KA calls for pub­lic par­tic­i­pa­tion in cost-ben­e­fit anal­y­sis pro­cesses

Malta Independent - - Front Page -

The In­ter­dioce­san En­vi­ron­ment Com­mis­sion in Malta (KA), on yes­ter­day’s oc­ca­sion of World Town Plan­ning Day 2018, has pro­posed to the Euro­pean Com­mis­sion and Euro­pean Par­lia­ment that the pub­lic be in­volved in the prepa­ra­tion of cost-ben­e­fit-analy­ses (CBA).

The KA said it is tak­ing the ini­tia­tive in the knowl­edge that the Euro­pean Union is made up of com­mu­ni­ties liv­ing in ur­ban and ru­ral set­tings across all mem­ber states. The KA said it be­lieves that its pro­posal is rel­e­vant not only to Malta, but also to all EU mem­ber states, what­ever their size.

In a let­ter ad­dressed to Malta’s Euro­pean par­lia­men­tar­i­ans, the Com­mis­sion and the Par­lia­ment, the chair­per­son of Malta’s In­ter­dioce­san En­vi­ron­ment Com­mis­sion Mario Ca­men­zuli noted: “As you are well aware, the ‘CBA is an an­a­lyt­i­cal tool to be used to ap­praise an in­vest­ment de­ci­sion in or­der to as­sess the wel­fare change at­trib­ut­able to it and, in so do­ing, the con­tri­bu­tion to EU co­he­sion pol­icy ob­jec­tives. The pur­pose of the CBA is to fa­cil­i­tate a more ef­fi­cient al­lo­ca­tion of re­sources, demon­strat­ing the con­ve­nience for so­ci­ety of a par­tic­u­lar in­ter­ven­tion rather than pos­si­ble al­ter­na­tives.’”

Ca­men­zuli un­der­scores the fact that CBAs are re­quired as part of an ap­pli­ca­tion for the tap­ping of Euro­pean Union funds for the re­al­i­sa­tion of projects of a cer­tain size. The CBA re­quires that op­tions are stud­ied and then, de­pend­ing on the out­come of the stud­ies of such op­tions, the pre­ferred op­tion is cho­sen.

Ca­men­zuli said the KA’s con­cern is that, so far, “the CBA guide or the fund­ing re­quire­ments for projects that re­quire a CBA do not ask for a manda­tory pub­lic con­sul­ta­tion on the op­tions to be stud­ied at the ear­li­est stage of the CBA. Such op­tions are cho­sen by the project pro­po­nents, in many cases na­tional or lo­cal gov­ern­ments. More­over, there is no re­quire­ment that the CBA, in its en­tirety, is to be made avail­able to the pub­lic.”

As such, the KA in­vited the Euro­pean Com­mis­sion and the Euro­pean Par­lia­ment to make the nec­es­sary changes to the ap­pro­pri­ate le­gal in­stru­ments that reg­u­late fund­ing which re­quire a CBA so that:

1. There is pub­lic con­sul­ta­tion in the choice of op­tions to be stud­ied in the CBA;

2. In the CBA re­port that is sub­mit­ted to the Com­mis­sion as part of the ap­pli­ca­tion for fund­ing a project, an ad­den­dum list­ing the op­tions that were sub­mit­ted by the pub­lic as part of the pub­lic con­sul­ta­tion men­tioned in point 1 above is to be at­tached;

3. Apart from the de­tailed stud­ies of the op­tions that are cho­sen for con­sid­er­a­tion and from which the pre­ferred op­tion is cho­sen, the re­port has to pro­vide less-de­tailed fi­nan­cial, eco­nomic, so­cial and en­vi­ron­men­tal rea­sons jus­ti­fy­ing the re­jec­tion (if this would be the case) of the other op­tions sub­mit­ted by the pub­lic;

4. The CBA re­port in its en­tirety is to be made avail­able to the pub­lic and no so-called ‘com­mer­cial rea­sons’ can be in­voked by project pro­po­nents to jus­tify the non-pub­li­ca­tion of the CBA re­port.

The rea­sons for the KA’s pro­posal are the fol­low­ing:

• Projects that are funded by the EU and which re­quire a CBA are projects that have an im­pact on com­mu­ni­ties. Good sense re­quires that com­mu­ni­ties have a say at the very ini­tial stage of the con­sid­er­a­tion of such projects. Com­mu­ni­ties are nor­mally in­volved too late in the day when there is the ac­tual plan­ning ap­pli­ca­tion sub­mit­ted to the rel­e­vant plan­ning and/or en­vi­ron­men­tal au­thor­i­ties, and pub­lic con­sul­ta­tion is re­quired in ac­cor­dance with lo­cal plan­ning leg­is­la­tion and the EIA Di­rec­tive. In some cases, projects may also be based on devel­op­ment plans that would have be­come ob­so­lete given that they would not have been re­viewed for many years since their orig­i­nal adop­tion, and there­fore would not re­flect the com­mu­ni­ties’ cur­rent and fu­ture needs. Thus, timely pub­lic par­tic­i­pa­tion be­comes more im­por­tant.

• The timely pub­lic con­sul­ta­tion as sug­gested by the KA has the po­ten­tial to min­imise the risk that a more cost-ef­fec­tive, en­vi­ron­men­tally-sus­tain­able and in­no­va­tive op­tion would miss be­ing con­sid­ered for fund­ing while other less sus­tain­able op­tions would be ap­proved.

• Many ar­gue that such a pro­posal is yet an­other bu­reau­cratic hur­dle for eco­nomic devel­op­ment. On the con­trary, bu­reau­cracy which is at the ser­vice of com­mu­ni­ties is com­mend­able and should not be dis­missed. The avoid­ance of bu­reau­cracy may be an ar­gu­ment put for­ward by those who favour play­ers in cer­tain eco­nomic sec­tors and not in oth­ers, and who do not put trans­parency and a level play­ing field as pri­or­i­ties in their pol­icy-mak­ing.

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