** the verdict on this basis ### 23.2 Why not Act 1080 (2022) is a **revenue instrument** — it prices the assessment; it does not decide which assessment tier applies. The binding tier is set by **L.I. 2504 (2025) First / Second Schedule**. Under the prior gazetted rule (L.I. 1652 Schedule 2, 1999) many undertakings required a full EIA at surprisingly low thresholds — e.g. hotels of **40 rooms or more**. Unless L.I. 2504 expressly raised the threshold for the specific activity, the pre-migration verdict is binding. ### 23.3 If you want to downgrade Manually downgrade the tier only after verifying the L.I. 2504 threshold against the gazetted text and recording the verification source (page + edition) on the case file as an audit-trail note. The tool will not make this downgrade automatically. ### 23.4 Category A activities Mining, petroleum, primary industry, hospitals >100 beds, dams, and large infrastructure are **Category A** — a full EIA is mandatory regardless of scale. The Impact Scale band affects fee only, not tier. The callout says so explicitly for these cases. --- This manual is part of the pilot v0.1 release. Last updated 2026-07-18.