MSA Public Consultation Feedback: Citizens Omnibus Initiative – reducing administrative burdens

 The Malta Sociological Association (MSA) notes the European Commission's initiative to identify opportunities for simplification, better implementation, and the reduction of unnecessary administrative burdens affecting citizens.

The MSA emphasizes that efforts to streamline legislation and public administration should be informed by robust Social Impact Assessment (SIA). Administrative simplification can have significant social consequences, both intended and unintended, particularly for vulnerable groups, social inclusion, access to services, participation, and social cohesion.

We therefore recommend the mainstreaming of Social Impact Assessment across relevant EU policy-making processes, in line with internationally recognised guidance such as the International Association for Impact Assessment (IAIA) principles and guidelines. Where the Commission identifies the need for further impact assessment in relation to this initiative, such assessment should explicitly include a Social Impact Assessment component, ensuring that proposed measures are evaluated not only in terms of efficiency and administrative burden reduction, but also in terms of their effects on citizens, communities, social equity, and quality of life.

A stronger social dimension in impact assessment would contribute to evidence-based, citizen-centred policy making and help ensure that simplification measures deliver tangible benefits while safeguarding social wellbeing across the European Union.

Malta Sociological Association – Feedback on the National Agricultural Policy 2027–2037

The Malta Sociological Association welcomes the development of a long-term National Agricultural Policy for 2027–2037, particularly its focus on sustainability, resilience, food security, agricultural land protection, generational renewal, and governance. The policy rightly recognises that agriculture is not only an economic activity but also a social, cultural, and environmental asset.

The Association recommends the mainstreaming of Social Impact Assessment (SIA) throughout the policy cycle, including policy design, implementation, monitoring, and evaluation. Agricultural policies have significant implications for rural communities, farmers' livelihoods, food security, social inclusion, intergenerational equity, community wellbeing, and quality of life. Systematic assessment of such impacts can help identify intended and unintended consequences, strengthen stakeholder participation, and support more evidence-based and sustainable decision-making.

The Association therefore proposes that social impacts be considered alongside economic and environmental considerations in future agricultural legislation, programmes, support schemes, and governance mechanisms arising from this policy. Such an approach would contribute to a more holistic and sustainable agricultural sector for Malta.

 The Malta Sociological Association welcomes the Gozo Climate Neutral Plan and its recognition of the importance of governance, coordination, accountability, and long-term planning in achieving climate neutrality.

The Association particularly notes the proposed Governance framework, including the establishment of a Carbon Control Committee tasked with monitoring emissions and assisting implementation. While these measures are important, the Malta Sociological Association believes that governance processes should also systematically integrate the analysis of social impacts arising from climate transition measures.

Climate neutrality policies have important social dimensions relating to quality of life, mobility, accessibility, affordability, employment, tourism, community well-being, social inequalities, and everyday practices. Measures concerning transport, land use, energy, waste, and tourism may generate both intended and unintended social consequences for different communities and social groups in Gozo.

The Malta Sociological Association therefore recommends that Social Impact Assessment (SIA) and ongoing social impact monitoring are mainstreamed within the governance structure of the Plan. This should include:

• the assessment of social impacts of proposed measures prior to implementation;

• ongoing monitoring of social outcomes during implementation;

• meaningful stakeholder and community participation;

• attention to social justice, inclusion, and equity in climate transition processes.

The Association believes that integrating social impact analysis into governance structures would strengthen evidence-based policymaking and contribute towards a more socially sustainable and inclusive climate transition for Gozo.

MSA's Public Consultation Feedback on Malta's Energy Shift: A Sustainable Power Transition

The Malta Sociological Association (MSA) welcomes the public consultation on Malta’s Energy Shift: A Sustainable Power Transition and recognises the importance of long-term planning toward a sustainable and secure energy system.

The MSA emphasises that energy transitions are not solely technical or economic processes, but also deeply social ones. Such transitions affect everyday life, communities, employment, inequalities, land use, governance, and quality of life, often generating both intended and unintended social consequences.

In this regard, the MSA strongly recommends the mainstreaming of Social Impact Assessment (SIA) throughout the formulation, implementation, monitoring, and review of this policy process, in line with previous MSA public consultation submissions.

As defined by the International Association for Impact Assessment, SIA involves analysing, monitoring, and managing the social consequences of policies, programmes, plans, and projects. The MSA believes that SIA should be embedded as an ongoing, participatory, interdisciplinary, and transparent process within Malta’s energy transition strategy.

The MSA therefore recommends:

* the integration of SIA from the earliest stages of policy and infrastructure planning;
* meaningful stakeholder and community participation throughout the process;
* assessment of impacts on households, workers, vulnerable groups, and local communities;
* ongoing monitoring of social indicators such as wellbeing, inequality, affordability, public health, and quality of life;
* greater recognition of the relationship between environmental, economic, and social sustainability.

The MSA believes that socially informed and evidence-based policymaking is essential for a just, democratic, and sustainable energy transition in Malta.  

Renewal of the current IPPC permit for AGV Non-Ferrous Malta Ltd

Here the Environment and Resources Authority is informing the public that AGV Non-Ferrous Malta Ltd. has applied for the renewal of IPPC permit application IP 0007/25 concerning the operation of a hazardous waste management facility in Kirkop, and is inviting public objections, representations, or comments as part of the consultation process under S.L. 549.77 Industrial Emissions Regulations.

In this context, the MSA strongly recommends the incorporation of Social Impact Assessment (SIA) as a core component of the permit renewal, also covering implementation, and ongoing monitoring.

The International Association for Impact Assessment defines Social Impact Assessment as “the processes of analysing, monitoring and managing the intended and unintended social consequences, both positive and negative, of planned interventions (policies, programs, plans, projects) and any social change processes invoked by those interventions”.

An SIA is an interdisciplinary process, and should employ various methods, both quantitative and qualitative. Social impact assessments should not be one-off exercises, but ongoing processes which engage with various stakeholders and which report back so as to ensure effective policy processes. 

Public Consultation Feedback: Renewal & Variation of the current IPPC permit for WEEE Recycle 4U Co. Ltd

The Malta Sociological Association (MSA) notes the public consultation IP 00004/25 - Renewal & Variation of the current IPPC permit for WEEE Recycle 4U Co. Ltd..

Here, the Environment and Resources Authority is informing the public that WEEE Recycle 4U Company Ltd. has applied for the renewal and variation of IPPC permit application IP 0004/25 concerning the operation of a hazardous waste management facility at the Ħal Far Industrial Estate, and is inviting public objections, representations, or comments as part of the consultation process under S.L. 549.77 Industrial Emissions Regulations.

In this context, the MSA strongly recommends the incorporation of Social Impact Assessment (SIA) as a core component of the permit renewal, also covering implementation, and ongoing monitoring.

The International Association for Impact Assessment defines Social Impact Assessment as “the processes of analysing, monitoring and managing the intended and unintended social consequences, both positive and negative, of planned interventions (policies, programs, plans, projects) and any social change processes invoked by those interventions”.

An SIA is an interdisciplinary process, and should employ various methods, both quantitative and qualitative. Social impact assessments should not be one-off exercises, but ongoing processes which engage with various stakeholders and which report back so as to ensure effective policy processes.

Public Consultation Feedback: European Health Data Space - dataset descriptions

 MSA gave feedback to the EU Public Consultation on European Health Data Space - dataset descriptions as follows:

Malta operates with a relatively integrated personal identity infrastructure, including universal personal identification numbers used across government departments throughout individuals’ lifetimes. This may facilitate cross-border data sharing and implementation of the European Health Data Space (EHDS). However, it also concentrates responsibility for data governance and public trust within a limited institutional ecosystem, potentially amplifying the effects of weaknesses in oversight or transparency.

Not all EU Member States use a single universal identifier across systems. Although the eIDAS framework establishes mutual recognition of national electronic identities, implementation remains uneven, reflecting different national infrastructures and approaches to identification. The proposed European Digital Identity Wallet may address some of these inconsistencies, but it is not a neutral tool.

The Wallet structures how individuals are recognised through predefined healthcare attributes shaped by institutional, technical, and regulatory priorities rather than lived realities. Identity is therefore not simply verified but constructed in ways that determine which aspects of a person become visible and actionable within cross-border healthcare. This may unintentionally privilege standardised and system-compatible profiles while marginalising individuals with incomplete, fragmented, or difficult-to-translate records, including those with limited engagement in digital systems. In this sense, the Wallet does not merely enable access but also shapes the conditions under which access becomes possible.

Questions also arise regarding who is responsible for simplifying, categorising, and interpreting healthcare data across systems. Whether these processes are driven primarily by software developers or medical experts has important implications for how healthcare information is understood and operationalised. Existing research shows that even medical definitions and diagnostic categories are influenced by broader social and institutional dynamics, raising concerns regarding equity, exclusion, and representation.

Article 5 allows healthcare providers to request additional information directly from individuals where healthcare attributes in the Wallet are incomplete. In practice, this means that data disclosure is not entirely optional, and participation in cross-border healthcare may depend on an individual’s ability to provide system-recognisable information. Furthermore, Article 3 states that each Member State shall determine the healthcare attributes used to verify identity, yet it remains unclear how vulnerable individuals or those with low digital literacy and limited digital access will be supported within this framework.

It is therefore recommended that EHDS implementation, including identity verification and cross-border data exchange, involve structured engagement with social scientists, patient groups, and civil society organisations. Greater transparency is also needed regarding how healthcare attributes are defined, standardised, translated, and interpreted across Member States, including who is responsible for these processes. Safeguards should be incorporated for individuals with limited digital access or literacy. Recognising that identity systems are not neutral is essential to avoid reproducing existing inequalities. Without such considerations, technically robust systems may fail to ensure socially equitable access to healthcare.