Tourism: from Covid to Climate Change

The tourism lobby, through the MHRA (Malta Hotels and Restaurants Association), is once more breathing down the authorities’ neck. Some of their former employees have not returned, after the pandemic.  They are obviously referring to those employees of theirs who were shed off their payroll, as soon as the pandemic impacts started being felt.

After treating some of their employees like shit they are now asking for tax exemptions as a carrot to attract them back to fill the void created. Tax exemptions?  Difficult to qualify if you are employed on a zero-hour contract, hardly paying any tax at all!

The fact that an increasing number of employees are migrating from the tourism industry, is indicative that the employment conditions and the remuneration paid by the industry, at least, to some of its employees, is not worth it. If it were, former employees would come back on their own without the need to be enticed with tax exemptions.

Specifically, sections of the tourism industry are based on cheap labour: paying miserly hourly rates on zero-hour contracts. In addition to having reasonable rates of pay, it is imperative that zero-hour contracts are scrapped. That is to say a contract of employment must be for an agreed number of hours per week and not left at the absolute discretion of the employer. Greens in Malta have repeatedly advocated this step. A Labour government is apparently not interested.

Isn’t it about time that the tourism industry gets its act together? Government has over the years dedicated many resources to help the industry get on its feet. Various subsidies and favourable administrative decisions including planning policies designed to ride roughshod over the residential community are in place. Yet they want more.

At almost 3 million tourists in 2019, Malta is definitely close to a saturation point in the uptake of tourists it can handle. This has placed too large a strain on the country’s infrastructure.

Covid has clearly identified an Achilles heel. We need to learn a number of lessons. Foremost to reduce our dependence on tourism in order to ensure that the next time movement between countries is an issue, impacts on all are cushioned considerably. The next issue is round the corner. It is climate change.

Last week various initiatives were announced by the EU Commission in order that the target of carbon neutrality by 2050 is achieved. The Commission has identified a number of measures which could facilitate the achievement of an intermediate target of 55 per cent greenhouse gas emissions reduction by 2030 and beyond.

One such initiative is the environmental taxing of aviation fuel. Such an initiative is intended to internalise the environmental costs of such flights. This could result in either of two options: the payment of a carbon tax by those who use such flights or the use of alternative modes of transport thus avoiding altogether the payment of the tax.

On mainland Europe, use of trains is in many cases a suitable alternative which has considerably reduced environmental impacts. However, in our case we do not have practical alternatives to aviation. This will inevitably increase the costs of flights and consequently bring about a reduction in the number of tourists opting to visit Malta. Most of our competitors will be similarly impacted, but that is no consolation for the industry! Cheap plane fares could soon be history.

As announced by Minister Miriam Dalli, Malta expects that it is a “special case”. Most probably it will be successful in negotiating a reasonable transition, and/or some exceptions. In the long run, however, opposing outright such a measure goes against Malta’s long-term interests. Malta, like all island states, together with coastal settlements and communities, will have to face some of the worst impacts of climate change, that is sea-level rise. The climate, would not care less about our special case, or our economy. It will impact us just as forcefully. The climate is merciless.

It would be pertinent to remember that most of our tourism infrastructure lies along or within reach of the coast. This signifies that a sea-level rise could easily play havoc with such infrastructure. If substantial, a sea-level rise will also seriously impact our coastal communities, which are spread over quite a large area along the coast.

It is about time that we stop and think carefully. Tourism is at the crossroads. It needs to be subject to an overhaul: taking into consideration the covid lessons, and applying them to the climate change scenario which sooner or later we will have to face. This is the future of tourism, not tax exemptions.

published in The Malta Independent on Sunday : 25 July 2021

It-turiżmu wara l-pandemija

It-turiżmu kien wieħed mis-setturi li l-iktar intlaqat bħala riżultat tal-pandemija Covid-19. Tul is-snin in-numri tat-turisti li ġew iżuruna żdied kull meta tjiebet il-konnettività: min-naħa l-oħra hekk kif il-konnettività naqset u eventwalment waqfet kompletament, ġara bil-maqlub.

Iktar kmieni din il-ġimgħa bdew jaslu l-ewwel turisti fil-port u l-ajruport tagħna. Bil-mod qed terġa’ tiġi stabilita l-konnettività li twassal biex it-turiżmu jibda jirpilja bil-mod. Il-Ministru tat-Turiżmu Julia Farrugia-Portelli f’dawn il-ġranet ħabbret il-mira tal-Gvern: 700,000 turist sal-aħħar tas-sena. Iktar kmieni t-tmexxija tal-Ajruport Internazzjonali ta’ Malta kienet emfasizzat li jeħtieġ madwar sentejn biex il-wasla tal-passiġġiera tirkupra u naslu fejn konna qabel ma faqqgħet il-pandemija.

Jista’ t-turiżmu qatt jilħaq il-livelli ta’ qabel il-pandemija?

Jeżistu stimi diversi dwar il-kontribut tat-turiżmu lejn l-ekonomija. Stima minnhom tipponta lejn kontribut dirett ta’ 5 fil-mija tal-ekonomija. Imma, bħala riżultat tal-impatt fuq setturi oħra dan is-sehem jitla għal madwar 12 fil-mija. Barijiet, restoranti, ħwienet li jbiegħu bl-imnut, attivitajiet pubbliċi, l-industrija tad-divertiment u t-trasport (in partikolari l-kiri tal-karozzi) huma dipendenti fuq it-turiżmu. Setturi partikolari bħat-tagħlim tal-Ingliż u ċ-ċentri tal-għaddasa huma meqjusa bħala parti integrali mill-ekonomija turistika.

Intqal ħafna dwar l-impatt tal-pandemija fuq il-lukandi. Imma anke dawk li jipprovdu sodod turistiċi barra mil-lukandi ġarrew fuq spallejhom impatt sostanzjali avolja ftit li xejn issemmew fid-dibattitu konness mal-impatti tal-pandemija. Dan huwa settur li jinvolvi negozjanti żgħar u dawk li nirreferu għalihom bħala micro-businesses li kull wieħed minnhom jimpjega inqas minn għaxar persuni.

UNCTAD, l-Aġenzija tal-Ġnus Magħquda dwar il-Kummerċ u l-Iżvilupp, iktar kmieni din il-ġimgħa ħabbret li l-iġġammjar tat-turiżmu minħabba l-pandemija ser jiswa’ lill-industrija globali tat-turiżmu madwar $1.2 triljun . Din l-istima tista’ tirdoppja skond kif tiżviluppa t-tieni mewġa tal-pandemija.

Il-Ġamajka tista’ titlef madwar 11 fil-mija tal-Prodott Gross Domestiku, t-Tajlandja 9 fil-mija, l-Italja 5 fil-mija. Fl-Unjoni Ewropeja l-agħar impatti huma mal-kosta Mediterranja fejn l-ekonomija hi dipendenti ħafna fuq it-turiżmu. Minbarra Malta hemm l-Italja, l-Kroazja, is-Slovenja, Cipru u l-Greċja li kollha ntlaqtu sew. It-Turkija u t-Tunesija, parteċipanti Mediterranji fl-industrija turistika ukoll iġġammjaw, wara li gawdew minn żidiet sostanzjali fin-numri ta’ turisti tul is-snin.

Jagħmel sens li l-Gvern, f’dan il-waqt, permezz tal-Awtorità Maltija tat-Turiżmu, qiegħed jiffoka fuq li jġib lill-industrija tat-turiżmu lura fuq saqajha. Dan imma, mhux biżżejjed. Jeħtieġ li nibdew naħsbu dwar il-futur tal-industrija u dan billi neżaminaw fid-dettall dak li l-industrja teħtieġ li tiffaċċja fit-tul.

Fi tmiem is-sena li għaddiet, l-2019, ilħaqna in-numru ta’ 2.8 miljun turista iżuruna. Il-punt hu jekk dawn in-numri humiex sostenibbli. Dan hu argument ta’ dejjem li ilu għaddej sa minnmeta n-numri kienu ferm iżgħar. Id-dibattitu kien, u għandu jibqa’ jkun dwar jekk għandniex niffukaw iktar fuq il-kwalità milli fuq il-kwantità.

Il-miġja fostna tal-linji tal-ajru low-cost bħala parti essenzjali mill-politika tat-turiżmu illum tpoġġi emfasi ikbar fuq in-numri. Din hi għażla politika li saret u li teħtieġ li tkun eżaminata u analizzata fil-fond. L-impatti ekonomiċi għandhom jitqiesu fl-istess ħin mal-impatti ambjentali. Irridu niftakru kontinwament li t-turiżmu jiġġenera bosta impatti ambjentali.

Wasal iż-żmien li nirrealizzaw li d-dibattitu meħtieġ dwar il-futur tat-turiżmu jeħtieġ li jsir fl-isfond tal-Patt l-Aħdar: The Green Deal.

L-emissjonijiet tal-ajruplani ser ikollhom ikunu indirizzati fil-futur qarib. Hu inevitabbli li jiddaħħlu taxxi dwar dawn l-emissjonijiet (carbon taxes) fi żmien mhux il-bogħod. Jekk mhux ser jittieħdu passi immedjati dwar dawn l-emissjonijiet ser ikun ħafna iktar diffiċli, biex ma ngħidx impossibli, biex ikunu ndirizzati l-konklużjonijiet tas-Summit Klimatiku ta’ Pariġi tal-2015. Summit li Malta ħarġet tiftaħar li kienet wieħed mill-ewwel pajjiżi li rratifikatu. F’dak il-mument (jekk nibqgħu ma nieħdux passi) mhux biss it-turiżmu jaqla’ daqqa kbira oħra imma tkun il-kwalità tal-ħajja tagħna lkoll li tieħu daqqa l-isfel.

Il-gżejjer Maltin, bħall-parti l-kbira tal-gżejjer imxerrda mal-ibħra, ikunu minn tal-ewwel biex jaqilgħu ġo fihom l-impatti tat-tibdil fil-klima. Il-kosta tkun effettwat bl-għoli tal-livell tal-baħar. Tajjeb li niftakru li l-infrastruttura tat-turiżmu qegħda kważi kollha mal-kosta! Iktar ma ninjoraw dan il-fatt bażiku ikbar tkun id-daqqa li naqilgħu.

S’issa naħseb li kulħadd irrealizza kemm l-industrija tat-turiżmu hi waħda fraġli. Kull xokk li l-industrija issofri jista’ jwassal għal tnaqqis kbir fl-impiegi f’din l-industrija. It-turiżmu għadu staġjonali wisq u dan minnu innifsu jwassal għal kundizzjonijiet tax-xogħol ta’ natura prekarja.

Jeħtieġ li nippjanaw iżjed billi nħarsu il-bogħod u fuq medda twila ta’ żmien: naħsbu u nippjanaw sewwa dwar l-impatti soċjali, ambjentali u ekonomiċi ta’ kull deċiżjoni. Dan wara kollox hu l-proċess li jwassal għal żvilupp sostenibbli. Hu l-unika mod kif nistgħu nassiguraw li l-impatti negattivi tal-industrija tat-turiżmu nistgħu nindirizzawhom illum qabel għada.

Ippubblikat fuq Illum : il-Ħadd 5 ta’ Lulju 2020

Post-Covid Tourism

Tourism is understandably one of the hardest hit sectors as a result of the Covid-19 pandemic. Over the years, tourism numbers increased substantially as a result of an increased connectivity: the reverse happened the moment that connectivity was restricted or became practically inexistent.

Earlier this week saw the first arrivals at our air and seaports. Slowly, connectivity is being restored. It is expected that tourism will now start a slow recovery. Tourism Minister Julia Farrugia-Portelli is on record with a 700,000-tourist target for year end. Malta International Airport CEO had earlier opined that it will take at least two years to recover to pre-pandemic level airport movements.

Will tourism ever recover to the pre-pandemic levels?

There are various estimates of the contribution of tourism to the economy. One such estimate points at a direct contribution of around 5 percent of our economy. However, as a result of its impacts on other sectors the overall contribution rises to around 12 percent. Bars, restaurants, retail trade, events, entertainment and transport (in particular car hire), are heavily dependent on tourism. Specific sectors such as the English language school sector as well as diving are important sectors in the tourism economy.

Much has been stated on the impact of the pandemic on the hotel industry. The providers of non-hotel beds, however, have also been heavily impacted by the pandemic, but they have not featured much in the post-Covid-19 debate. This is a sector which involves a number of small-scale investors and micro-businesses each employing less than ten employees.

UNCTAD, the UN Trade and Development Agency, earlier this week stated that the four-month standstill of the tourism industry due to the pandemic Covid-19 could cost the industry around $1.2 trillion. This estimated cost could more than double, depending on the severity and spread of a second wave of the pandemic.

Jamaica could lose as much as 11 percent of its GDP, Thailand 9 percent, Italy 5 percent. In the EU, the worst impacts are along the Mediterranean coast where the economy is heavily dependent on tourism. In addition to Malta, Italy, Croatia, Slovenia, Cyprus and Greece are also heavily impacted. Turkey and Tunisia, Mediterranean players in the tourism industry have also been almost at a standstill, after experiencing a substantial expansion of their tourism industry throughout the years.

It is understandable that government through the Malta Tourism Authority is currently focused on getting tourism back on its feet. This is however not enough. We must start discussing a long-term view of the tourism industry.

At the end of 2019 the 2.8 million mark of tourists visiting the Maltese islands had been attained. The point at issue is whether this is sustainable in the long-term. This has been a perennial issue in tourism politics since the days when the numbers were much lower. The debate was and should be whether we should focus more on quality than on quantity.

The advent of low-cost carriers as an essential part of the tourism equation places more emphasis on numbers than on quality. It is a choice which may need to be analysed and revisited. Economic impacts have to be viewed concurrently with environmental impacts. We must remember that tourism has a considerable environmental impact. It is about time that the tourism debate is carried out within the parameters of the Green Deal.

Aeroplane emissions will at some point in time in the near future have to be addressed. Carbon taxes will sooner or later come into play. Unless they are addressed immediately it will be more difficult, if not practically impossible, to address the Paris Climate Change conclusions to which Malta has adhered. At that point it will not be just the tourism industry but our whole lifestyle which will be in for the chop.

The Maltese archipelago, like all islands, will bear the brunt of climate change impacts. The coastline will be severely hit by a sea level rise. It may be pertinent to remember that the coast houses practically all of the tourism infrastructure. The longer we ignore this basic fact, the more severe will the impacts be.

By now all of us are aware that Tourism is a very volatile industry: any shock will result in mass redundancies. Tourism is currently way too seasonal, and consequently it only serves to create precarious working conditions.

It is the time to plan ahead: thinking carefully of the social, environmental and economic impacts of all decisions. This is what sustainable development is, after all, about. It is the only way to ensure that the negative impacts of the tourism industry are addressed by us sooner rather than later.

 

published in The Malta Independent on Sunday : 5 July 2020

Time to realign actions with words

On Budget Day next week, the government ought to explain the extent to which its actions are consistent with its political programme read during Parliament’s inauguration by the President in 2008.

It would be pertinent to remember that the President had then stated: “The government’s plans and actions are to be underpinned by the notion of sustainable development of the economy, of society and of the environment. When making decisions today, serious consideration will be given to the generations of tomorrow.” Sustainable development, the President had informed Parliament, was a main goal of this government.

Well, since then, and for a number of months before that too, the National Commission for Sustainable Development has not met. It has been dormant for three years. Not a good sign for a government that considers it should direct itself onto the sustainability path. In addition, targets and objectives of the National Sustainable Development Strategy have been ignored.

Alternattiva Demokratika considers that next week’s Budget could be the opportunity for the government to realign its actions with its declarations.

Cabinet approved a national strategy for sustainable development towards the end of 2007 after extensive consultations with civil society carried out by the NCSD. This strategy laid down a number of specific actions for government ministries to follow. These have been honoured in the breach.

The selected method for implementation of the strategy is through action plans drawn up by ministries. Within 18 months from the strategy’s adoption, that is by mid-2009, ministries were required to prepare their action plans to implement the strategy. They are already 12 months late.

This has occurred because, at least to date, the government has considered the NCSD as a formality.

The mere fact that the Prime Minister, who ex-ufficio is chairman of the NCSD, hardly ever attended commission meetings since 2004 is, in itself, the clearest indication of the mismatch between declarations and actions, the end result being the prevailing state of affairs.

The NSDS identified 20 priority areas: environment (eight areas), economy (three areas), society (four areas), cross-cutting issues (three areas) and implementation (two areas).

Priority area 19, for example, established that, by 2008, that is 24 months ago, a permanent structure properly staffed and funded had to be in place to monitor and review the strategy’s implementation. A role for major stakeholders was also envisaged in order to “critically evaluate progress relating to the strategy”.

Priority area 17 identified the year 2008 as the target for the drawing up of a strategy “to enhance the use of economic instruments such as charges, taxes, subsidies, deposit refund schemes and trading schemes” in order to apply the polluter-pays principle and to promote sustainable development in Malta. Instead of drawing up this strategy, the government drew up a national environment policy issues paper and queried whether and to what extent the public considers it advisable “to move towards a taxation system that penalises pollution rather than jobs”.

To add further to the indecision, the pre-Budget document published in July declared the government was considering introducing a carbon tax. It further advocates a tax shifting mechanism whereby the taxes collected through this carbon tax are offset by the reduction of taxes that “penalise jobs”. Has a study analysing the impacts of this proposal been carried out? While reducing carbon emissions would be positive, what analysis has been made of the economic and the social impacts of such a measure?

On behalf of AD I have sought an answer to this question. In terms of the Freedom of Access to Information on the Environment Regulations 2005 I requested the release of studies commissioned by the Ministry of Finance.

The reply I received last Monday is another proof of the amateurism prevalent at policy formation level. The reply drew my attention to a number of academic journals dealing with tax shifting. I was further informed that the issue (of tax shifting) is being discussed in the Green Economy Working Group, which is expected to present its initial findings to the government by the end of 2010. These findings, it was stated, will be subject to public consultation in early 2011.

While consultation is always to be viewed positively, my point is that the announcement in the pre-Budget document that carbon taxation and tax shifting are being considered was premature in view of the fact that no studies have been concluded to date. Not even preliminary ones.

It seems the government has not yet learned its lessons from the introduction of eco contribution.

Serious policy formation and announcements have to be accompanied by studies detailing impacts of the proposals. Premature policy declarations serve no purpose except to mislead.

Ending all this by realigning actions with words would be a good first step. Our future depends on it.

Published in The Times, October 23, 2010

Reflections on an Environment Policy

The current debate on what should form part of a National Environment Policy is a healthy exercise. It is focusing not only on the different aspirations of each citizen but also on the role of each one of the towns and villages which together constitute this country.

The environmental issues we face are the result of the manner we organise our lives both individually and as a community. In fact it can be safely stated that the manner in which economic activity has been organised throughout time has created different environmental and social impacts.

The exercise at this point in time is hence the clear identification of these impacts and subsequently seeking the best manner in which they can be tackled. This is done on two fronts: firstly through the formulation of an environment policy and secondly by integrating this environment policy with economic and social policy within the National Strategy for Sustainable Development (NSSD).

The NSSD has already been formulated and approved by Cabinet almost three years ago after a long process of consultation. It established targets and objectives which have unfortunately been ignored by the same Government which has approved them. This necessarily leads to the conclusion that these exercises can be a waste of time as their only purpose seems to be an exercise to prove that the new hands on deck can do things in a better way than those they have replaced. 

The National Environment Policy Issues Paper identifies a number of areas which are to be tackled but excludes a number of important ones. What is in my view objectionable and bordering on the insulting is the ignoring by the Issues Paper of the NSSD. It also ignores matters which have been tackled by the NSSD as well as the specific targets identified. This the NSSD did after extensive consultation with civil society, which the Issues Paper promises to go through again.

 

Eco-taxation

One such case refers to the use of economic instruments to attain environmental objectives. The Issues Paper queries whether and to what extent there is agreement  with the use of such instruments to further environmental objectives. Simultaneously with the publication of the Issues Paper, Finance Minister Tonio Fenech through the pre-budget document was lauding the idea of introducing a carbon tax and the possible utilisation of the proceeds to affect a tax shift. This is in the spirit of the former EU Commission President  (French Socialist) Jacques Delors’ 1993 EU White Paper entitled “On growth, competitiveness and employment. The challenges and ways forward into the 21^st century”.

So whilst the Environment Ministry is requesting our opinion on the use of eco-taxation (and other instruments) it seems that the Finance Ministry is dead-set to proceed.  Do these two Ministries form part of the same government? 

Both the Environment Ministry and the Finance Ministry would do well to go back in time to the debate on the introduction of the eco-contribution (2003-05) where they could identify a number of issues raised by civil society.

Should fiscal objectives be the purpose of environmental taxation or would it rather be environmental improvement? All over the globe governments declare that their aim in applying eco-taxation is environmental improvement. Yet they resist transferring political responsibility for environmental taxation from the Finance Ministry to the Environment Ministry. Such a move would lend credence to statements on the environmental objectives of eco-taxation and would ensure that the design of specific measures is more in line with encouraging changes in behaviour. Retaining political responsibility for environmental taxation at the Finance Ministry on the other hand signifies that the objective is to tax behaviour but not  to change it. This reluctance is generally reflected in the manner  in which eco-taxes are designed. Fiscal policy makers pay attention to the fact that changing behaviour would mean drying up a source of revenue. Hence eco-taxes designed for fiscal objectives are intended not to affect the elasticity of demand. This is done by selecting items in respect of which there are no alternatives and thus irrespective of tax added to the price there is no alternative to purchasing the product or service. The eco-contribution exercise clearly illustrates this argument.

 

Environmental nuisance 

The Issues Paper has failed to project an understanding that environmental issues can be most effectively tackled at a micro-level. In fact the Issues Paper adopts an exclusively macro approach and does not give any weight to the real life issues. Issues of environmental nuisance are the ones which the man in the street feels strongly about. These include primarily noise, air quality and odour nuisance caused by neighbours in residential areas. They could range from an air conditioner fixed below your bedroom window to a neighbour’s fireplace chimney spewing smoke right into your living room or a bakery belching black smoke onto your washing line. Or the newly opened restaurant or snack bar in a transformed ground floor flat whose operator wouldn’t care less about where the odours from his kitchen end up.    

Information

Access to environmental information is an important aspect of environment policy. Yet the drafters of the Issues Paper ignored it. The environmental information aspects of the Åarhus Convention have been incorporated into Maltese legislation as a direct result of Malta’s EU accession. This legislation provides a mechanism through which the citizen requests the release of information which up till then would be withheld by the authorities. This is a very primitive form of governance. The state should release information without having its hand forced to do it. This is the minimum required in an age of transparency and accountability. 

Policy proposals and other initiatives must be buttressed by studies which not only justify the proposal or initiative but which also identify the resulting impacts and the manner in which these can be addressed. Studies must be published at an early stage and not in the final stages of a discussion. Otherwise the public debate cannot be fruitful.

Transparency and accountability

Transparency and accountability are not only duties of the state. They are also a responsibility of private enterprise.  Corporate Social Responsibility (CSR) reporting is one way in which private enterprise informs the public on its activities. It is a function as important as financial reporting. Financial reporting having been accepted by society for quite a long time as a reporting requirement.

In Malta currently two companies publish a CSR report. Vodafone (Malta) and Bank of Valletta (BOV) have already published two editions of their CSR report. There has been considerable improvement in the information made available by Vodafone (Malta) in its second report, but BOV’s reporting  can be substantially improved.

The environment policy should identify the type of organisations that should have the duty to report publicly and on a regular basis on their environmental and other impacts. By organisations I understand not just industry and business but also public corporations, government departments and local authorities. A reasonable first step would be for companies quoted on the stock exchange to take the lead followed by public bodies such as Enemalta, Water Services Corporation, Heritage Malta and Air Malta.

CSR reporting should be guided by international standards such as the Global Reporting Initiative G3 guidelines and should be subject to auditing in order to verify that the statements made reflect what the organisation is really up to. 

Alternattiva Demokratika, AD, the Green Party in Malta has earlier this month published a document in reply to the National Environment Policy Issues Paper which lists and discusses the areas missed out by the said Issues Paper.  In addition to focusing on the urgent need to implement the NSSD, environment information, environmental nuisance and environment information it also points out the need to tackle the uptake of environmental management systems such as ISO 14001 and the Eco-Management and Audit Scheme (EMAS) Regulations of the European Union, light pollution, contaminated land, environmental and sustainability planning at a locality level better known as Local Agenda 21,  the role of civil society and environmental NGOs in environment policy and environment  research.  

We hope that when the environment policy is drafted it will include the widest possible list of issues and will tackle them in an holistic manner keeping in mind the parameters established in the National Sustainable Development Strategy.                 

Alternattiva Demokratika considers that environment policy is one of several instruments through which improvement in the quality of life can be attained. Protecting the environment signifies that we better our quality of life. It also signifies that each one of us acts in a responsible manner. However primarily it must be government which leading the way should act in an appropriate manner in order that it leads by example.

 published in

The Independent on Sunday, October 17, 2010, Environment Supplement

AD on Government’s Environment Policy

During a press conference in Valletta, Michael Briguglio, AD Chairperson, said: ‘Alternattiva Demokratika is presenting its reactions to Government’s proposed environment policy. In a nutshell we believe that it would have been wiser if Government implemented the recommendations of the National Commission for Sustainable Development, which have been ignored by Government for over two years. A holistic and effective environment policy should be based on the concept of sustainable development through which environmental, social and economic considerations are given due importance in order to improve the quality of life of people and to protect species. This is precisely what is being proposed in our policy paper, which covers various areas’.
 
Carmel Cacopardo, AD Spokesman on Sustainable Development and Local Government said that AD’s detailed reaction to the National Environment Policy Issues Paper was presented to Parliamentary Secretary Mario de Marco yesterday during a cordial meeting.
 
AD, said Cacopardo, is of the opinion that environment policy and environment measures have to be buttressed by studies which analyse the economic, social and environmental impacts of the proposals. Environmental research is absent from the list of issues dealt with by the document government published for public discussion. This is not a surprise for AD as acting without analysing impacts a priori is this government’s preferred method of action as has already happened when the eco-contribution legislation was introduced.
 
Government has just announced that it is toying with the idea of introducing tax shifting by reducing taxes on labour and introducing a carbon tax. This proposal communicated in the pre-budget document is scant on details such that it is not at all clear what Government is considering. In addition no studies indicating targets, methods and impacts has been published. Nor is it known whether in fact any studies have been carried out. It is for this reason that AD has 15 days ago requested the release of studies on the “carbon tax” proposal in terms of the provisions of LN 116 of 2005 (Freedom of Access to Information on the Environment Regulations).
 
The use of economic instruments for environmental improvement should be the responsibility of the Ministry of the Environment and not of the Ministry of Finance. This would ensure that environmental objectives and not fiscal ones are the primary objectives when such instruments are used
 
The Issues Paper added Cacopardo does not consider a number of important areas of action such as : Light Pollution, Environmental Impacts of Organisations, CSR, environmental nuisance, land contamination, the role of civil society and eNGOs in environment policy formulation, access to environment information and environment research.
            
AD considers that in view of the large number of vacant properties a moratorium on large scale residential development is long overdue. The regulating of funding of political parties would also ease the pressure of the building development lobby on politicians.  
 
Press here to download full AD paper

Environment Policy and the Budget

The National Environment Policy Issues Paper, launched by the Parliamentary Secretary for the Environment, Mario de Marco, on July 27 requested the views of the public on a move towards a taxation system that “penalises pollution rather than jobs”.

When launching the 2011 pre-Budget document on the same day, Finance Minister Tonio Fenech was more clear as to the government’s intentions. Under the heading Tax Shifting, he proposed the shifting of taxes from economic goods to economic bads. The pre-Budget document goes on to say: “In order to incentivise the creation of work by making labour less costly we are proposing the lowering of government-induced employee costs as well as corporate and income taxation.” The pre-Budget document then praises the merits of a carbon tax as a fiscal tool.

It seems that both the minister and the parliamentary secretary have forgotten that taxation does not penalise jobs. It is an instrument for the attainment of social solidarity. That is what the post-1977 Nationalist Party I remember was in favour of. It seems that time has changed the PN. It cannot be anymore described as being “un partito di centro che guarda a sinistra” (a party of the centre that looks to the left), as the old guard, quoting Alcide de Gasperi, justifiably boasted.

The drafters of the documents launched could have consulted the Cabinet-approved National Sustainable Development Strategy for the Maltese Islands (page 59), which established 2008 for the conclusion of a strategy on environmental taxation. The year 2008 is 32 months away and the strategy on the use of economic instruments to regulate environmental impacts is still not in place. Instead of asking for views of the public they should have drafted the strategy that has been promised but not delivered. It could be a useful guide for the finance minister.

At issue in this debate on tax shifting are points already emphasised during the eco-contribution legislation debate in 2004/05. Which ministry will be in the driving seat of environment taxation policy: Finance or the environment? Will the primary objectives of environment taxation be environmental or fiscal?

The strategy to be adopted and, thus, the specific proposals to be brought forward will depend on whether fiscal policy is used to regulate and reduce environmental impacts or whether the environment will be used to compensate for shortfalls in tax revenue.

After 17 years, the government has woken up to the proposals of a Jacques Delors EU White Paper in 1993 on growth, competitiveness and employment [COM (93) 700 final] who had the argued in favour of taxing environmental impacts and resource use.

In its 2008 electoral manifesto, the PN promised it will reduce income tax in the higher bands. It is now seeking ways to deliver without subjecting the Exchequer to further problems. It is very unfortunate that an inappropriate tool was selected. As a result of the tax shifting proposal, a tax, which is socially progressive (income tax) will be partially substituted with a carbon tax that, viewed on its own, can be socially regressive. The proposal aims to reduce taxation from a band which is paid mostly by companies and those who have a substantial income. To compensate for the resulting shortfall, it will spread the tax-load on everyone without discrimination, irrespective of their means.

Once the government decided on the reduction of the higher band income tax, I understand that it did not have much of a choice. In order to ensure a regular flow of income, which would have to substitute a reduction of the forfeited income tax, it had to select a subject in respect of which (at least, in the short term) demand is largely inelastic to tax-induced price changes.

It would be interesting if any studies on the impacts of the pre-Budget tax-shifting proposal are available. Such studies should clearly demonstrate the two basic flaws of the proposal: first it’s being socially regressive and, secondly, it’s exploiting of the environment as a tax revenue generator without ensuring environmental improvement as a primary objective.

If environmental improvement was a primary objective, the projected tax revenues would not be generated as they would be reduced gradually, in line with environmental improvement.

A carbon tax would force business and industry to address their environmental impacts. However, the impacts of a carbon tax on SMEs and households have to be assessed more carefully before policy declarations are made in view of the limited size of the former and the lack of resources of both. Given that most of Malta’s business is in the SME sector, matters should first be studied in their proper perspective before declarations are made or decisions taken.

There are various alternatives to the government’s proposals. Each one of them must however be tested through studies to ensure that the social and environmental impacts of fiscal policy are either positive or else substantially mitigated.

Studies made must be available at this stage. Otherwise, the discussions on both the National Environment Policy and the pre-Budget document would be just kite flying exercises.

 

published in The Times Saturday, September 4, 2010