However, FoE Malta is concerned that the exercise currently lacks the necessary depth and analysis to be considered a serious attempt to address the core problems in relation to climate change in Malta. Friends of the Earth is also glad to note that the recommendations leave the option open for having an effective climate change legislation.

As such, FoE has submitted various proposals in its review document. These include a proposal to have a Green Community Neighbourhood Watch which will cooperate within or in affiliation with Local Councils and consist of voluntary or paid staff providing training and informal education on environmental challenges and how to tackle them.

In its submission, FoE Malta also proposes that in order to meet the target reductions of greenhouse gas emissions, projected emissions from major projects should be taken into consideration by a Strategic e reviewEnvironmental Assessment (SEA) and carried out by the proponent.

Regrettably it is observed that the Committee set forth these recommendations with the clear intention to not discuss adaptation measures, thus failing to offer a holistic climate change strategy. In addition the consultation period was limited both in timeframe and in the content and appointment of the Committee. A true consultation would have included a call for interested and knowledge parties to state their interest in participation and representation on the committee before commencing this exercise. FoE Malta firmly believes that it is an asset to decision-making on the/a national climate change strategy and believes that NGOs should be represented on such decision-making bodies.

FoE Malta observed that there are no signs of monitoring being included in the strategy. Evaluation is a stronghold of scientific validity and should thus be an integral part of the strategy together with transparency and accountability. FoE Malta requests decisions based on sound knowledge and science to determine a strategy on climate change. A hunch or feeling is not to be supported within a scientific study. FoE Malta states that the limitations on analysing data available on Malta’s emissions must be addressed immediately.

FoE Malta believs that action on climate change issues should start without delay. Many recommendations, if followed, will start to be acted on by the government in late 2009. However, unless an operational climate change department is set up or the current units and individuals entrusted with following climate change policy are provided with the necessary financial and human resources, it will not be easy to start working on some of the recommendations in 2009.