WEEE Responsibility

published on 23 May 2009

by Carmel Cacopardo

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The Nationalist Party’s and Alternattiva Demokratika’s 2008 electoral manifestos proposed the free distribution of energy-saving light bulbs in order to encourage energy conservation but with a difference!

Prior to that, in London, the then Labour mayor Ken Livingstone had, as part of the London Climate Change Action Plan in January 2008, launched a “light bulb amnesty” as a result of which each London household could exchange a traditional incandescent light bulb for an energy-e fficient one.

The public in Malta should be informed not only of the benefits but also as to the advisable precautions relative to the use of these energy-saving light bulbs or compact fluorescent lamps (CFLs).

The use of CFLs, notwithstanding their price, saves about 75 per cent of electrical energy used for lighting purposes by traditional bulbs.

An educational campaign relative to breakages and disposal of CFLs is essential.

Damage to the CFL can release mercury dust to air. In other countries users have been advised that they are to vacate and ventilate rooms for about 15 minutes when CFL breakages occur. This is essential to avoid inhaling mercury dust. It is imperative that in homes and, in particular, in areas where children and the elderly and/or sick people gather, those in charge are aware as to the measures they should take. Advice is also called for as to the cleaning of the resulting breakages and the manner in which the damaged CFL is to be disposed of.

It is to be borne in mind that, due to their containing about four milligrams of mercury dust per light bulb, CFLs are subject to the provisions of the EU WEEE Directive (Waste from Electric and Electronic Equipment). This directive has been transposed into Maltese legislation through Legal Notice 63 of 2007 but it is not yet being implemented.

The EU established the framework for dealing with hazardous waste resulting from electric and electronic equipment and applied thereto the principle of producer responsibility. This means that producers and distributors (irrespective of the selling technique used) are directly responsible for the handling of this type of waste.

The government has the role of a regulator, ensuring that EU legislation is adhered to within Maltese territory. Being an EU member in my view, at least, signifies this much in addition to harping on the availability of EU funds, which assist us in attaining objectives of a better quality of life. The WEEE Directive had to be implemented in various stages between 2004 and 2006 and the Maltese government was in breach of its provisions, so much so that the EU Commission had already initiated infringement procedures against Malta due to the delay in transposing it into Maltese law.

The recently-published update to the Maltese Waste Management Strategy for public consultation postponed once more consideration of the plans for the implementation of the WEEE Directive in Malta.

Within this context, the placing of over one million CFLs in one go on the market without having in place a waste management strategy for hazardous waste is surely not environmentally responsible. While addressing the issue of energy consumption, the government is creating an equally serious problem by encouraging the use of hazardous materials without having first ensured that the required waste management infrastructure is in place and functioning.

The responsibility is not just the government’s. It has to be equally shouldered by producers and distributors who, unless they act fast, may eventually have to carry the can and pay the fines due for not assuming their producer responsibilities. Taxpayers’ monies should not be used to bail out those who have failed to shoulder their responsibilities.

Those who have advised local distributors that the management of hazardous waste is a government responsibility would do well to reconsider their position. This is an area the EU has assigned to the private sector, which must ensure that the impacts of all products it places on the market are addressed. In fact, the WEEE Directive, in addition to responsibility for today’s hazardous waste, also assigns to producers and distributors responsibility for historical waste, that is responsibility for WEEE waste generated prior to the implementation of the directive.

The point at issue is clearly the eco contribution payable on a number of electric and electronic products. Maltese business is correct in complaining that it has been shouldered with a double responsibility: responsibility for WEEE waste and simultaneous payment of eco contribution. This, however, does not exonerate businesses from putting in place a collection system for WEEE waste (including CFLs).

By failing to revisit the eco contribution regime, the government is obstructing business from moving on to shoulder its producer responsibilities. Further procrastination will not make matters any easier. It is in everybody’s interest that business conforms to its WEEE responsibilities and for that to happen the government must get out of the way.

Addressing Our Environmental Deficit

published on Sunday 27 July 2008

by Carmel Cacopardo

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 In his address to Parliament last May, the President had stated: “The government’s plans and actions are to be underpinned by the notion of sustainable development of the economy, of society and of the environment. When making decisions today, serious consideration will be given to the generations of tomorrow.”

In December 2006, the National Sustainability Commission had drawn up the National Sustainable Development Strategy. Having been approved by Cabinet, it is appropriate that the pre-budget document just published ignites the debate on its implementation. The strategy is a blueprint for action representing a holistic perspective as to how this country should be administered. Its eventual handling will in due course give a clear indication of the government’s real views on sustainable development.

Malta’s energy policy is undoubtedly up for an upheaval. Due to the absence of strategic planning over the years, Malta is one of the few countries without any significant alternative energy generated. Other countries identified their vulnerability because of fuel oil dependency years ago and took action. Denmark has since built up its wind energy industry from scratch since the oil crises in the 1970s and is now a world leader. In 2005 Denmark generated 18.5 per cent of its electrical energy needs through wind.

The pre-budget document identifies near shore wind technology as the next step forward, contributing 95MW of wind energy or seven per cent of Malta’s projected electricity demand in 2010. The shortfall in meeting the EU target of having 10 per cent of electricity demand met by alternative energy is planned to be met with wind turbines at other exposed land sites and industrial estates, including those to be identified within the framework of the eco-Gozo project.

The pre-budget document focuses on macro-generation and does not give sufficient weight to micro-generation of energy, both with small wind turbines as well as with photovoltaic panels. It must be borne in mind that micro-generation if adequately motivated could add up to a substantial amount of energy generated through alternative technology. In addition to residential application (not flats or maisonettes!), schools and public buildings could be ideal sites for the micro-generation of energy. Moreover, one can consider fitting micro-turbines to the structures of the hundreds of disused windmills (water pumps) that pepper the countryside. These windmills were strategically located by our ancestors in wind-prone areas and are now an integral part of the Maltese countryside.

The pre-budget document rightly refers to energy generated through waste. It speaks of the generation of electricity using animal waste through biogas in a facility to be constructed in the north of the island. This is a long overdue initiative. However, I believe that it is badly conceived. The lessons that should have been learnt following the Sant’ Antnin debacle seem to have been forgotten.

The point at issue is whether one facility covering the whole island is sufficient or desirable. Would it be a good idea to transport animal manure across the whole island to a facility in the north?

One point resulting from the public debate relative to the Sant’ Antnin waste recycling plant was the applicability of the proximity principle. The required plant should be sited as close as possible to the source of the waste being processed. This had led to the Sant ‘Antnin projected operation itself being scaled down to deal with one third of the islands’ waste. The rest, it was stated, should be processed on other sites (possibly two) that have not yet been identified! These other sites should be used for the production of biogas too and they should be identified in a location as close as possible to those areas that have the largest number of animal farms in order to minimise the movement of animal waste. Knowing that a number of these farms are sited very close to each other should make matters easier for our waste management planners.

Bad planning brings out another sore point, which was not discussed in the pre-budget document: namely the management of our water resources. Groundwater (a ‘free’ source of freshwater) still accounts for 40 per cent of our potable water supply. Groundwater accounts for the greater part of the water used by agriculture, the construction sector, landscaping activities and various other industrial and commercial concerns, including some hotels which are supplied by bowsers. However, as a result of over-extraction, the quality of the water in the aquifer is becoming saltier by the day and will become useless within our lifetime.

Yet, illegal extraction of ground water continues unabated and the authority responsible for the sustainable use of this precious resource (the Malta Resources Authority) persists in not taking any concrete action. The recent increase in the surcharge on mains water will inevitably result in a rush to drill more boreholes and extract more groundwater, with the consequence that our aquifer will die an earlier death.

Within this context, the construction of wastewater treatment plants treating urban wastewater and discharging it directly into the sea assumes an alarming relevance. A country whose natural water resources are not sufficient for its use ought to manage its water resources in a much better way. It certainly ought not to permit the illegal extraction of water or the discharge of treated water into the sea. The siting of the wastewater treatment plants in Malta and Gozo is such that discharging treated water into the sea is a foregone conclusion. This decision, undoubtedly arrived at based on the original siting of the sewage outfalls, ignores the possibilities to reuse the treated water, either as a second-class source or (with additional treatment) as potable water. Other developed countries, notably Singapore, produce an ever-increasing percentage of their potable water in this manner. This issue is ignored in the pre-budget report.

All this could easily have been prevented with a proper water management planning strategy, which, instead of large-scale plants for wastewater treatment, could have identified a number of smaller sites along the sewer route on the islands for the construction of small packaged wastewater treatment plants. These would have provided ample treated effluent where and when required for agricultural use, landscaping and other uses not requiring water of potable quality – at little or no distribution costs. The widespread availability of this water would have substituted the need to extract groundwater and facilitated the required enforcement action on its illegal extraction.

The total costs would have been substantially less. By costs I do not just mean economic ones but also the ecological cost of losing a strategic resource (the aquifer), which loss will have to be borne by future generations.

As indicated in the public hearings carried out by Minister Tonio Fenech, the pre-budget document deals with the sustainability of localities, rightly linking this issue to the proposed reform of local councils. It refers to the need for localities to draw up a Local Sustainable Development Strategy. In environmental management, we normally consider this within the Local Agenda 21 process currently espoused by thousands of localities around the globe: think global act local.

The sustainable localities proposal is undoubtedly well intentioned, and if adequately planned and applied can lead to positive results. The difficulty that will arise is that of economies of scale. Our localities vary substantially in size: from the largest – Birkirkara, to the smallest – San Lawrenz in Gozo. I believe that the best manner to apply Local Agenda 21 in Malta would be on a regional level. It would entail the setting up an additional level of local government that could be made up of all the local councils in the region. One possibility for the identification of regions would be to follow the boundaries of the seven local plans. These regions could be the channel for drawing up a Local Agenda 21 in conformity with national policy and strategies, which allow ample room for adequate planning. The proposed Conference on Local Sustainable Development would be a good start.

The basic point at issue in all deliberations is to view the economy as a tool at the service of the eco-system rather than as master of all. Adopting sustainable development as a policy instrument is no easy task. It entails taking a holistic view of public administration and its consequences. It signifies that national policy and administrative action need to have a continuous long-term view.

Economic policy generally takes on board social policy. It now needs to ensure that it is subservient to the eco-system because at the end of the day the eco-system is the source of our being. It is only at this point that we will be in a position to settle our country’s accumulated environmental deficit!