Public Consultation Feedback: Financial Compensation EU emissions trading system (ETS2)

 The Malta Sociological Association (MSA) notes the European Commission's initiative on financial compensation under the EU Emissions Trading System for buildings, road transport and additional sectors (ETS2), recognising its importance in supporting a fair and socially just transition to climate neutrality.

The MSA recommends that the design, implementation and evaluation of compensation measures explicitly incorporate Social Impact Assessment (SIA) alongside environmental and economic considerations. Carbon pricing may affect different social groups unevenly, particularly lower-income households, older persons, persons with disabilities, and communities with limited access to affordable and sustainable transport or energy alternatives.

The MSA also encourages a stronger social rights approach, recognising access to affordable energy, mobility and a healthy environment as essential components of social wellbeing and inclusion. Financial compensation should therefore prioritise those most affected by the transition while promoting long-term investments that reduce social vulnerabilities and improve resilience.

The MSA further recommends that future evaluations of ETS2 compensation measures assess their wider social impacts, including effects on inequality, energy poverty, transport accessibility, employment, and territorial cohesion. Embedding SIA within the implementation of ETS2 would strengthen evidence-informed policymaking and contribute to a transition that is not only environmentally effective but also socially equitable and inclusive across the European Union.

The Malta Sociological Association also emphasizes that the ETS2 should factor in the impacts on small-island (including small island states), insular and peripheral regions within the EU, and hence include mitigating and compensatory measures in relation to such impacts.  

Public Consultation Feedback: EU Fuel Maritime Regulation – updating the list of “neighbouring container transhipment ports"

 The Malta Sociological Association (MSA) notes the proposed update to the list of neighbouring container transhipment ports under the FuelEU Maritime Regulation and supports measures that safeguard the environmental integrity of the Regulation while ensuring fair competition across the maritime sector.

The MSA recommends that the implementation of the Regulation should not create incentives for shipping operators to shift activities to neighbouring non-EU ports, primarily because of lower labour costs, weaker social protections, less stringent environmental standards, or more precarious regulatory frameworks. Such practices risk undermining both the objectives of the European Green Deal and the EU's commitment to a socially just transition.

Particular consideration should be given to small island states and peripheral EU regions, whose ports play a vital role in territorial cohesion, economic resilience, employment, and connectivity. These regions should not be placed at a competitive disadvantage through regulatory asymmetries that encourage the relocation of maritime activities to jurisdictions operating under substantially lower labour, social, or environmental standards.

The MSA further recommends that the implementation and future evaluation of the Regulation explicitly incorporate Social Impact Assessment (SIA) alongside environmental and economic considerations. This would enable policymakers to assess impacts on workers, port communities, regional development, and employment, while promoting socially sustainable and equitable maritime governance across the European Union.

Public Consultation Feedback: EU Emissions Trading System (ETS) – update to list of neighbouring container transhipment ports

The Malta Sociological Association (MSA) notes the proposed update to the list of neighbouring container transhipment ports under the EU Emissions Trading System (ETS) and supports measures that safeguard the environmental integrity of the ETS while ensuring fair competition across the maritime sector.

The MSA recommends that the implementation of the Regulation should not create incentives for shipping operators to relocate activities to neighbouring non-EU ports primarily because of lower labour costs, weaker social protections, or less stringent environmental and regulatory standards. Such practices risk undermining the objectives of the EU's climate policies, social rights, and the principles of a just transition.

Particular consideration should be given to small island states and peripheral EU regions, whose ports are essential for territorial cohesion, connectivity, employment, and economic resilience. These regions should not be placed at a competitive disadvantage through regulatory asymmetries that encourage the diversion of maritime activities to jurisdictions operating under substantially lower labour, social, or environmental standards.

The MSA also recommends that the implementation and future evaluation of the ETS incorporate Social Impact Assessment (SIA) alongside environmental and economic considerations. This would strengthen evidence-informed policymaking by assessing impacts on workers, port communities, regional development, and maritime employment, while promoting socially sustainable and equitable decarbonisation across the European Union.

The transition to low-carbon maritime transport should be environmentally effective, economically viable, and socially just, ensuring that climate action reinforces rather than undermines decent work, fair competition, and the long-term resilience of European coastal and island communities.

Public Consultation Feedback: EU Birds and Habitats Directives – stress test

The Malta Sociological Association (MSA) notes the stress test of the Birds and Habitats Directives and recommends that any review strengthen implementation while maintaining the Directives' high level of environmental protection. The MSA recommends mainstreaming Social Impact Assessment (SIA) alongside ecological and economic considerations, recognising that biodiversity conservation has important implications for communities, livelihoods, health, cultural heritage and quality of life. The review should strengthen stakeholder participation, policy coherence and evidence-informed decision-making, while giving particular attention to small island states and coastal communities, where environmental and social systems are closely interconnected. Simplification should improve implementation without weakening environmental safeguards or social sustainability.

Public Consultation Feedback: European Ocean Research and Innovation Strategy

 The Malta Sociological Association (MSA) notes the European Commission's initiative to develop a European Ocean Research and Innovation Strategy and recognises its importance in supporting sustainable, resilient and evidence-informed ocean governance.

The MSA recommends that the Strategy explicitly strengthen the contribution of the social sciences, including sociology, alongside the natural sciences, engineering and technological innovation. Many ocean challenges—including climate adaptation, the blue economy, fisheries, coastal development, maritime transport, marine conservation and ocean governance—have important social dimensions that require interdisciplinary research.

The MSA also recommends mainstreaming Social Impact Assessment (SIA) within European ocean research and innovation. Research and innovation should not only advance scientific and technological knowledge but also improve understanding of how ocean policies and innovations affect coastal communities, workers, social inequalities, cultural heritage, wellbeing and public participation.

Particular attention should be given to the experiences of small island states, peripheral regions and coastal communities, where environmental, economic and social challenges are often closely interconnected.

The MSA further encourages the Strategy to promote participatory and transdisciplinary research, bringing together researchers, policymakers, civil society, industry and local communities in the co-production of knowledge. Such an approach would contribute to more socially just, inclusive and effective ocean research and innovation across the European Union.

Public Consultation Feedback: Review of EU rules on alternative fuels infrastructure

The Malta Sociological Association (MSA) notes the review of the EU rules on alternative fuels infrastructure and recommends that their implementation explicitly incorporate Social Impact Assessment (SIA) alongside environmental, economic and technical considerations. The deployment of alternative fuels infrastructure has important implications for accessibility, affordability, employment, territorial cohesion and social inclusion. The MSA also encourages the mainstreaming of social rights, ensuring equitable access to sustainable transport infrastructure, particularly for small island states, peripheral regions and vulnerable communities. Infrastructure planning should be informed by meaningful stakeholder participation and evidence-based assessment of social impacts to support a transition that is environmentally sustainable, economically viable and socially just.

 

Public Consultation Feedback: Targeted consultation on the draft guidelines for the classification of high-risk artificial intelligence systems

The Malta Sociological Association notes the European Commission's draft guidelines on the classification of high-risk Artificial Intelligence (AI) systems and recognises their importance in promoting trustworthy, human-centred AI across the European Union.

The MSA recommends that Social Impact Assessment (SIA) be incorporated into the classification and assessment of high-risk AI systems. While technical performance, safety, and legal compliance are essential, AI systems may also generate significant social risks, including impacts on employment, inequality, education, healthcare, public services, privacy, social inclusion, democratic participation, and public trust. A systematic assessment of these social impacts would strengthen evidence-informed, transparent, and socially responsible  governance.

The MSA also recommends that the European Commission complement regulatory measures with comprehensive public education and outreach initiatives to improve AI literacy among citizens, organisations, businesses, educators, and public authorities. Greater awareness of both the opportunities and the risks associated with AI is essential for informed participation, responsible use, and public confidence in these technologies.

Embedding SIA alongside technical and legal assessments, while investing in public education and engagement, would contribute to a more accountable, inclusive, and socially sustainable framework for the development and deployment of AI across the EU.