Thursday, June 25, 2020

Feedback to public consultation - Maltese Gas Price Methodology

With reference to the following public consultation, https://meae.gov.mt/en/Public_Consultations/MEW/Pages/Consultations/MalteseGasTransmissionSystemReferencePriceMethodologyinaccordancewithCommissionRegulationEU2017460of16March2017.aspx

I sent the following to the Ministry for Energy and Water Management (Melita TransGas Company Ltd.)

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With reference to the initiative above, I am hereby appealing to the Ministry for Energy and Water Management (Melita TransGas Company Ltd) to employ a Social Impact Assessment (SIA) process, which is in accordance with international standards for example those set by the International Association for Impact Assessment, which is accessible from this link:

A social impact assessment reviews the social effects of development and social change, both intended and not.

The International Association for Impact Assessment defines an SIA as the process of analysing, monitoring and managing the intended and unintended social consequences, both positive and negative, of planned interventions and any social change processes invoked by those interventions.

Such changes may range from natural disasters to population growth and from policy interventions to singular development projects. Consequently, SIAs investigate the effects on people’s everyday lives in terms of culture, politics, community, health, well-being, aspirations, needs, rights and responsibilities, to name a few.  They provide data for policymaking, which is based on evidence.

Social impacts under assessment should include all those things relevant to people’s everyday life. This may include one’s culture, community, political context, environment, health, well-being, personal and property rights as well as fears and aspirations.

Social impact assessments can help verify the consequences and impacts of policy proposals in relation to the communities involved. Hence, a basic starting point for such assessments should be the compilation of a community profile. A social impact assessment that does not understand the society in question is practically worthless.

Various methods, both quantitative and qualitative could be used within social impact assessments. The former refers to generalisable data especially through numbers, while the latter produce in-depth data on matters.

Research methods in SIAs may therefore include surveys of concerned populations who are asked questions on their perceptions of the change in question. Ethnographic methods may involve a deeper look into everyday practices of people, while elite interviews may verify the advice, concerns and interpretations of persons who are experts or who have experience in the respective field under analysis.

Methods may also involve the analysis of discourse on the subject in question, for example by looking at what is being pronounced in the public sphere, whether by the public, civil society, political actors, the media and the like.

SIAs should involve the participation of different stakeholders, ideally through mixed research methods.

Some other factors which should be included in social impact assessments include the consideration of reasonable alternatives to development proposals as well as comparative analysis of similar development proposals and related good or bad practices.

Analytic indicators should be provided and the entire process should be subject to peer review by independent experts in the field.

Social impact assessments should not be one-off exercises which are rubber-stamped by authorities without any sense of critical engagement. To the contrary, they should be ongoing processes which engage with various stakeholders and which report back so as to ensure effective policy processes. They should also use complementary research methods so as to ensure reliable and valid data.

Recommendations and mitigation measures could therefore be in place, and these would be based on social-scientific evidence.

It is also important that SIAs are peer-reviewed. This means that if a study is being carried out by a team of social scientists, this should be scrutinised by other independent social scientists. This could help identify shortcomings, conflicts and possible improvements to the same SIA.

Dr Michael Briguglio
Sociologist