Over the past days, FELTOM has embarked on a number of consultations so as to put forward concerns and recommendations that are based on fact and information available.
FELTOM welcomes the announcement made by Government during last week’s Budget speech regarding the Education Malta initiative. As the local association focused on the Internationalisation of Education, FELTOM, the Federation of English Language Teaching Organisations Malta, looks forward to being involved in this initiative and its eventual actualisation.
However, whilst FELTOM reiterates its satisfaction at Government’s recommendations with regards to Education and the Tourism industry in general, the organisation would like to express its reservations with some issues and the timing of their implementation.
The main reservation concerns the newly proposed Environmental Contribution of 0.50cents per night per tourist with effect from 1st April 2016 applicable for all incoming tourists over the age of 18.
Although FELTOM has no issue with any form of eco-contribution and acknowledges that tourism has an impact on the environment that needs to be addressed, and the estimated generation of an income of 6 million euros is one way of doing that, the Federation is concerned by the fact that stakeholders seem to not have been consulted in the decision making process that led to this proposal and therefore issues with its implementation are still unclear not to mention worrisome.
FELTOM is concerned with the timing of the implementation of this measure. As with all tour operators, ELT Organisations have had their price lists published for 2016 (inc. taxes & contributions) since early this year and since this industry is nearly entirely based on group bookings or bookings through agents, taking into account that average length of stay for an ELT student is 22 days, and that 60% of students are over 18, this can easily mean, looking at industry statistics, that this will translate into an unbudgeted cost of circa 250,000 Euro for 2016 for industry, impacting directly on the profit line of the organisations since they will in fact in 2016, be absorbing such contribution.
Therefore FELTOM would like a clarification on who will be collecting this new eco-contribution, how will it be collected and whether there is any room for negotiation for those schools/tour operators that offer package deals to be exempt from 2016. The Federation proposes that this measure is implemented for individual travels as suggested, however exempts prepaid travellers for 2016.
Further to this, whilst FELTOM recognises the Government’s appointment of MHRA as the administrators of said fund, we would also like government to acknowledge those stakeholders that are in fact, responsible for actually attracting tourists with a quantifiable and significant number of bed nights, such as FELTOM with 13% of all bed nights, as stakeholders that should also be consulted on the administration of this fund.
Over and above these issues, FELTOM also outlines the fact that the differentiation of tourists over/under 18 years of age, will add a further administrative cost on the party tasked with collection, an issue which seems not to be taken into consideration, and although recognising that this differentiation may have been with good intentions, any differentiations, whether with capping or with age creates an untenable administrative burden that needs to be addressed.