The consultation report issued by the Climate Change Committee for Adaptation serves as a good basis for discussion on issues which have not been given sufficient attention over the years.
One of the issues tackled is that concerning the absence of rainwater cisterns in dwellings. Recommendation 35 deals with the matter.
It consists of three proposals. First, it emphasises the need to implement the existing legal provisions and then goes on to suggest the year 2007 as a cut-off point. It does this by referring to the uptake by the Malta Environment and Planning Authority of provisions relative to rainwater storage. Finally, it proceeds with recommending a one-off flood fine on those properties which, not having a rainwater cistern, contribute to flooding during heavy rainfall.
The recommendation ignores the fact that the duty to collect rainwater in cisterns was not introduced in 2007 but way back in 1880 through legislation. So the point of departure in this discussion is that all residential properties constructed after 1880 should be provided with a rainwater cistern.
The 1880 legislation was an important milestone. The provision of damp proofing, measures emphasising the importance of ventilation, the provision of an adequately sized rainwater cistern and many other matters were introduced. They are incorporated in article 97 of the Code of Police Laws. The relevant legislative provision on rainwater cisterns is regulated by the director of public health and states that “every house shall also have a cistern of a capacity of at least three cubic metres for every five square metres of the surface of the floor of each room of such house”.
One could justifiably argue that the rainwater cistern dimensions resulting from the above quoted legal provision are on the high side and that after 130 years they need revisiting. When this legal provision was introduced, the most common type of dwelling was one of two floors.
Applying the law’s dimensions to blocks of flats would result in very large water cisterns, of such dimensions that would never be fully utilised. The existing dimensions can be revisited by referring to the footprint of a building rather than to its total floor space. This would result in dimensions that are reasonable and achievable given today’s predominant building typology. It would also iron out discrepancies between the dimensions for rainwater cisterns in the Code of Police Laws and those indicated elsewhere. The establishment of the year 2007 as a cut-off point would exempt dwellings constructed before that date from shouldering their contribution to flooding.
This would discriminate and would mean that a substantial number of dwellings are left free to continue contributing to the flooding problem.
Recommendation 35 suggests the introduction of a one-off flood fine to be paid by the owners of those properties which do not have a rainwater cistern. A one-off fine will not solve anything unless it is substantial. The fine should be payable annually until such time that a rainwater cistern of an appropriate size is introduced.
How should one proceed? As a first point no one should be exempt. To reduce flooding, rainwater should be collected in every dwelling.
Secondly, it has to be recognised that, in some cases, a solution may be beyond the financial means of current owners of buildings without rainwater cisterns. In such cases some form of financial assistance should be considered as the politics of climate change should not be socially regressive.
A third consideration would be that in a number of cases the construction of a rainwater cistern may not be technically possible. In such cases the solution may well be the pooling of resources to construct communal rainwater reservoirs or to fund the maintenance of existing ones. Such funds could be administered by local councils with the owners of defaulting properties being obliged to contribute an amount equivalent to what it would cost to construct a rainwater cistern in their property.
The tangible results of such an initiative would be manifold. Having an alternative source of water some would be in a position to reduce their water bills. With less rainwater flowing in our streets flooding can be substantially reduced and our streets will be generally safer both during as well as immediately after a storm. We will also end up with less sewage overflowing into our streets if rainwater is collected instead of ending up in the public sewer. Finally, our sewage purification plants will have a reduced load during storms thereby reducing their running costs.
Alternattiva Demokratika has been emphasising the above for a number of years.
A good point to start implementation would be for the government to set the example by embarking on an exercise of providing rainwater cisterns in all government-constructed housing estates. Most of them have none.
If the government leads by example the rest will slowly follow.
Published in The Times of Malta : Saturday 13th November 2010