24th August 2001

Moviment ghall-Ambjent,
Friends of the Earth (Malta);
Nature Trust (Malta);
ECO – The Malta Ecological Foundation;
Din L-Art Helwa

Environment NGOs call for action on waste management strategy

Environment NGOs have sent submissions on the proposed waste management strategy and have pointed out certain deficiencies in what is being proposed.

The NGOs urge the authorities to put certain parts - on which there seems to be broad agreement - of the proposed strategy into practice.

As a first step the composting plant at Sant’Antnin needs to be upgraded and a good system for waste separation at source should be launched as soon as possible.

The NGOs are also calling for incineration to be removed from the strategy. It is clear that Malta can have an environmentally sound strategy, and comply with the EU Directives, without incineration.

The main criticisms of the groups were the following:

1) The strategy as proposed does not properly tackle the problem of waste contamination on these islands. For this to be addressed the toxicity of our waste streams should be reduced by a number of measures. Also the strategy does not mention measures that could be taken to ban certain toxins from being used in products and packaging;

2) The proposed strategy does not indicate by reference to facts and figures how certain conclusions were arrived at. Although many of the recommendations in the strategy appear to be based on logic and enjoy our support, we call on the government to make available to the public all the facts and figures used as a basis for the proposed strategy;

3) The EU approved consultants time and again told us that Malta will need an incinerator as part of its waste management tools. Incineration with energy recovery is included in the proposed strategy. We were always opposed to incineration for a variety of reasons and sceptical of the need for an incinerator. We are now more than convinced that Malta would benefit from a strategy that does not include incineration;

4) We feel that the strategy does not properly tackle the first aim of waste management strategies: that of waste prevention and reduction. It must be remembered that from the environmental point of view it should be a target to reduce the waste coming into our islands, so as to reduce the rate of depletion of resources, and also the toxicity of such waste;

5) The strategy did not consider at least one important waste management disposal option: that of biological treatment for mixed waste as a tool to meet the targets of Directive 99/31/EC. We feel that biological treatment is appropriate for Malta and recommend that it is included in the final strategy to be adopted by the government;

6) The strategy does not provide clear guidance for the management of construction and demolition waste. The strategy should provide detailed plans for the reduction of construction and demolition waste and this would involve cooperation from the construction industry and the Planning Authority. About 85% of our waste arisings are from C& D. This is due to the cheap price of stone and our unsustainable building industry. The strategy should ensure that measures are taken to change the ways of the construction industry so as to reduce waste. Sustainable development is just a catch phrase in Malta and we have no sustainability targets;

7) Certain waste streams were not properly considered in the strategy e.g. agricultural waste and packaging waste;

8) The strategy does not indicate how Malta will comply with certain EU Directives, particularly the Packaging and Packaging Waste Directive;

9) We contend that it would be prudent to adopt a strategy that is suitable for the Maltese situation including going beyond EU Directives and one that considers the possibility that Malta does not become a member state;

10) For special wastes, the strategy does not consider any other waste treatment options and technologies other than incineration. We do not agree that special wastes (abattoir, airport, hospital, port) should be incinerated;

11) The strategy does not explain what will happen to Maghtab and other dump-sites. The strategy should include a plan for the rehabilitation of these sites;

12) The strategy should indicate criteria for the location of the proposed waste treatment plants: composting plants (should new ones be required) recycling plants, stone depots and the new landfill;

13) We feel that the strategy should have a more comprehensive look at the social and economic costs of what is being suggested and compare the different alternatives;

14) The strategy does not cover the problems related to illegal dumping which can be expected to increase dramatically given the suggested higher price of landfilling. The disposal of animal sludge needs further consideration.

15) The proposed strategy should be subjected to a Strategic Environment Assessment as per the new EU Directive;

16) While education is very important for the strategy to work, the experiences from EU countries have shown that the correct implementation of a well-formulated strategy is the key to success in waste management;

17) We suggest a strategy that gives more importance to waste separation at source and the production of good quality compost which is much needed in the Maltese Islands.

A copy of the entire document is available from foe@maltanet.net