The circus has come to town



When considering the draft National En­vironment Policy some patience is required. On one hand it is a detailed document covering a substantial number of environmental issues. However, its exposition of the issues to be tackled contrasts starkly with the government’s environmental performance throughout its long term in office.

The draft policy says more about the government than about the environment. It collates together the accumulated environmental responsibilities the government should have been addressing throughout the past years. The draft policy tells us: this is what the government ought to have done. It further tells us that in the next 10 years, the government will try its best to remedy its past failures by doing what it should do.

The government’s words and action are in sharp contrast, as I have been repeatedly pointing out in these columns. In late 2007, Cabinet approved the National Strategy for Sustainable Development, which, although being less detailed than today’s draft National Environment Policy, says practically the same things. It also covers a 10-year period (2007-2016), half of which has elapsed without the set targets having been addressed. Prime Minister Lawrence Gonzi is the Cabinet member politically responsible for this failure. Having failed repeatedly, I find it difficult to think how he could be trusted to deliver on environmental or sustainability issues.

On the basis of this experience, it is reasonable to dismiss the government’s media circus at Xrobb l-Għaġin where the draft National Environment Policy was launched as just another exercise in rhetoric.

It is definitely not a sudden conversion in favour of environmental issues that moved the government to act. The present exercise is the result of society’s metamorphosis, which came about as a direct consequence of years of environmental activism in Malta. Civil society has pushed a reluctant Nationalist-led government to this point.

No one in his right senses can quarrel with the proposed National Environment Policy in principle. Yet, it is a fact that the environment has always been the Cinderella of government business. All talk and little walk. A clear example is the adjudication process of the Delimara power station extension. When the submitted tenders were adjudicated, it resulted that the submissions that were technically and environmentally superior were considered less favourably than the tender that was perceived as being economically more advantageous. When push comes to shove, environmental issues are not given priority, the adjudication criteria being skewed in favour of perceived economic gain.

All this contrasts with the declarations in favour of green procurement in the draft National Environment Policy. In defending the decision on the use of heavy fuel oil in the power station extension, government spokesmen are in fact stating that while the environment is the government’s political priority it still retains the right to have second thoughts whenever it takes an important decision.

When the government plays around with its declared environmental convictions with the ease of a juggler, it sows serious doubts on its intentions. Even if the Parliamentary Secretary for the Environment is doing his best to convince that, under his watch, the environment carries weight it is clear to all that he has not succeeded in wiping the slate clean. He is still conditioned by the attitudes and the decisions taken by his boss and colleagues in the recent past. Their attitudes have not changed at all. Old habits die hard.

On a positive note, I have to state that the process leading to the draft National Environment Policy submitted for public consultation was one which involved civil society. A number of proposals submitted by civil society, including those in an AD document submitted to Mario de Marco, were taken on board. I also had the opportunity to discuss the draft policy and AD’s views with Dr de Marco on more than one occasion. The discussions were, in my opinion, beneficial.

The problem the government has so far failed to overcome is that it preaches one thing and continually does the opposite. The only times when it carries out positive environment action is when it is forced on this course by EU legislation or by threats of EU infringement proceedings. Within this context, declarations that Malta aims to go beyond the requirement of the EU’s acquis are, to say the least, hilarious. It would have been much better if the basics of the EU environmental acquis are first put in place.

The environmental initiatives taken during the past seven years have been mostly funded by the EU.

They would not have been possible without such funding.

By spelling it out, the draft National Environment Policy defines the government’s past failures. Hopefully, it also lays the groundwork for the required remedial action. The environmental destruction the government has facilitated and encouraged will take a long time to remedy. In some cases, the damage done is beyond repair.

Beyond the entertainment value of the media circus at Xrobb l-Għaġin, these first steps are just the beginning of a long journey. For the sake of Malta’s future generations I hope that the government does not go astray once more.

Reflections on an Environment Policy

The current debate on what should form part of a National Environment Policy is a healthy exercise. It is focusing not only on the different aspirations of each citizen but also on the role of each one of the towns and villages which together constitute this country.

The environmental issues we face are the result of the manner we organise our lives both individually and as a community. In fact it can be safely stated that the manner in which economic activity has been organised throughout time has created different environmental and social impacts.

The exercise at this point in time is hence the clear identification of these impacts and subsequently seeking the best manner in which they can be tackled. This is done on two fronts: firstly through the formulation of an environment policy and secondly by integrating this environment policy with economic and social policy within the National Strategy for Sustainable Development (NSSD).

The NSSD has already been formulated and approved by Cabinet almost three years ago after a long process of consultation. It established targets and objectives which have unfortunately been ignored by the same Government which has approved them. This necessarily leads to the conclusion that these exercises can be a waste of time as their only purpose seems to be an exercise to prove that the new hands on deck can do things in a better way than those they have replaced. 

The National Environment Policy Issues Paper identifies a number of areas which are to be tackled but excludes a number of important ones. What is in my view objectionable and bordering on the insulting is the ignoring by the Issues Paper of the NSSD. It also ignores matters which have been tackled by the NSSD as well as the specific targets identified. This the NSSD did after extensive consultation with civil society, which the Issues Paper promises to go through again.



One such case refers to the use of economic instruments to attain environmental objectives. The Issues Paper queries whether and to what extent there is agreement  with the use of such instruments to further environmental objectives. Simultaneously with the publication of the Issues Paper, Finance Minister Tonio Fenech through the pre-budget document was lauding the idea of introducing a carbon tax and the possible utilisation of the proceeds to affect a tax shift. This is in the spirit of the former EU Commission President  (French Socialist) Jacques Delors’ 1993 EU White Paper entitled “On growth, competitiveness and employment. The challenges and ways forward into the 21st century”.

So whilst the Environment Ministry is requesting our opinion on the use of eco-taxation (and other instruments) it seems that the Finance Ministry is dead-set to proceed.  Do these two Ministries form part of the same government? 

Both the Environment Ministry and the Finance Ministry would do well to go back in time to the debate on the introduction of the eco-contribution (2003-05) where they could identify a number of issues raised by civil society.

Should fiscal objectives be the purpose of environmental taxation or would it rather be environmental improvement? All over the globe governments declare that their aim in applying eco-taxation is environmental improvement. Yet they resist transferring political responsibility for environmental taxation from the Finance Ministry to the Environment Ministry. Such a move would lend credence to statements on the environmental objectives of eco-taxation and would ensure that the design of specific measures is more in line with encouraging changes in behaviour. Retaining political responsibility for environmental taxation at the Finance Ministry on the other hand signifies that the objective is to tax behaviour but not  to change it. This reluctance is generally reflected in the manner  in which eco-taxes are designed. Fiscal policy makers pay attention to the fact that changing behaviour would mean drying up a source of revenue. Hence eco-taxes designed for fiscal objectives are intended not to affect the elasticity of demand. This is done by selecting items in respect of which there are no alternatives and thus irrespective of tax added to the price there is no alternative to purchasing the product or service. The eco-contribution exercise clearly illustrates this argument.


Environmental nuisance 

The Issues Paper has failed to project an understanding that environmental issues can be most effectively tackled at a micro-level. In fact the Issues Paper adopts an exclusively macro approach and does not give any weight to the real life issues. Issues of environmental nuisance are the ones which the man in the street feels strongly about. These include primarily noise, air quality and odour nuisance caused by neighbours in residential areas. They could range from an air conditioner fixed below your bedroom window to a neighbour’s fireplace chimney spewing smoke right into your living room or a bakery belching black smoke onto your washing line. Or the newly opened restaurant or snack bar in a transformed ground floor flat whose operator wouldn’t care less about where the odours from his kitchen end up.    


Access to environmental information is an important aspect of environment policy. Yet the drafters of the Issues Paper ignored it. The environmental information aspects of the Åarhus Convention have been incorporated into Maltese legislation as a direct result of Malta’s EU accession. This legislation provides a mechanism through which the citizen requests the release of information which up till then would be withheld by the authorities. This is a very primitive form of governance. The state should release information without having its hand forced to do it. This is the minimum required in an age of transparency and accountability. 

Policy proposals and other initiatives must be buttressed by studies which not only justify the proposal or initiative but which also identify the resulting impacts and the manner in which these can be addressed. Studies must be published at an early stage and not in the final stages of a discussion. Otherwise the public debate cannot be fruitful.

Transparency and accountability

Transparency and accountability are not only duties of the state. They are also a responsibility of private enterprise.  Corporate Social Responsibility (CSR) reporting is one way in which private enterprise informs the public on its activities. It is a function as important as financial reporting. Financial reporting having been accepted by society for quite a long time as a reporting requirement.

In Malta currently two companies publish a CSR report. Vodafone (Malta) and Bank of Valletta (BOV) have already published two editions of their CSR report. There has been considerable improvement in the information made available by Vodafone (Malta) in its second report, but BOV’s reporting  can be substantially improved.

The environment policy should identify the type of organisations that should have the duty to report publicly and on a regular basis on their environmental and other impacts. By organisations I understand not just industry and business but also public corporations, government departments and local authorities. A reasonable first step would be for companies quoted on the stock exchange to take the lead followed by public bodies such as Enemalta, Water Services Corporation, Heritage Malta and Air Malta.

CSR reporting should be guided by international standards such as the Global Reporting Initiative G3 guidelines and should be subject to auditing in order to verify that the statements made reflect what the organisation is really up to. 

Alternattiva Demokratika, AD, the Green Party in Malta has earlier this month published a document in reply to the National Environment Policy Issues Paper which lists and discusses the areas missed out by the said Issues Paper.  In addition to focusing on the urgent need to implement the NSSD, environment information, environmental nuisance and environment information it also points out the need to tackle the uptake of environmental management systems such as ISO 14001 and the Eco-Management and Audit Scheme (EMAS) Regulations of the European Union, light pollution, contaminated land, environmental and sustainability planning at a locality level better known as Local Agenda 21,  the role of civil society and environmental NGOs in environment policy and environment  research.  

We hope that when the environment policy is drafted it will include the widest possible list of issues and will tackle them in an holistic manner keeping in mind the parameters established in the National Sustainable Development Strategy.                 

Alternattiva Demokratika considers that environment policy is one of several instruments through which improvement in the quality of life can be attained. Protecting the environment signifies that we better our quality of life. It also signifies that each one of us acts in a responsible manner. However primarily it must be government which leading the way should act in an appropriate manner in order that it leads by example.

 published in

The Independent on Sunday, October 17, 2010, Environment Supplement

Lejn politika tal-ambjent


Dalgħodu ħadt sehem fil-Workshop dwar il-Pjan Nazzjonali għall-Ambjent. Dawn huma uħud r-riflessjonijiet tiegħi.

Li nitkellmu dwar il-politika ambjentali hu pass tajjeb. Id-diskussjoni iżda biex tkun ta’ kontribut posittiv trid tkun waħda onesta. Trid tirrispetta lil kull min ta’ ħinu u saħħtu fis-snin passati f’ħidma favur l-ambjent.

Tajjeb li neżaminaw l–analiżi dwar il-Public Attitudes Survey 2008 li d-ditta Ernest & Young (2010) ħejjiet fuq inkarigu tal-MEPA. Minn dan jirriżulta illi  69% ta’ dawk li wieġbu huma tal-fehma li l-ambjent huwa importanti daqs l-ekonomija filwaqt li 23% jidhrilhom illi l-ambjent huwa iktar imporanti mill-ekonomija.  8% biss għadhom tal-fehma tas-supremazija tal-ekonomija fuq l-ambjent.

Huwa b’sodisazzjoni li nosserva din l-attitudni ġdida. Attitudni li ilha tinħass tiżviluppa bil-mod il-mod. Hi riżultat tal-ħidma ta’ dawk kollha illi għal snin sħaħ ħadmu kontra l-kurrent b’bosta minnhom ikunu deskritti bħala eko-fundamentalisti.

Fid-dawl ta’ dan huwa iktar importanti li d-diskussjoni tal-lum tkun ċara u onesta. L-Issues Paper li għandna quddiemna tistaqsi ħafna mistoqsijiet. Imma sfortunatament għażlet illi tinjora l-fatt li ħafna mit-tweġibiet diġa ngħataw. Dawn qegħdin fl-Istrateġija Nazzjonali dwar l-Iżvilupp Sostenibbli approvata mill-Kabinett tal-Ministri lejn tmiem l-2007 wara proċess twil ta’ diskussjoni mas-soċjeta’ ċivili.

Mhux ser nidħol fid-dettal għax il-ħin ma jippermettix.  Ser nillimita ruħi għal eżempju wieħed: dwar it-tassazzjoni ambjentali.

L-Issues Paper  f’paġna 12 tistaqsina dwar x’naħsbu fuq sistema li tintaxxa t-tniġġiz flok ix-xogħol. Kumbinazzjoni fid-dokument ta’ qabel il-budget imniedi mill-Ministru tal-Finanzi  fl-istess jum tal-Issues Paper qed jiġi propost (f’paġna 136) ezerċizzju ta’ “tax shifting”. Jgħid li qed jikkonsidra d-dħul ta’ “carbon tax” u li hi l-intenzjoni li din tissostitwixxi taxxi oħra konnessi max-xogħol.

La l-Issues Paper u l-anqas id-dokument dwar il-budget ma jagħmlu l-iċken referenza għall-istrateġija nazzjonali dwar l-iżvilupp sostenibbli li diġa bil-kunsens tas-soċjeta’ ċivili u tal-Kabinett stabiliet fil-proposta 17 tagħha illi sal-2008 kellha titfassal strateġija dettaljata dwar l-użu ta’ strumenti ekonomiċi biex jippromwovu l-iżvilupp sostenibli f’Malta. L-2008 ilu li ġie u mar u flok strateġija dettaljata għandna iktar mistoqijiet. Din mhux serjeta’. Flok iktar mistoqsijiet kellu jkollna analiżi tat-taxxi ambjentali li ġja għandna fil-pajjiż u jekk dawn laħqux l-iskop li għalih saru. X’tgħallimna mill-eżerċizzju tal-eko-kontribuzzjoni?    Tgħallimna li  :

l-ewwel :          li taxxi ambjentali għandhom jintużaw għal skopijiet ambjentali u mhux għal skopijiet fiskali,

it-tieni :             ir-responsabbilta’ politika għal sistema ta’  tassazzjoni   ambjentali għandha tkun fdata f’idejn il-Ministeru għall-Ambjent u mhux f’idejn dak tal-Finanzi, biex b’hekk ikun iktar possibli li  t-titjib fil-qasam ambjentali jkun l-oġġettiv ewlieni tagħhom,

it-tielet :            li filwaqt li hemm bosta setturi li jistgħu jkunu soġġetti għal tassazzjoni ambjentali l-għażla tagħhom għandha issir bir-reqqa u wara studju tal-impatti kemm ambjentali kif ukoll soċjali.

F’dan il-kuntest irrid ngħid li mhux aċċettabbli li l-Gvern iħabbar illi qed jikkonsidra “carbon tax” mingħajr ma jinfurma lill-pubbliku dwar xi studji għamel mhux biss fuq kemm jista’ jdaħħal iżda ukoll dwar kif din ser teffettwa kemm il-kwalita’ tal-ħajja kif ukoll il-livell tal-għajxien tal-faxex differenti tas-soċjeta. Dan l-istudju, jekk sar, s’issa għadu ma rax id-dawl tax-xemx. Fil-fatt dalghodu jiena għamilt talba formali taħt il-provedimenti tal-Konvenzjoni ta’ Åarhus biex jekk jeżistu jiġu rilaxxjati l-istudji relattivi. Dawn huma l-affarijiet li jmissna niddiskutu.

M’huwiex iktar żmien li nlabalbu. Huwa żmien li dak li ġie imfassal jitwettaq. Wara li l-proċess ta’ diskussjoni li beda madwar 5 snin ilu kien wassal għal konkluzjoni fl-forma ta’ strateġija li tintegra l-ħidma ekonomika ma dik soċjali u ambjentali dan il-proċess ta’ diskussjoni tal-lum ser iwassal għal duplikazzjoni. F’pajjiż li kontinwament ġustament nilmentaw li la għandna riżorsi u l-anqas biżżejjed nies imħarrġa, l-inqas li konna nistennew huwa li naħlu l-ħin u riżorsi billi flok jitwettaq dak li ġie deċiz nerġgħu niftħu d-diskussjoni.

Nikkonkludi billi nħeġġiġkom biex tifhmu li l-aħjar triq il-quddiem hi illi nkunu kapaċi nintegraw l-isforzi tagħna. Dan hu dak li ppruvat tagħmel l-istrateġija nazzjonali dwar l-iżvilupp sostenibbli. Għandna nfittxu li nimxu f’dik it-triq billi nimplimentaw ir-rakkomandazzjonjiet tagħha. Forsi l-ewwel pass ikun li kif tistabilixxi l-istess Strateġija kull Ministeru jfassal pjan t’Azzjoni (avolja sentejn tard) biex iqiegħed fil-prattika dak li tipproponi l-istrateġja. B’hekk forsi tieqaf darba għal dejjem id-drawwa li żviluppat f’dan il-pajjiż illi r-rapporti u l-istrateġji iservu biss biex jitnisslu  rapporti oħra. Nittama biss li mid-diskussjoni tal-lum nagħrfu nibnu fuq dak li sar mhux biss b’rispett lejn min iddedika ħinu għall-pajjiż iżda fuq kollox biex nużaw il-ftit riżorsi li għandna l-aħjar mod.

Imma l-Kummissjoni Nazzjonali dwar l-Iżvilupp Sostenibbli jeħtieġ li tibda tiltaqa’ : ilha tlett snin wieqfa. Xhieda tal-impenn tal-Gvern favur l-Iżvilupp Sostenibbli.

Thoughts for an Environmental Policy

The government has published a number of policy documents for public consultation. Two deal with different aspects of water policy while a third deals with issues for a National Environment Policy.

Also of relevance is an Ernst & Young Report commissioned by the Malta Environment and Planning Authority on a 2008 Public Attitudes Survey. It is dated April 2010. Although recently published I do not recollect reading anything in the press about this survey. One of the conclusions of this survey should be an eye opener to policy makers as to the central importance which the Maltese public attaches to the environment.

In the 2008 Public Attitudes Survey it was concluded that 69 per cent of respondents held the view that the environment was as important as the economy. On the other hand 23 per cent of respondents considered that the environment was more important than the economy while only eight per cent considered the economy as being of overriding importance.

To my mind these are significant conclusions contrasting with current national policy which considers that the economy has an ­overriding priority over the environment. The Maltese public thinks otherwise: 92 per cent of respondents of the Mepa Public Attitudes Survey have understood that the economy should not be an overriding consideration in environmental policy formulation. Now this is what sustainable development is all about.

Contrary to what green-washers imply, being committed to sustainable development does not mean that one seeks to balance or mitigate environmental, social and cultural impacts of economic development. Sustainable development speaks another language altogether for which unfortunately there is still a lack of translators. Real commitment to sustainable development conveys the message that humankind does not own the earth. It shares the earth with other species together with which it forms part of one eco-system.

The way in which our society has evolved and is organised is such that it considers human activity as meriting overriding importance. In fact it is often stated that policies are anthropocentric. Both PN and PL environmental policies can be grouped in this category. AD together with other Green parties around the globe differs as it follows a eco-centric path. But then the ecology has no vote!

Sustainable development properly construed considers the need of an eco-centric environmental policy. This signifies that a holistic approach is applied through which impacts on the whole eco-system are considered.

Now this is completely different from the manner in which our society is accustomed to look at itself. An eco-centric approach leads us to take a long term view in contrast to the short-sighted view of our immediate interests. This does not only impact land use but also waste management, agriculture and fishing, light pollution, acoustic pollution, air quality, water resources, mineral deposits, transport policy, the protection of our ecological heritage and many other areas.

When one considers the above I cannot understand why the authors of the National Environment Policy Issues Paper ignored the National Sustainable Development Strategy when formulating the Issues Paper for public consultation. They considered the 2008 State of the Environment Report and the Parliamentary debate which ensued together with the Ernst & Young report above quoted as the basis for a discussion.

In so doing they ignored completely a consultation process spanning a number of years which answered most of the questions which the Issues Paper poses.

This is surely not a new way of doing politics. It is a way with which most of us are familiar as it does away with past achievements and seeks to start a fresh page, ignoring everything and everyone. Knowing that at least one of the drafters of the National Environment Policy Issues Paper was actively involved in the process leading to the National Sustainability Strategy, I must ask the obvious question: Is the Issues Paper the first step towards the scrapping of the National Sustainability Strategy?

The current Bill before Parliament which seeks to consolidate existing legislation on land use planning and the environment removes all references to the National Sustainable Development Commission. It was stated repeatedly that a separate legislative measure will be proposed dealing with issues of sustainable development. Yet to date this is nowhere in sight. Does this confirm that there have been second thoughts on the National Sustainability Strategy?

The Strategy should currently be in the process of implementation. Section 5 of the Strategy entitled “The Way Ahead” provides that ministers have to produce action plans for the implementation of the National Sustainable Development Strategy in their portfolio within 18 months from the adoption of the strategy.

The strategy was adopted by Cabinet more than 18 moons ago yet the action plans are nowhere in sight.

I have never had any doubt that this government is being consistent with its beliefs: it says one thing, but when push comes to shove it proceeds with doing something else.

published in The Times : August 14, 2010