| My feedback to public consultation: Conservation of Wild Birds (Framework for Allowing a Research Derogation To Determine Malta’s Reference Population of Seven Finch Species) Regulations, 2020 |
|---|
Attn:
| Ministry for Gozo (Wild Birds Regulation Unit) wildbirds@gov.mt |
|---|
With reference to this public consultation, I am submitting the following points for your consideration.
1. The policy proposal will allow trappers to keep the birds they trap without any form of enforcement or accountability. This goes against the spirit of the policy framework in question
2. The scope of the scientific study should be to improve the conservation of finches rather than to be used as a political excuse to derogate from the directive in question. The methodology requires scientific accreditation and independent peer review.
3. The methodology being proposed will allow around 4,000 non-scientifically trained people to trap birds simultaneously using live decoys and electronic lures in a small island state. This looks like a case of over-pressure on migrating finches. The methodology requires scientific accreditation and independent peer review.
4. The proposal and consultation exercise requires a social impact assessment process, even more so since the policy proposal looks tailor made to accomodate one lobby amid a much broader field of stakeholders. An SIA could produce valuable evidence for policy formation and implementation. Various methods, both quantitative and qualitative could be used within social impact assessments. The former refers to generalisable data especially through numbers, while the latter produce in-depth data on matters. Research methods in SIAs may therefore include, for example, quantitative perception surveys and qualitative methods which involve a deeper look into social realities. Besides, elite interviews may verify the advice, concerns and interpretations of persons who are experts or who have experience in the respective field under analysis. SIAs should involve the participation of different stakeholders, ideally through mixed research methods. Analytic indicators should be provided and the entire process should be subject to peer review by independent experts in the field.
This means that if a study is being carried out by a team of social scientists, this should be scrutinised by other independent social scientists. This could help identify shortcomings and possible improvements to the same SIA. |
|---|
Social impact assessments should not be one-off exercises: To the contrary, they should be ongoing processes which engage with various stakeholders and which report back so as to ensure effective policy processes. They should also use complementary research methods so as to ensure reliable and valid data.
