Category: Archive – 2008

P-PHENYLENEDIAMINE (PPD) and related compounds are used in permanent hair dyes, and more than two thirds of hair dyes currently used contain PPD. PPD is a well-known and extremely potent skin sensitizer. Scientific reporting and clinical diagnosis in patients with dermatitis from hair dyes have focused on PPD as the main skin sensitizer.

PPD is currently regulated by the Cosmetics Directive Annex III, Part 1 under entry 8 on the "List of substances which cosmetic products must not contain except subject to restrictions and conditions laid down". The present restriction is 6% of PPD calculated as free base in the finished cosmetic products.

In the updated safety file submitted in the framework of the re-assessment strategy the cosmetics industry defends the use of PPD in oxidative hair dye products at a maximum concentration of 2.0% in the formulation applied to hair.

TOLUENE-2,5-DIAMINE (PTD)

Apparently, aside from PPD, it is mostly the use of PTD that causes skin allergies by hair dyes in the population. It is almost as potent as PPD and it occurs in up to 70-90% of oxidising hair dye products on the EU market.

PTD is currently regulated by the Cosmetics Directive, Annex III, Part 1 under entry 9. The present restriction is 10% of PTD calculated as free base in the finished cosmetic products. In the updated safety file submitted in the framework of the re-assessment strategy the cosmetics industry defends the use of PTD and its sulfate salt in oxidative hair dye products at a concentration of 4.0% in the formulation applied to hair.

MEASURES ENVISAGED CONCERNING THE REGULATION OF PPD AND PTD

Taking into consideration that the risk assessment of additional data on PPD and PTD and final opinions made might still require a considerable amount of time, the Commission intends, as a precautionary measure of reducing the risk of allergies to hair dye products among consumers, to decrease the maximum authorized concentrations of PPD and PTD to the levels which are defended by the cosmetics industry in their submitted safety files.

 GRTU President – Paul Abela's Speech

• Matters discussed:
• The Rent Reform
• The MEPA Reform
• Policies regarding Localities and Reform of  the Local Councils
• Schemes of the betterment of the Environment

Professor Arnold Cassola, first of all I congratulate you for the new responsibilities you are undertaking and I welcome you to GRTU.

The GRTU and Alternattiva Demokratika do not keep frequent contact, but this does not mean that we do not believe in the importance of political parties other than the two major political forces in our country's democratic system.  On the contrary, we believe that it is very important that others voice the opinion of minor groups, especially when the two major parties agree on particular issues and their common ground is really fear of losing their voters.  The GRTU is not a political party and we do not have any political ties, but we are also a large national force that represents important sectors of the Maltese economy.  Unfortunately, although the self-employed and small and medium enterprise owners represent more than 90% of Maltese and Gozitan enterprises, and between them they are the largest employers in Malta, as voters they are regarded as a minor force, though an important one.

The two large parties have a long history of empty promises that are easily forgotten after the self-employed and business owners have cast their electoral vote.  This does not mean that the two parties have not worked for the self-employed and the small businesses, indeed this was done always at the instigation of the GRTU.  And GRTU is vigilant to ensure that what has been achieved is not easily discarded by those in power.

Currently, we are going through a rough period, regarding matters affecting the sectors we represent.  A lot was said in the recent electoral campaign about how the self-employed and small business owners are at the heart of politicians' interests.  However, from the first few days of this legislature things already started going wrong.  In the GRTU, we are currently keeping back but if the attitude of the two large parties remains one of keeping mute on important issues with the result that everything seems to go when the interests of small businesses are involved, GRTU's anger will have to become manifest.

I will start immediately on the issue regarding the Reform of Rent of Commercial Property.  This is the property from which the work and earnings of many of our members emerge.  Is it possible that none of you, neither the Alternattiva Demokratika, nor the Nationalist and Labour parties, has thought of looking up the history?  Is it possible that nobody has noticed that in most democratic countries, the issue of rent of residential property is legislated separately from that of rent of property used commercially for enterprises? Is it possible that none of you were scandalized as we were that the Government inserted in the White Paper, which primarily deals with the reform of rented residential property just two pages and the handful of proposals that refer to rented commercial properties that affect thousands of business owners, their families and their employees?  Does this mean that nobody cares about the tenants, whose income depend on the property from which they work, and that the issue of their security of tenure is of no relevance to the political party currently in Government?  And what about the Party in Opposition, and the Alternattiva Demokratika?  Is this their attitude too?

The proposals of the Government included in the White Paper are not based on any statistical evidence.  Does the Government have no statistics that show how many businesses are going to be affected?  Is this the state of affairs we have in our country today?  Does it mean that whoever has the majority in parliament even if obtained by a few hundred votes can proceed regardless of the impact of its proposals?

Is it possible that none of today's politicians has taken the initiative to understand that the laws regarding rent of commercial property are an important instrument for the safeguarding of jobs in small enterprises, of the self-employed business owners, their families as well as their employees?  Other countries, especially France and Austria, give great value to the livelihood of enterprise owners in rented properties.  Why is Malta taking a different approach?  Were the promises that the self-employed and the small business owners are at the heart of Maltese politicians, empty?

We have already had the opportunity to express our anger against the unprofessional way the Government is addressing this issue to the Prime Minister, the Honourable Dr. Lawrence Gonzi, to the Minister for Social Policy, the Honourable John Dalli and the General Secretary of the Nationalist Party, Dr. Paul Borg Olivier.  It is absolutely unacceptable for the GRTU that fundamental rights acquired by our predecessors in the GRTU during the 60 year existence of the GRTU existence are now to be washed away as if it they were nothing just because the Nationalist Party has that safeguarding small business owners' rights is no longer relevant and defending major landowners rights is of greater importance to the PM while for the Labour Party silence and non-commitment has suddenly become a major policy stance.

We believe that what was done in 1995 was already faulty as the Government then abandoned many small business owners hiding behind the turmoil of what was for enterprise a very bad year.  The Party in Government marched forward in 1995 even though it paid a high political price afterwards.  It is clear that now, fresh after an electoral victory, the Government is going to disregard small business owners with the hope that by the next election they will have forgotten all the punishment Government is now proposing for many of them.

An enterprise owner who has rented property has much of his wealth tied up in that enterprise.  How can it be that the property owner is now being given the right to kick him out of the premises and effectively requisition his business without compensation at the termination of the lease contract?  We are speaking clearly by saying that what is proposed in the White Paper allows the property owner not only to take back the property but also to take everything else.  Once the tenants are kicked out the property owner can effectively open the business for himself.  Malta has never seen a proposal involving such large theft as this.  How can it be that suddenly the owner's right for seizure has become so sacred?  Did this right become so sacred when the European Union recognized that the small businesses are the backbone of the European Economy and when a Small Business Act is being drawn up so that European Politicians try to safeguard the small enterprises?  I ask, who are the owners who have a great deal of property rented before 1995?  May they show their statistics so that we can truly see who is putting the Nationalist Party into Government with their proposal?  What is the reason behind all this hurry?  Why did they come up with this proposal in the middle of the summer, when everybody's interests are elsewhere?  Who, in Malta, is conscious of the fact that the consultation period closes a few days after Santa Marija and that the Government already has the law almost fully planned out?  Is this how they are going to lead democracy, with dictatorship of the majority walking over the rights of the minority and mocking the people in the middle of this hot summer?  It is obvious that we, the GRTU, believe in an alternative democracy!

Professor Cassola, this is a subject that we would like to have a discussion today because it is of extreme importance to us.  We want to discuss our proposals for the MEPA reform.  Regarding this subject, we presented concrete proposals to the Government based on extensive research that we carried out.  We would also like to have the opportunity on our politics regarding Localities and for the Reform of the Local Councils, about which we also have clear positions.

Above all, we would like to explain to you our work to create Management and Waste Compliance Schemes in the name of our partners.  Regarding the environment, we do not simply discuss.  We have created a subsidiary company, Green MT, and with great sacrifice and with the involvement of many enterprise owners and after many meetings with our people, with the Authorities and with our friends in the Association of Local Councils, it is with great pride that I say that we have a License from MEPA for the management of electronic and electrical waste (WEEE).  These days we also have in our possession the license to carry out the Compliance and Management Waste Scheme for Packaging.  What we are doing in Malta in this regard has already been described from high officials from the European Union as best practice which, in the future, Malta should be proud of.  We are doing this on our own initiative in full support of the Government and hundreds of enterprise owners and in full collaboration with many mayors, even though other groups, who should know better, have tried to slow us down.

But this is the GRTU Professor Cassola and our issues are studied well.  We speak to our people.  We have a website and an electronic, interactive publication system to ensure that our decisions are the decisions that enhance the welfare of our members ad our country of which the sectors that we represent are the backbone.  When we are decided, we take action.  We are not afraid to speak out and we do not budge easily.

I invite you, Professor Cassola to give us your opinion and that of Alternattiva Demokratika.  Afterwards, we will give a few minutes for the MEDIA to ask for some clarifications and after that, we will continue with our discussions.

Thousands of small businesses will be robbed of what they are entitled to under the present laws if what Government is proposing is accepted by Parliament.

Whatever Minister John Dalli and his team of “experts” say, the current law gives tenants in commercial outlets an assurance which is as good as money in the Bank. What Government is proposing is to rob people of their wealth. It’s as simple as that.

GRTU does not accept what is being proposed by a Working Team that, in GRTU’s view, is incompetent on the main issue. The main issue is the safeguard successive Maltese Governments have given to the self employed and to small business owners that they will not be evicted of their rented business premises at the whim of the land owner.

What Government is proposing today is tantamount to requisition of private businesses by land owners without compensation. GRTU considers this to be a rip-off. The rip-off of the century.

Government is not even putting forward to compensate business owners for what is being taken away. Government does not even have an idea of how many thousands of business owners are going to be effected.

It is unbelievable that Government is proposing a reform and does not present any statistics whatsoever to prove and substantiate the arguments presented. They call is a White Paper. Its actually a Red Paper, the colour of shame.

GRTU is not for turning. What enterprise owners enjoy today is a safeguard that GRTU won for them over the years.

If Government wants to turn its back on small business owners and forget all the Nationalist Party’s past commitments to the self employed and small business owners, then they should be prepared to pay the heavy political price. Government on the other hand must be prepared to come forward to pay the heavy economic price to compensate those who by Act of Parliament will be robbed.

What GRTU will be demanding as compensation to tenants denied of their rights at law will be the highest ever recorded in Malta. Current estimates indicate tens of hundreds of millions.

The objective of the proposal is to recast the existing EU legislation on cosmetic products with the view to simplify it; following the 55 amendments the original Directive has undergone since its publication. With the same objective of simplification, it tries to define a common set of definitions and obligations both for manufacturers and importers.

The French Presidency recently put forward a proposal aiming to introduce specific provisions with regard to distributors. According to these proposals they will request them:

to verify, before making a product available on the market, that certain labelling requirements are complied with

to take appropriate measures in case of non compliance

 GRTU has this week sent its official position to the consulting entity, the Malta Standards Authority.

GRTU feels that in so far as most of the information that will be required to appear on the label falls under the control and responsibility of the manufacturers, it would be abusive, not to say impossible to ask distributors to verify more than the fact that the label is worded in a language easily understandable by the end-users and that the date of minimum durability has not expired. It would be unbearable (not to say impossible) for companies and more particularly SMEs to verify whether the other types of information are present and accurate. Namely, the new provision imposes on distributors to verify that the following labelling requirements are respected:

the name or style and address of the responsible person,

the batch number of manufacture or the reference for identifying the cosmetic product,

the list of ingredients.

Imposing such types of controls would be contrary to the principle on which most of the EU legislation is founded, i.e. each operator is responsible within the limits of its activities (see for example the General Product Safety Directive 201/95).

Insofar as the initial proposal of the Commission did not contain any reference to specific obligations bearing on distributors, one could assume that, in its view, it would have been disproportionate to ask them for controlling elements of information for which they are not in a position to judge whether or not they are accurate.

GRTU drew the attention of the MSA about the impracticability of implementation of such provisions, in particular for SMEs, aiming to get closer to the initial proposal of the Commission which is more practical and sensible.

In the meantime, any comments on the subject would be greatly appreciated.

Notice of the impending expiry of certain anti-dumping measures concerning imports of silicon originating in Russia. The Commission gives notice that, unless a review is initiated in accordance with specific procedures, the anti-dumping measures will expire on the 25th of December 2008.

Imposition of a provisional anti-dumping duty on imports of certain prepared or preserved citrus fruits (namely mandarins, etc.) with regard to imports into the Community originating in the People's Republic of China. 

Notice of initiation of an anti-dumping proceeding concerning imports of certain seamless pipes and tubes, of iron or steel originating in the People's Republic of China.  The Commission received a complaint alleging that imports of certain seamless pipes and tubes, of iron and steel originating in the People's Republic of China, are being dumped and thereby threatening to cause material injury to the Community industry.

Imposition of a definitive anti-dumping duty of EUR 323 per tonne on imports of powdered activated carbon originating in the People's Republic of China.  

Imposition of a definitive anti-dumping duty of EUR 3479 per tonne on imports of coumarin originating in the People's Republic of China, as extended to imports from India, Thailand, Indonesia and Malaysia, whether declared as originating in India, Thailand, Indonesia and Malaysia or not following an expiry review.

Notice of initiation of a partial interim review of the anti-dumping measures applicable to imports of certain plastic sacks and bags originating in the People's Republic of China. 

Notice of initiation of an anti-dumping proceeding concerning imports of certain aluminium foil originating in Armenia, Brazil and the People's Republic of China.  The Commission received a complaint on protection against dumped imports from countries not in the European Community, alleging that imports of certain aluminum foil, originating in America, Brazil and the People's Republic of China are being dumped and thereby causing material injury to Community industry.

Contact GRTU to know more.

In February 2007 the European Commission asked EFSA to provide scientific opinion on the food safety, animal health, animal welfare and environmental implications of animal clones, obtained through somatic cell nucleus transfer (SCNT) technique, of their progeny and of the products obtained from those animals.

One of the main conclusions was that cloning has major impacts on the health and welfare of cloned animals, but not on the offspring since the offspring are obtained from conventional reproduction. The risk that a cloned animal is ill is 40% and their mortality is 4 times more.

BEUC was concerned by the numbers of unhealthy animals and asked how EFSA could feel comfortable drawing conclusions while having only limited data available.

EFSA responded that no method of reproduction, not even the conventional one, produces only healthy animals. The numbers and figures mentioned during the meeting regarding the healthy/sick proportion (60/40%) as well as the effects on the health and welfare (0-40% negative effects) relates only to cloned animals. Their offspring needs to be assessed in order to see if it is healthy or not. Sick/unhealthy animals must be removed from the food supply chain. Regarding food safety, concerns are unlikely. Before approval for human consumption an extra control regarding food safety must be carried out.

The Commission has launched a Eurobarometer study seeking the public's opinion on cloning techniques and on food deriving from cloned animals and/or their offspring.

The European Group on Ethics (EGE) is also asked to deliver an opinion on the issue's ethical considerations. The Commission will conduct an extensive consultation with the different stakeholders, the Member States and the European Parliament and will also consider whether any other action may be necessary.

EFSA made some recommendations to the Commission such as:

The health and welfare of clones should be monitored during their production life and natural life span.

As food animals other than cattle and pigs have also been produced via SCNT, risk assessments should be performed on these species when relevant data become available.

An organisation is seeking to collaborate with artists (musicians, visual artists, photographers, documentary film makers, poets) as part of a trans-national culture project.

An organisation is seeking partners to create a European festival ‘road show' for young people to visit and participate in each other's festival performances for young people and school children to work together, through various cultural activities, to develop their ideas of "what does being European mean?". A play would be produced where each country would perform nationally to various audiences  to create a more European dimension.

If you are interested in applying as a partner for any of these project please contact Abigail Mamo at our offices or send an email on:

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  The Small Business Act for Europe was once again a key priority during the month of July for UEAPME, the organisation representing GRTU at European level, which marked the debut of the French Presidency of the EU. On 17-18 July, President Toifl and UEAPME attended the Competitiveness Council in Jouy-en-Josas, where the SBA was discussed as the central point of the agenda.

UEAPME was the only EU organisation present at the meeting. UEAPME the floor during the lunch of Ministers and Commis-sioners in order to illustrate some simple proposals that, if accepted, would finally grant a legally binding value to the SBA, at least as far as the EU institutions level is concerned. Since the principle of subsidiarity prevents the EU institutions from imposing at national and regional level the Think Small First principle, the way to "convince" Member States to commit themselves is that EU institutions legally commit themselves making their position more credible. This was UEAPME's request, which Vice President Verheugen accepted soon after the speech.

During the meeting, UEAPME also distributed to all participants a one-page assessment on the SBA, including positive and negative points in the current text. On the positive side, the EC abandoned in the Small Business Act a twisted logic made of rules for large businesses and exceptions for smaller enterprises in favour of the "Think Small First" principle that, if fully applied at all levels, would quickly rule out the need for derogations.

On the negative side, UEAPME regretted that no mention is made in the SBA of the labour market dimension and of flexicurity, which are crucial issues for the future of SME owners and their staff. Moreover, the concept of "growth" used throughout the Council's notes on the SBA is not in line with the reality of SMEs, and the lack of any additional funding source or legal basis for implementing the various measures and actions foreseen by the SBA is worrying.

UEAPME's assessment ended up with concrete solutions, in particular the request to upgrade the founding principles of the SBA ("Think small first", above all) to the level of an EU Inter Institutional Agreement (IIA). An IIA is a particular form of agreement where the three main EU institutions (Parliament, Council, and Commission) impose themselves principles and procedures to follow when undertaking new laws or actions.

GRTU back this initiative at a local  level and we are lobbying to convinces national government to assign the Think Small First principle with a legally binding value or, at least, accept within the Council the conclusion of the IIA.

GRTU Proposals for MEPA Reform

Preamble:

The overall consensus of the Maltese public is that MEPA needs some form of reform.   Most articles in the media dwell on the fact that MEPA is insensitive to the needs of the "joe public" but lays out a red carpet treatment to the big boys who run roughshod over genuine objections by third party.   There is a general concern regarding the amount of development that has taken place over the last 20 odd years primarily fuelled by the rise in land prices and partially compensated by the designation of the penthouse level (a Government sponsored proposal) which in turn fuelled more price hikes and further housing supply.  The first time buyer market is now virtually at a standstill with the sale of quality apartments remaining buoyant.

This situation has produced a fertile environment for budding NGOs to become more vocal against indiscriminate and insensitive overdevelopment ironically  sponsored by Government itself  (e.g Pender Place, Fort Cambridge Fort Chambray, Vittoriosa Waterfront, Tigne and Manoel Island redevelopment)  signifying a major failure by MEPA to strike the proverbial balance between development and the environment.  This was primarily due to the infant MEPA buckling under pro-development political pressure in a desperate bid to survive as one of the more important government agencies.

The pro-development lobby and construction industry has consistently leveled its attacks against MEPA at its bureaucratic practices which lead to lengthy processing times for development permits especially in major projects but is also apparent in the "normal applications". 

The transition into local plans was a lengthy one (more than 10 years) however conflicting interpretation of policies is still rife and not consistent. The Structure Plan is in a dire need of revision as a strategy document and the Commission for Sustainable Development is to our knowledge non-functional.

Against this background the internal structure of MEPA struggles to keep up with its responsibilities and actions.  (Quote: MEPA Chairman- We do not have the luxury to be logical !!!). Of recent (and prior to each General Election) accusations of corrupt practices have been exchanged both internally and externally leaving by definition a negative collateral effect on the morale and  job effectiveness of the staff.

One of the critical issues is whether the environment sector should continue to form an integral part of the planning process or not. Talk to the employees of both directorates first and they will express a resounding NO.  Their opinion stems from the very real   problem of dealing on a daily basis with two, often conflicting, legislations namely the Development Planning Act and the Environmental Act.   It is pertinent to point to out that the previous Environment Protection Department and the Planning Authority empires have always been to a greater or lesser extent in continual turf wars with each other.  This situation that still persists within MEPA is to me, one of the great demotivators in sustaining healthy working relationships between the two directorates.

The decision to house the Environment Directorate away from the main MEPA building is the nail in the coffin, a conscious decision to split the two directorates without actually admitting that the two directorates have communication issues and cannot work together within the present set up.  This flies against the notion of integrated planning underpinning the so called sustainable approach the Authority should be looking at in its land use and environmental responsibilities. This decision should be critically reviewed and the possibility of expanding the current premises at St.Francis Ravelin should be taken up once again not least because the nearby park and ride zones better serve these existing premises.

What are the perceived and real problems in MEPA? 

A cause and effect analysis was used to identify the problems which currently afflict MEPA.  A Cause-and-Effect Diagram (also known as a "Fishbone Diagram") is a graphical technique for grouping people's ideas about the causes of a problem.  The identification of problems were analysed by asking:

• o What is the problem?
• o Who is affected?
• o When does it occur?
• o Where does it occur?

An overview of the internal staff dynamics reveals a number of problems:

These can probably be grouped under the title of mismanagement which is the largest contributor for staff demotivation.

• 1. Undefined roles– Conflict between the roles of the DG, DOP and Chairmen DCC ( and board members) at a higher level and enforcement officers in the planning and environmental directorate at the lower level is symptomatic of this situation.. The recent set up of the Strategy group although good in principle is not transparent in its proceedings. Decisive decisions are crucial
• 2. Lack of co-ordination and co-operation between the different units– primarily between the environmental and planning directorates is the main problem here.
• 3. Mini-Empires– DOP vs DG vs Chairman block and Liaison office ( set up to create bridges between the Directorates and the Boards) . This is direct political interference in the planning process
• 4. Lack of knowledgeable staff – particularly in design issues at case officer level.
• 5. General lack of interest -due to the perception that staff cannot effect change to the status quo.

MAIN IDENTIFIED PROBLEM IS LACK OF LEADERSHP AND MANAGEMENT

What do we expect from MEPA as its users and its customers?

The Maltese population are all potential users and customers of MEPA.  MEPA can never please all its users and customers at the same time by definition however transparency in its proceedings and explanation of its decisions are crucial to mitigate this situation.

MEPA should:

• 1. Inspire confidence in its decision taking
• 2. Be fair with all its customers
• 3. Be transparent in it proceedings
• 4. Be seen not to be influenced by political pressure
• 5. Be consistent in its decision taking
• 6. Be efficient in its decision taking process
• 7. Be pro-active in its customer care
• 8. Consistently carry out enforcement actions as a deterrent
• 9. Set up mechanisms to update its policies in a continual fashion
• 10. Be led by good practices both in the ethical and professional sense

What are the possible solutions?

It is GRTU's opinion that incremental change is much better than the grand solution approach to MEPA woes.

Areas that need special and immediate attention however are:

• 1. Improving MEPA's image through a total review of its customer service and care;
• – Favorable treatment should be given to developers that choose to accept favourable conditions for the environment above the minimum required.

• 2. Improving the decision process at all levels with related accountability timeliness and consistency

To be able to carry out these changes the setting up of a Change Team under the auspices of OPM is set up.  Representatives on this change team should include a key person which would be the right person to step in the Chairman's/ CEO role, a member of a revamped Users Committee, NGO member, Operations Manager, legal representative and PR office as key members.

Improving the decision process at all levels with related accountability timeliness and consistency

• 1. Improve management structure by reviewing performance of key people in key positions. Consider merging the roles of the directors (i.e. DG, DOP and DOE) into one as a CEO function. If necessary consider golden handshakes to remove staff.
• 2. Improve current liaison office into a fully fledged customer Call Centre (possibly with extended hours)
• 3. Consider the removal of chessclock mechanism in Development Control
• – A specific period for determination is established on the date of submission of application. Especially where the determination of applications are straight forward, as in the case of the building scheme, MEPA has to become much more efficient.
• 4. Set up one full time DCC board with competent professionals (good remuneration) with environmental permitting competencies included.
• 5. Review workings of Major Projects as a negotiating team
• 6. Set up continual training programs for DC staff
• – Staff must be well trained and capable of being good mediators and address anomalies that might arise. These should meet regularly with the chairman so that it is ensured that one direction is kept.
• 7. Initiate process of merging the Development Planning Act and the Environmental Act.
• 8. To be able to tackle current backlog within the ODZ team (around 900 cases) the introduction or redeployment of 5 case officers is necessary
• – GRTU is in favour of MEPA becoming more stringent in its approach to ODZ, particularly in sensitive and designated sites (e.g. Natura 2000 sites, Wardija, Zebbiegh, Bidnija, ect…)
• 9. Consider the introduction of MEPA being made liable to damage due to its administrative mistakes.
• – Unfortunately much harm is done through inconsistency and lack of predictability due to the huge investments property developers make. For this reason one should not permit that revision of policies harm the investments already made. When a revision or an introduction of a new policy is made there should be a cut off date from when it will start to apply following a transition period.
• – When one has a deemed approval MEPA should be obliged to issue the permit and not be subject to interpretation. More importantly when a permit is issued it must not be revoked afterwards.
• – MEPA should never, unless in extraordinary cases move away from what is written in black and white. When MEPA decides to differ from what is written the concession should be given to everyone.
• – For extraordinary cases where the written procedures do not give clear enough guidelines a board should be set up to decide. The are several mistakes and missing parts in the Local Plan and therefore it should be redone for 2008 and only this would apply and the ones before become irrelevant. This would alleviate the problem with interpretation.
• 10. Streamline DC consultation process (one stop shop) however outside agencies should bear responsibility for non-response. (Exception : Museums Department)
• – For major projects it is suggested that there should be the possibility of relaxing planning policies with the aim of achieving sustainable development. A pre-submission meeting with MEPA and potentially effected residents should be held in the specific case where policy does not fit the proposed development.
• 11. Development Briefs for Government projects should be done outside of MEPA
• 12. Review of local plans (rationalization sites) needs a more professional approach
• 13. New Structure Plan to be published (sustainable development to be the main driving force)
• 14. Review the setting up of an EIA Commission (on the Dutch Model)
• 15. Introduce user empowerment
• – On submission of application only 10 % of the amount is paid by the applicant. The full amount would be paid on the final authorization. This for the simple reason that they are paying for a pricy service which is being given very poorly.

How does one put the reform into practice?

GRTU believes there is a lot of talent within the organisation which needs to be tapped so that the reform is owned by the individual employee and not just by management and /or Government. Too many reports have been written which advocated change most of which were top down impositions.   

The process of the reform is perhaps more crucial than the actual content. Speak to all the staff. Let them come up with their own suggestions. Give them back their pride to be part of an important organisation.  Motivating the staff will tease out those logical and in most cases simple suggestions that can make the whole difference.  However, this change process must assume strong central leadership with the critical stakeholders on board perhaps in the form of a think tank groups made up of both technical and non-technical experts.

GRTU wants to be involved in the reform process as we believe we can give a valid contribution to the aim of meeting a balance between the environment and sustainable development. This should be so also for the revision of the local plans and structure plans.