Stormwater Management: entrenched incompetence

(photo by author dated 4 October 2018: overflowing sewer at Archbishop Gonzi Square Kalkara)

The Ministry for Public Works and Planning has embarked on another public consultation on stormwater management. I have lost count as to the number of times this exercise has been carried out along the years, directly or indirectly. At the end of the day the authorities continuously develop cold feet as they fail to address the basic issue: enforcement!

The consultation document points to a basic statistic which proves this point: only 36 per cent of dwellings have a water cistern. This notwithstanding that the matter has been codified in our legislation since 1880: that is since the approval of Ordinance I of 1880 by the British colonial government. Before that date most buildings had a water cistern. Everyone was then aware that water in Malta is scarce and all sought to do their part in collecting rainwater. Nowadays no one cares, as long as there is water in the tap!

The consultation document, entitled Green Stormwater Infrastructure Guidance Manual, drawing on Census 2011 information, further points out that it is in the sector of apartment blocks that one finds the largest number of infringements in non-provision of water cisterns. Compliance ranges from 80 per cent in the case of villas to 4 per cent in the case of apartments. On a geographic level it is probably no surprise that Gozo is only 25 per cent compliant!

As is also pointed out by the consultation document the present state of water harvesting is the result of a lack of adequate enforcement. I would emphasise that it is a case of an incompetent, almost inexistent, enforcement. It is very easy to point at developers who try to avoid excavating or constructing water cisterns, reducing his costs and increasing profits. They have a number of accomplices, who ignore this fact and then proceed to certify works as having been completed satisfactorily. In these instances, compliance certificates are issued just the same by the Planning Authority. Likewise, the Water Services Corporation authorises the connection of foul water drains from such developments to the public sewer without generally bothering to ascertain as to where rainwater is being collected or directed.

Rainwater is to be collected in a water cistern which should be fitted with an overflow which directs excess rainwater onto the street. Instead, a number of developments direct all rainwater directly onto the street. At times, unfortunately increasing in frequency, rainwater is disposed of directly into the public sewer.

This is the cause of flooded streets and overflowing sewers with which we are very familiar during and after heavy rainfall.

Enforcement hits hard as non-compliance is widespread. This is the primary reason as to why no government has seriously embarked on tackling this problem. In the past government, instead of addressing the root cause of the problem, that is the non-provision of water cisterns, embarked on the drilling of a number of tunnels to facilitate the collection of rainwater and its dumping into the sea. Millions of euros in EU funds were utilised in this exercise, literally money down the drain.  Notwithstanding this misapplication of EU funds, the problem of flooded streets and overflowing sewers is still a common occurrence during and immediately after heavy rainfall.

Having expertly drawn up codes and manuals is generally helpful. It is however no substitute for clear indiscriminate enforcement: no exceptions allowed. It is what we lack. It is the result of clientelism forming an integral part of the philosophy of government and administration. It is a political disease which is not limited to stormwater management but as we all know is spread throughout the public administration.

If those employed to implement our laws, rules and regulations get on with their jobs, the problem of stormwater management would be substantially smaller, and definitely quite manageable!

The basic problem which the consultation document does not discuss is that there is no political will to ensure that simple rules on rainwater harvesting are observed by all. The rest follows.

published in The Malta Independent on Sunday : 3rd July 2022

L-ilma tax-xita: l-inkompetenza tal-awtoritajiet

Il-Ministru tal-Finanzi Edward Scicluna, fl-aħħar diskors tal-Baġit qalilna : “Il-Gvern huwa wkoll kommess li jkompli jaħdem biex jitnaqqas ir-riskju tal-għargħar f’pajjiżna. Għaldaqstant, se jsiru studji dettaljati sabiex jiġu żviluppati aktar miżuri li jistgħu jnaqqsu dan ir-riskju filwaqt li jimmassimizzaw l-użu tal-ilma tax-xita.”

Edward Scicluna bla dubju jaf li bħala riżultat tat-tibdil fil-klima l-maltempati kif ukoll ix-xita qed ikunu ta’ natura iktar intensivi. Meta tinżel ix-xita, b’mod partikolari meta tkun qawwija, l-infrastruttura tagħna ma tistax tlaħħaq. Imma minbarra l-impatti kkawżati mill-klima għandna fuqna ukoll il-piz u r-riskji kkawżati minn regolaturi nkompetenti.

F’Malta għal dawn l-aħħar 138 sena, il-liġi pprovdiet biex ikun hemm l-obbligu li jkollna l-bjar għall-ilma tax-xita fid-djar. Il-qisien tal-bjar varja tul is-snin. Originalment il-qies kien dipendenti fuq il-qies total tas-sulari kollha mibnija. Illum il-ġurnata dan tnaqqas biex ikun relatat mal-qies tal-art mibnija.

Sfortunatament dawn ir-regoli ftit huma osservati. Din mhiex storja li bdiet illum, ilha għaddejja snin twal possibilment sa mis-snin 60, żmien meta l-industrija tal-bini kienet għaddejja b’rankatura kbira. Jiena niftakar, meta kont għadni student, ftit snin ilu mhux ħażin, kont rajt rapport li kien tħejja għall-Gvern Malti minn esperti mibgħuta mill-Ġnus Magħquda. Dakinnhar diġa kien ċar li waqt u wara maltempati qawwija l-ilma għaddej mis-sistema tad-drenaġġ kien jiżdied b’mod astronomiku u dan billi ħafna ilma tax-xita flok ma jinġabar fil-bjar kien qed jintrema fid-drenaġġ. Is-sitwazzjoni, minn dakinnhar, marret ħafna għall-agħar!

Flok mal-ilma tax-xita jinġabar fil-bjar, f’ħafna każi qed jintrema fit-toroq, inkella direttament fis-sistema tad-drenaġġ pubbliku. Ammont enormi ta’ ilma tax-xita li nistgħu nutilizzaw qed jintrema. Ħafna, jekk jużaw l-ilma tax-xita jistgħu jnaqqsu b’mod drastiku l-kontijiet tal-ilma!

Meta l-ilma tax-xita jintrema fid-drenaġġ, dan mhux biss ifur fit-toroq tagħna imma minħabba li jgħabbi l-impjant tal-purifikazzjoni tad-drenaġġ b’ammont zejjed ta’ ilma iżid b’mod konsiderevoli l-ispejjes għat tmexxija tal-impjant.

Il-parti l-kbira tal-ħtija għal dan trid tinġarr minn dawk li jiżviluppaw il-propjetá. Anke l-Gvern, direttament, kif ukoll permezz tal-aġenziji tiegħu, fil-passat riċenti kien responsabbli għall-iżvilupp ta’ housing estates li fihom ma tinġabarx qatra ilma tax-xita!
Hu fatt magħruf li fejn żvilupp residenzjali jkun fih garaxxijiet parzjalment jew kompletament taħt il-livell tat-triq ftit għandna bjar għall-ilma tax-xita. L-Awtoritá tal-Ippjanar hi responsabbli biex tassigura li l-kundizzjonijiet tal-permessi tal-iżvilupp ikunu osservati: dawn kważi dejjem jinkludu l-obbligu li jinbena bir biex fih jinġabar l-ilma tax-xita. Imma ħafna drabi, għall-Awtoritá tal-Ippjanar, qiesu ma ġara xejn jekk il-bir ippjanat jibqa’ fuq il-karta.

Min-naħa l-oħra, l-Korporazzjoni għas-Servizzi tal-Ilma (WSC) matul dawn l-aħħar snin assumiet ir-responsabbiltá għas-sistema kollha tad-drenaġġ, liema responsabbiltá qabel kienet f’idejn id-Dipartiment tad-Drenaġġ. Din ir-responsabbiltá tinkludi l-għoti tal-permess biex bini ġdid jiġi imqabbad mas-sistema tad-drenaġġ.

Il-Korporazzjoni għas-Servizzi tal-Ilma x’verifiki qed tagħmel li l-katusi tad-drenaġġ biss qed jitqabbdu mas-sistema pubblika tad-drenaġġ? Qed isiru verifiki li m’hemmx katusi tal-ilma tax-xita ukoll? It-tweġiba teħduha waħedkom fit-toroq tagħna f’ġurnata ta’ xita qliel. Ħadd mhu jagħmel verifika dwar dak li qed jiġri.

Dan kollu jwassal għall-konklużjoni li waqt li l-ħtija ewlenija għall-qagħda preżenti hi tal-industrija tal-bini, għax, iktar le milli iva ma tipprovdix bjar għall-ilma tax-xita fi żvilupp ġdid, il-ħtija mhiex tagħha biss. L-awtoritajiet u d-dipartimenti tal-Gvern għandhom ukoll iġorru s-sehem tagħhom tar-responsabbiltá minħabba li ma onorawx l-obbligi regolatorji tagħhom. L-Awtoritá tal-Ippjanar u l-Korporazzjoni għas-Servizzi tal-Ilma (u dawk li ġew qabilhom) setgħu waqqfu dan l-abbuz, imma ma għamlu xejn.

Meta jkollna xita qliel, jew xita għal ħin twil, diffiċli tgħaddi minn ċertu toroq f’Malta u Għawdex. Dan hu sors ta’ periklu u fil-fatt id-Dipartiment tal-Protezzjoni Ċivili ikun okkupat ħafna f’dawn iż-żminijiet jgħin lil min ikun f’diffikulta minħabba l-għargħar.
Fondi tal-Unjoni Ewropea ntużaw biex jiġu ffinanzjati mini taħt l-art biex l-ilma tax-xita fit-toroq jinġabar u jintrema l-baħar. Fondi pubbliċi intużaw biex jinħbew irregolaritajiet li sar mis-settur privat. Mhux biss, imma ntużaw ukoll biex riżors prezzjuż jintrema. Dawn il-fondi setgħu intużaw ferm aħjar kieku intużaw biex l-ilma inġabar u nħażen fl-ibliet u l-irħula tagħna, flok ma ntrema.

Il-parir tiegħi lil Edward Scicluna hu li, flok ma jinħlew iktar fondi pubbliċi, għandu jassigura ruħu li l-Awtoritá tal-Ippjanar u l-Korporazzjoni għas-Servizzi tal-Ilma jwettqu l-obbligi regolatorji tagħhom. Meta jagħmlu dan, parti mdaqqsa mill-problema tal-ilmijiet fit-toroq tagħna tisparixxi.

 

Ippubblikat fuq Illum: 4 ta’ Novembru 2018

Rainwater: the cost of incompetence

In his latest Budget speech, Finance Minister Edward Scicluna informed us that more studies will be carried out to identify flooding risks, simultaneously seeking to maximise the use of rainwater.

Edward Scicluna is aware that, as a result of climate change, storms are more intense than ever. When it rains, it pours, and our infrastructure is not capable of handling the resulting rainwater. To add to the impact of climate change, we also have to deal with the risks created as a direct result of incompetent regulators.

For the past 138 years,legislation in Malta has specifically provided for the construction of water cisterns in buildings, primarily residential ones. The dimensions of these water cisterns varied over time. Originally, they were related to the floor area of the residence but in the recent past, the required volume was reduced to be related to the footprint of the building.

These regulatory provisions are, however, more honoured in the breach, even when reduced. This is not a recent phenomenon. Regulatory control in Malta has been in steep decline since the building boom of the 1960s. I remember, while I was still a student – many moons ago- leafing through a UN expert-financed report penned in the late 1960s which, even then, had measured the significant increase in foul water in our sewers during intense rainfall, clearly indicating that too much rainwater was going to waste notwithstanding the collection obligations. The situation has not improved since!

Instead of being collected in rainwater cisterns, in an ever-increasing number of cases rainwater is discharged directly onto our roads or into the public sewers. Large volumes of rainwater, which can be utilised for various purposes, are being wasted. Its use domestically could substantially reduce water bills.

When rainwater is discharged into our public sewers, not only does the water overflow onto our streets, but it also increases the costs of sewage purification unnecessarily.
The major culprits are a substantial portion of the developers of blocks of flats and maisonettes. The government, both directly, as well as through its agencies, has also (in the recent past) been responsible for the development of housing estates without providing for the collection of rainwater.

In particular, it is common knowledge that in cases where basement or semi-basement garages are constructed, the duty to provide for the collection of rainwater is very rarely complied with. The Planning Authority (PA) is responsible for determining and ensuring the observance of the conditions of development permits which, in most cases, specify the required capacity of a rainwater cistern.

Over the years, the Water Services Corporation (WSC) has taken over responsibility for the management of the public sewers from the former Drainage Department. This responsibility includes authorising the owners of newly- constructed properties to connect the drains with the public sewer. Is the WSC verifying that it is only the drains that are connected and, in particular, that rainwater pipes are not connected to the public sewer too? The obvious answer is provided by our streets on a rainy day. Clearly, no one is bothering to check what is connected to the public sewer.

This leads to the conclusion that, while the culprit for the present state of affairs is the building industry because, more often than not, it does not provide for rainwater storage in new developments, it is not the only one to blame. The authorities and government departments must take a substantial share of the blame for not complying with their regulatory responsibilities. The PA and the WSC could have stopped the abuse, but they did not.

A number of areas are practically out of bounds whenever heavy or continuous rain hits the Maltese islands. This is a source of danger and, in fact, the Civil Protection Department is heavily involved in assisting residents or motorists who are trapped as a result of flooding.

Money made available by the EU has been used to fund a project for the construction of underground tunnels, as a result of which rainwater from our streets and roads is being collected and discharged into the sea. Public funds have been used to cover up private irregularities.

The EU funds utilised in the construction of these tunnels have been used to squander a very precious resource. European taxpayers’ money has also have been flushed down the drain. This could have been put to a much better use had it been applied to address the lack of adequate rainwater harvesting in our towns and villages.

My advice to Edward Scicluna is that before wasting any more public funds he should ensure that the Planning Authority and the Water Services Corporation carry out their regulatory responsibilities. When they do, a considerable part of the problem of the flooding of our streets will disappear.

published in The Malta Independent on Sunday: 4 November 2018

Harvesting rainwater

At the time of writing the average rainfall in Malta from 1st September 2014 to date is recorded at 442.4 mm. The actual rainfall varies from a high of 529.6mm recorded at Selmun to a low of 373.7mm noted at Valletta. With still some months to go, it seems that precipitation in the Maltese islands during the current year will shortly exceed the average annual precipitation of 553.12mm, computed by Charles Galdies in his National Statistics Office publication entitled The Climate of Malta: statistics, trends and analysis 1951-2010. It will however be far short of 955.62mm, the maximum recorded precipitation in Malta which was recorded at Luqa Airport in 1951.

Since 1880, legislation in Malta has specifically provided for the construction of water cisterns in buildings, primarily residential ones. The dimensions of these water cisterns varied over time. Originally they were related to the floor area of the residential building. Recently, the required volume was reduced to be related to the footprint of the building.

These regulatory provisions are however more honoured in the breach, even when reduced. This is not a recent phenomenon. Regulatory control in Malta has been in decline since the 1960s building boom.

Instead of being collected in rainwater cisterns, in an ever increasing number of cases, rainwater is discharged directly onto our roads, or else into the public sewers. As a result, navigating some of our roads during or immediately after heavy rainfall is a dangerous exercise.

This is a case of water literally going down the drain. Large volumes of storm water, which can be utilised for various purposes, are being wasted. Much has been written about the potential use of harvested rainwater. Its use domestically can substantially reduce water bills.

It is also an issue of civil protection. Large quantities of rainwater in our streets, at times moving at an excessive velocity, are a danger to life and limb. Fortunately, it is very rare for people to lose their life in storms in Malta, but damage to property is a more frequent occurrence.

When rainwater is discharged into our overburdened public sewers, not only does the water overflow onto our streets, but it also increases the costs of sewage purification unnecessarily. These costs are recovered through our water bills. Hence, in the end, we all pay the costs of this abuse, irrespective of whether we are participants or not.

The major culprits are a substantial portion of the developers of blocks of flats and maisonettes. The government, directly, as well as through its agencies, has also been responsible for the development of housing estates without providing for rainwater harvesting.

In particular, it is common knowledge that in cases where basement or semi-basement garages are constructed, the duty to provide for rainwater harvesting is very rarely complied with. Since 1992, MEPA has been responsible for determining and ensuring the observance of the conditions of development permits, which in most cases, specify the required capacity of a rainwater cistern.

The Water Services Corporation (WSC) has during the last years, taken over the responsibility for the management of the public sewers from the former Drainage Department. This responsibility includes authorising owners of newly- constructed properties to connect the drains with the public sewer.

Is the WSC verifying that it is only the drains that are connected and, in particular, that rainwater pipes are not connected to the public sewer too? The obvious answer is provided by our streets on a rainy day. No one is bothering to check what is connected to the public sewer . This leads to the conclusion that, while the culprit for the present state of affairs is the building industry as, more often than not, it does not provide for rainwater storage in new developments, it is not the only one to blame. The authorities and government departments must take a substantial share of the blame for not shouldering their regulatory responsibilities. They could have stopped the abuse, but they did not.

A number of areas are practically out of bounds whenever heavy or continuous rainfall hits the Maltese islands. This is a source of danger and, in fact, the Civil Protection Department is heavily involved in assisting residents or motorists who are trapped as a result of flooding. The Birkirkara local council had, some years back installed a storm warning system to alert residents and passers-by that, “danger was on the way”! Public authorities in Malta, unfortunately, have developed the habit of dealing with the effects but continuously ignore the cause of flooding!

Monies made available by the EU have been used to fund a project for the construction of underground tunnels through which it is planned to collect rainwater from our streets and roads and to discharge most of the collected storm water into the sea.

The EU funds utilised in the construction of these tunnels have been utilised to squander a very precious resource. European taxpayers’ monies too have been flushed down the drain. They could have been put to a much better use if they had been applied to address the lack of adequate rainwater harvesting in our towns and villages.

We have been inundated with political speeches lauding sustainability and sustainable development. However, when push comes to shove, it is more than amply clear that this is just a case of some Members of Parliament showing off a newly-acquired vocabulary they have not yet understood. In 2015, Malta still lacks a sustainable water policy.

Published in the Malta Independent on Sunday : 22 February 2015