Waste update : back to the drawing board


by Carmel Cacopardo

published on Saturday February 28, 2009


The Solid Waste Management Strategy update published recently, identifies a zero waste scenario as a long-term aim. It refers to a number of studies commissioned and proceeds to a selective use of conclusions from the said studies, which are still under wraps.

A Situation Audit of the strategy was carried out in 2005. Yet, the only conclusion that has found its way into the proposed update is a statement on the practical non-existence of the interministerial committee set up to coordinate the strategy’s implementation across government. The full Situation Audit should see the light of day. The public has the right to be informed as to the manner in which targets were attained and the reasons as to why others were missed.

The update is incomplete; it postpones updating the strategy on hazardous waste, promising instead a Topic Paper in the future. The management of hazardous waste includes the implementation of the WEEE Directive (Waste from Electric and Electronic Equipment), which is way behind schedule.

Producers and their representatives in terms of the WEEE Directive assume full responsibility for the waste generated by their products. Yet, the government, through the simultaneous application of the eco-contribution and the WEEE Directive, has placed them in a situation where they have to pay twice for the handling of electric and electronic waste: The payment of an eco-contribution and shouldering producer responsibility in terms of EU legislation. The result is that while, on paper, the WEEE Directive in Malta has been transposed, in practice its implementation is being obstructed. It is an area of responsibility that EU legislation assigns specifically to the private sector, yet the government is reluctant to lose a substantial chunk of eco-contribution revenues and is consequently applying the brakes.

The regulation of scrap yards does not feature in the update. They are required in order to recycle scrap metal. However, they should operate within a regulatory framework, in particular in conformity to the WEEE and the ELV (End of Life Vehicle) Directives. Recently, it was reported that, during testimony submitted in a planning appeal, concerning the enforcement order relative to the Ta’ Brolli scrap yard in Birzebbuga, it was revealed that part of its business originates from the custom of government departments and corporations!

Some scrap yards process scrap from disused refrigerators! Processing? They just crush them, as a result releasing refrigeration gases to air. These gases are CFCs (chloroflorocarbons), contributors to the depletion of the ozone layer. In a regulated environment in terms of the WEEE Directive, processing disused refrigerators for waste would include the careful collection of the CFCs as a first step. Instead, some Maltese scrap yards are contributing to the depletion of the ozone layer in contrast to the provisions of the 1987 Montreal Protocol, which Malta has bound itself to observe and implement.

The proposal for an updated strategy encourages a policy favouring waste incineration. It proposes that the use of bio-digestion to convert waste to energy is complemented by a policy favouring incineration. Specifically, it proposes a waste to energy incinerator to be sited at Delimara next to the power station. This could also mean that on waste recovery sites (currently in operation or projected) the two technologies could co-exist.

Incineration is undoubtedly a waste management tool. In my opinion, it should however, only be used as the last option.

Relying on incineration to produce electricity would, on the plus side, reduce required landfill space and the fuel bill. It would still, however, contribute to the production of greenhouse gases and, hence, cannot be described as a source of clean energy. On the minus side, it negates the need to reduce waste generation and produces other possibly toxic emissions, which would vary dependent on the composition of the RDF (refuse derived fuel).

The regulation of these emissions is normally established through a permit issued by Mepa in terms of the EU Directive on Integrated Pollution Prevention and Control. The acceptability or otherwise of an incineration facility even as a tool of the last resort would in my view result from two points: The quality of emissions control imposed by Mepa through the conditions established in the IPPC permit, and the enforceability of these conditions.

If the manner in which the Marsa incinerator has operated in the past months is a reliable indicator on the workings of Mepa and Wasteserv, this is sufficient on its own to discard the incinerator option even as a tool of last resort.

These are just a few of the points indicating reasons as to why the proposed waste strategy update needs to go back to the drawing board. Together with the fact that a Strategic Environmental Assessment has not to date been carried out, this is clear evidence of its poor quality. Such a document cannot lead to a fruitful public discussion.

Kisba importanti wara suġġeriment ta’ AD – MEPA accepts AD proposal


Stqarrija ta’ AD

AD Press Release



Alternattiva Demokratika hi sodisfatta illi fid-deliberazzjonijiet tiegħu
il-Bord tal-MEPA, iktar kmieni llum, huwa hu jiddeċiedi dwar waħda
mill-applikazzjonijiet konnessi mal-Port Ħieles aċċetta proposta li saret
mill-kelliemi ta’ AD dwar l-Izvilupp Sostenibbli u l-Gvern Lokali l-Perit
Carmel Cacopardo.
Arnold Cassola, Chairperson ta’ AD, qal illi l-Bord tal-MEPA rabat il-ħruġ
ta’ permess ambjentali għall-operazzjonijiet tal-Port Ħieles mal-ħtieġa illi
tkun introdotta EMS (Evironmental Management System). Kien ta’ sodisfazzjon
żied jgħid Arnold Cassola li d-Direttur għall-Ħarsien tal-Ambjent Martin
Seychell qabel mal-proposta li saret
minn Cacopardo u ppropona emenda
għall-permess liema emenda ġiet approvata mill-Bord.

Carmel Cacopardo kelliem tal-Partit għall-Iżvilupp Sostenibbli u l-Gvern Lokali
ikkonkluda billi qal li l-adozzjoni mill-Port Ħieles ta’ EMS ser tfisser li
fuq perjodu ta’ żmien ikunu introdotti l-mekkaniżmi ħalli l-Port Ħieles
jindirizza l-impatti ambjentali tiegħu u b’hekk titjieb il-kwalita’ tal-ħajja tar-residenti ta’  Birżebbuga.

Alternattiva Demokratika ser tibqa’ ssegwi dan il-każ u tagħti l-appoġġ sħiħ tagħha lill-Kunsill ta’ Birżebbuġa.

AD The Green Party in Malta is extremely satisfied that in its deliberations the
MEPA Board earlier today, when discussing one of the development applications
relative to the Freeport accepted a proposal made by AD’s spokesperson on
Sustainable Development and Local Government Architect Carmel Cacopardo.
Arnold Cassola AD Chairperson said that the MEPA Board linked the issuance of the environmental permit relative to the Freeport operations to a requirement of
introducing an
EMS (Environmental Management System). It was quite satisfying added Arnold Cassola that the Director for Protection of the Environment Martin Seychell agreed to Cacopardo’s proposal and subsequently he proposed an amendment to the permit which was approved by the Board.

Carmel Cacopardo party Spokesperson on Sustainable Development and Local
Government concluded by stating that the adoption by Freeport of an EMS will
signify that over a short time-frame the
will introduce the necessary
controls such that it will be in a position to address its environmental impacts
and consequently improve the quality of life of Birzebbuġa residents. AD will
keep on monitoring this issue in full support of the Birzebbuġa Local Council.
Ralph Cassar




AD requests Environmental Information in terms of Aarhus Convention



AD statement issued today Tuesday 24 February 2009

Today AD Spokesperson on Sustainable Development and Local  Government Perit
Carmel Cacopardo on behalf of Alternattiva Demokratika, asked MEPA for a copy of
the following environmental information referred to in the “Solid Waste
Management Strategy for the Maltese Islands. A First Update”:

1) Situation Audit of the Solid Waste Management Strategy carried out in January
2) TAIEX Project Report carried out with Germany entitled : A Waste Management
Plan for the Maltese Islands 2006-10,
3) Report of the Twinning Project between Malta and Austria MT05-1B-EN-01 :
Recycling of Construction and Demolition Waste in Malta : Strategy for
Short-Term Implementation,
4) Report of the Twinning assignment between Malta and Austria entitled :
Hazardous Waste Inventory and Technical Assistance in regulatory aspects of
Hazardous Waste Management,
5) Report of the Twinning project between Malta and Austria entitled : Waste to
Energy in Malta – Scenarios for Implementation.
6) Report on an Agricultural Waste Management Plan for the Maltese Islands.

Perit Cacopardo said that selective parts of the said reports have been quoted
or referred to in the Consultation Document published recently by the Ministry
responsible for Waste Management. He said that for effective and informed
consultation to take place all those interested should have access to all
pertinent information available to the government. The request was made in terms
of the Aarhus Convention of which Malta is a signatory.

Ralph Cassar

Merkurju fl-ikel ?


Nhar t-Tnejn li għaddew f’Nairobi l-Kenya kulħadd baqa’ ssummat meta waqt laqgħa tal-Kunsill tal-UNEP (United Nations Environment Programme) ir-Rapprezentant tal-Gvern tal-Istati Uniti tal-Amerika ħabbar appoġġ tal-Gvern ta’ Barack Obama għall-inizzjattiva tal-UNEP dwar trattat internazzjonali li jikkontrolla t-tniġġiż mill-merkurju fuq livell dinji.


Il-Gvern ta’ Bush qatt ma ta’ widen, imma Obama f’inqas minn xahar dawwar ir-rotta !


Dan il-merkurju joriġina prinċipalment mill-faħam li jintuża f’xi power stations għall-ġenerazzjoni tal-elettriku. Jintuża ukoll fil-batteriji u f’xi proċessi industrijali.


L-merkurju meta bħala riżultat ta’ ħruq ta’ faħam jew għal xi raġuni oħra jsib ruħu fl-atmosfera ma jirrispettax il-funtieri fil-mixja tiegħu. Fost oħrajn jakkumula f’affarijiet li nieklu bħall-ħut. (ara per eżempju r rapport intitolat Mercury in Fish. A Global Health Hazard. Ippubblikat dan ix-xahar : Frar 2009)


Dan imbagħad jakkumula fina u f’uliedna b’konsegwenzi kbar għas-saħħa tagħna lkoll. Għalhekk huwa importanti li l-merkurju jkun ikkontrollat aħjar.


L-inizzjattiva tal-Gvern ta’Obama hi pass kbir il-quddiem u tawgura tajjeb għall-kooperazjoni internazzjonali fil-qasam tal-ambjent.


San Ġwann



It-tagħlima dwar il-każ San Ġwann hi waħda ta’ natura fondamentali : li l-opinjoni pubblika għandna nagħtu każ tagħha dejjem.


L-opinjoni pubblika tifforma fuq dak li tisma’, taqra u tgħarbel. Inkluż fuq dak li tifhem li qed jinħeba lilha. L-esperti ukoll għandhom rwol fil-formazzjoni tal-opinjoni pubblika. Imma dak li jgħidu l-esperti għandu jkun magħruf dejjem u mhux meta jaqbel biss.


Fil-każ San Ġwann il-Gvern ta’ Gonzi naqas prinċipalment għax kien inkonsistenti. Jekk vera emmen illi kienu meħtieġa iktar studji u opinjonijiet qabel ma tittieħed deċiżjoni dwar il-proġett mill-MEPA, għaliex il-Gvern ta’ l-go-ahead biex jiġu allokati l-fondi tal-EU għall-proġett? Il-messaġġ li ngħata b’dik id-deċiżjoni dwar il-fondi kien illi l-proċeduri jew kienu finta inkella li ma kien hemm l-ebda dubju dwar kif dawn ser ikunu konklużi. Min iddikjara li l-opinjonijiet kollha għandhom jinstemgħu (inkluż li jsiru l-istudji) qabel ma jittieħdu d-deċiżjonijiet messu hu stess ma ħax id-deċiżjoni dwar il-fondi qabel ma saru l-istudji.


Ovvjament jista’ jkun li l-moħħ wara din l-idea kien dak li jispeċjalizza fil-ħidma bil-moħbi, bil-kwiet, wara l-bibien magħluqin. Dak li imdorri jiddetta u jmexxi mingħajr ma qatt issottometta ruħu għal elezzjoni. Din hi l-filosofija li teħtieġ tingħata l-ġemb : it-tmexxija bil-ħabi, minn wara l-kwinti.


Il-lezzjoni hi waħda kbira : in-nies jidhrilha li m’għandhiex tintalab l-opinjoni tagħħa f’elezzjoni ġenerali biss. Il-fehma tan-nies hi relevanti dejjem.

The Value of Silence


published on February 7, 2009

by Carmel Cacopardo



Sound can be pleasant or annoying depending on personal preferences and moods. It becomes noise, acoustic pollution or maybe even sonic violence when it breaches the individual threshold of tolerance.

Through the Environmental Management Construction Site Regulations of 2007, an attempt has been made to regulate sound emanating from construction sites. While this was a step in the right direction it is to be pointed out that these regulations have not yet been rigorously applied.

The European Union, through Directive 2002/49 known as the Environmental Noise Directive (END), dealing with the “assessment and management of environmental noise”, went one step further: It established common criteria to assess and manage noise throughout the EU. It seeks to establish common criteria relative to the assessment of noise generated by main airports, roads carrying more than six million vehicle passages per year, urban areas having a population exceeding 250,000 and railways. The criteria relative to roads are clearly applicable; those relative to major airports would be applicable when flight movements at Malta International Airport exceed 50,000 per annum (29,972 flight movements in 2008), while the other criteria are obviously inapplicable.

The aim of END is three-fold. Firstly, to define a common approach in noise mapping by EU member states and, thus, to determine exposure to environmental noise through common methods of assessment. Secondly, to ensure that information on environmental noise and its effects is made available to the public. Thirdly, subject to public consultation, to adopt action plans on the basis of the noise-mapping results. These aims had to be attained by specific dates, all of which have now expired.

At AD’s request last week, the Meusac core group was informed by the director of Environment Protection, that Mepa does not have the know-how to implement END and that it intends to issue a tender to farm out the technical expertise required. This decision could easily have been taken more than four years ago such that Malta would now be in the phase of implementation. It seems, however, that this is still far away as the tender is yet to be issued!

When END is finally implemented, various noise sources would still be unregulated. Other jurisdictions have tackled such noise sources as the leisure industry, industrial activity that lies close to residential areas as well as the impacts of noise sources within residential areas themselves.

A court report in The Times some days ago highlighted the impacts which noise, generated by air-conditioning units used by a bank in Sliema, has on overlying residences. This particular case highlighted the friction generated within areas wherein commercial and residential use intermingles. Similar friction exists in residential areas due to the fixing of air-conditioning units servicing ground-floor tenements in such a manner as to be a nuisance to residents of overlying tenements. There is no easy solution to this problem if the point of departure is not the seeking of good neighbourly relations.

In September 2008, the Irish government, faced with similar problems, published a Noise Issues Consultation Paper. This was an initiative taken by John Gormley, Green minister for the Environment in the Irish coalition government. Through specific legislation it was proposed to regulate infrastructural, planning, construction, commercial, industrial, recreational and anti-social noise.

Infrastructural noise would be that related to road traffic as well as low-flying aircraft. Regulating noise from planning/construction does not only concern construction sites but also the noise resulting from the use of a property (say, air conditioners). The regulation of noise emanating from commercial and industrial establishments would address the use of equipment in these establishments, noise resulting from clients of bars, nightclubs and discos both when the premises is in use as well as when exiting.

Noise relative to industrial installations, especially those situated close to residential areas, is another area needing to be tackled! Recreational noise would address for example the sonic impact of jet-skis and festa fireworks while anti-social noise would include continual and persistent sounding of alarms (car and house/shop alarms), noise from neighbourhood parties, animal noise in residential areas, in particular the persistent barking of dogs, as well as noise generated by large groups loitering in residential areas late into the night.

Not all of these issues are regulated in Malta. Enabling powers are spread in various laws, which generally authorise the Commissioner of Police to take the necessary action. The police, however, at times are powerless when they consider that a sonic nuisance brought to their attention could not fall within their competence, the issue of air conditioners being a case in point.

This points to the need to consolidate and update Maltese legislation regulating acoustic pollution such that an immediate administrative remedy is available to ensure that the value of silence, where appropriate, is appreciated by all.