The GRTU has said that in general it sees the proposed changes as positive since no additional costs are envisaged and the proposal aims at minimising bureaucracy. “Another positive proposal being put forward is that the time window for objections will be limited to 30 days, this we believe should accelerate the process.”

GRTU added that it has however also a number of reservations, saying that it feels a number of elements “require clarification.”

“GRTU believes that the interests represented on the Planning Authority Board should be balanced. As such it is important that apart from eNGOs, there would also be members representing the interest of enterprises represented on the board.”

The Union said that it feels that an organisation such as GRTU should sit on the board “because it represents a wide range of interests and users of the Authority’s service. These range from interests in normal commercial development, specific groups for which there are specific policies as well as horizontal issues such as renewable energy and energy conservation.”

“It appears that the acts propose for the plans and policies to no longer be binding and the element of discretion is to become prevalent.” GRTU said that it feels this will drastically weaken the applicant position even when the case is taken to court.

“It is important that businesses have a certain amount of assurance in the policies they are applying under and the human element is limited as much as possible in decision taking to avoid discrimination and injustice.”

The MRA/EA merger requires more clarity, the Union said. “From information gathered during the public consultation meeting it appears that this new merged authority will be an Environment and Resources Authority (ERA). This however is not explained clearly in the acts.”

GRTU said that so far unfortunately, “having the functions of a regulator and promoter of renewable energy within the same authority has not reached the desired results. Year after year Malta classifies in the last positions with regards to renewable energy levels as a percentage of total energy and compared with fossil fuel derived energy, in all forms and shapes.”

It went on to say that, “to make matters worse, not only has Malta been regressive enough to negotiate and lower its E.U. 2020 targets, but this year Eurostat has even reported an increase in emissions in Malta by 2.5%, 1 of only 6 E.U. countries to report a rise.”

With supply and uptake of schemes repeatedly over-subscribed, it is clear the weak link is promotion of relatively new technologies such as Combined Heat and Power technology, heat pumps and Geo-thermal.

“Promotion of the renewable energy sector has to be done in cooperation and partnership with the private sector (through a PPP for example) as the sector that constantly seeks to introduce innovative technologies and comes up with innovative ideas.”

“When it comes to promotion, GRTU said, “we need to be proactive and stop hiding behind the bureaucratic structure. GRTU alone has been actively and successfully promoting the renewable energy sector for the last five years.”

GRTU noted that the possibility to obtain an Outline Permit is being re-introduced. Whilst the Union said it viewed this as “a positive move,” it has reservations regarding “the weight being given to such permits.”

GRTU said it believes that once an outline permit is issued, “this should become binding. The difference between the outline permit as proposed and a full development permit is just the fees paid to the PA.”

“Therefore,” it pointed out, “once an outline permit is issued, a permit upon which entrepreneurs might base important and costly decisions such as the acquisition of property, it should become irrevocable and the applicant should only be asked to pay the PA fees.”

“Regularisation is a very delicate issue and this should be implemented very carefully, through the most transparent and fairest methods.” GRTU stated that it believes that this should also be done “in full respect to our cultural heritage.”

It is being proposed, GRTU said, that the PA may ignore negative recommendations made by other authorities such as the MTA, the Cultural Heritage Superintendent, the Environmental Health Dept. and other entities.

The Union said that it would like clarification on what happens when one of these authorities objects to a permit which the PA approves of. “Will these authorities be obliged to issue their respective licenses for a business to operate?”

“Would the Cultural Heritage Superintendent, who has the power to stop a development even if this has the necessary permit by the PA be able to use this power? The GRTU asked.

In conclusion the Union said that, in article 72 (3) of the planning and development act, it is proposed that the Minister may override the PA if a project is deemed of ‘national interest.’ GRTU said that it is “not in agreement that a Minister should have such powers.”

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