Il-plastik f’ħajjitna

L-Awtorità għall-Ambjent u r-Riżorsi (ERA) bħalissa qed tieħu ħsieb konsultazzjoni pubblika dwar il-plastik li jintrema wara li jkun intuża darba waħda biss. Dan jikkuntrasta mal-istrateġija tal-Unjoni Ewropea li tħares lejn il-plastik b’mod iktar wiesa’ u olistiku.

L-argument bażiku hu li t-tfassil tal-politika tagħna trid tħares fit-tul u tqis l-impatti f’kull stadju tal-implimentazzjoni. Dak li hu deskritt bħala life-cycle thinking. Dan ifisser, b’mod partikolari, li fil-proċess tal-manifattura u l-użu tal-materjali, l-impatti ambjentali f’kull stadju tal-użu ta’ prodott ikun ikkunsidrat u analizzat fl-istadju l-iktar bikri possibli. Dan jibda mill-għażla tal-materjal użat, inkluż il-mod kif dan hu prodott u jibqa’ sejjer sal-mument li l-ħajja tal-oġġett tiġi fi tmiemha u allura jintrema jew inkella jkun ipproċessat mill-ġdid għal użu ieħor.

Id-dibattitu tal-lum hu dwar ir-rimi ta’ plastik wara li dan ikun intuża’ darba waħda (single-use plastic). Dan hu s-sors tal-ġenerazzjoni ta’ ammont sostanzjali ta’ skart li jeħtieġ li jkun indirizzat b’mod urġenti minħabba li żdied b’mod astronomiku f’dawn l-aħħar snin. Id-dokument li l-ERA ħarġet għall konsultazzjoni pubblika hu intitolat : Single-Use plastic products Strategy for Malta. (Bl-Ingliż biss, għax għall-ERA l-Malti qiesu ma jeżistix.) Min-naħa l-oħra, id-dokument tal-istrateġija tal-Unjoni Ewropea hu intitolat : A European Strategy for Plastics in a Circular Economy.

Id-dibattitu lokali hu indirizzat lejn it-tnaqqis tal-iskart iġġenerat mill-plastik u dan f’kuntrast mad-dibattitu Ewropew li għandu ħarsa iktar wiesgħa u jiffoka fuq ir-rwol tal-ekonomija ċirkulari. Dan il-kuntrast hu wieħed sinifikanti u jixhed kemm it-tfassil tal-politika lokali hi limitata għall-ovvju u ma tħarisx biżżejjed fil-fond ta’ dak li qed niffaċċjaw.

L-iktar ħaġa ovvja dwar il-plastik hi l-ħtieġa li jonqos il-ġenerazzjoni tal-iskart tal-plastik. F’dan l-aspett id-dokument konsultattiv Malti jindirizza b’mod adegwat il-ħtieġa li jonqos il-konsum tal-plastik u li titjieb l-ekonomija u l-kwalità tar-riċiklaġġ. Din l-istrateġija tidentifika l-problema, konsistenti f’oġġetti li nużaw kontinwament. Din hi s-soċjetà li tinqeda u tarmi (the disposal society): tazzi, straws, frieket u skieken, fliexken u kontenituri tal-ikel . Hi l-imġiba tagħna li għandha tkun fil-mira biex ma nibqawx nużaw oġgetti għal darba u narmuhom. Mhiex triq faċli għax is-soċjetà konsumista mexxietna f’din it-triq.

Ironikament fost il-proposti li hemm fid-dokument konsultattiv Malti hemm indikat miżuri ta’ diżinċentiv ekonomiku kif ukoll miżuri fiskali. Dan forsi jfakkar lil uħud mill-qarrejja dwar l-eko-kontribuzzjoni li kienet introdotta (kważi) bl-addoċċ mill-amminsitrazzjoni mmexxija minn Lawrence Gonzi fl-2005. Din il-miżura fiskali kienet introdotta biex (fost affarijiet oħra) jkun indirizzat l-iskart iġġenerat mill-plastik li nużaw darba: ewlenija fosthom il-fliexken tal-plastik.

L-eko-kontribuzzjoni kienet tneħħiet mill-Gvern tal-lum. Ikun interessanti kieku jkollna iktar informazzjoni dwar x’inhuma dawn il-miżuri fiskali kkontemplati bħala parti mill-istrateġija lokali dwar il-plastik. Għax mill-qari tad-dokument konsultattiv ma naslu mkien.

Waħda mill-miżuri prattiċi u tajba li qed ikunu ikkunsidrati biex tkun indirizzata l-ħtieġa li ma jintremewx fliexken tal-plastik, u li iktar minnhom jinġabru għar-riċiklaġġ, hi skema ta’ depositu fuq il-fliexken tal-plastik, liema depożitu tieħdu lura meta tirritorna l-flixkun. Meta din l-iskema tkun implimentata bla dubju tista’ tagħti riżultati tajbin. Lura lejn is-snin 2004/5 l-istess proposta kienet saret minn produtturi tal-minerali f’Malta bħala alternattiva għall-introduzzjoni tal-eko-kontribuzzjoni. Sfortunatament il-proposta kienet skartata minn rappresentanti tal-ħwienet għax ma riedux ikollhom x’jaqsmu mal-iskart.

Kieku bħala pajjiż fettaqna inqas fil-passat, illum forsi qegħdin f’posizzjoni aħjar biex nindirizzaw l-iskart ġġenerat mill-plastik. Fil-fatt ħlejna ħmistax-il sena għax il-Gvern dakinnhar kien ċeda.

L-istrateġija tal-Unjoni Ewopea dwar il-plastik tmur lil hinn mill-iskart. Għandna bżonn viżjoni ċara dwar is-sehem tal-plastik fl-iżvilupp tal-ekonomija ċirkulari, punt li l-istrateġija lokali ma teżaminax. L-isfidi jeħtieġ li nittrasformawhom f’opportunitajiet b’mod li nagħmlu l-aħjar użu possibli mir-riżorsi li għandna għad-disposizzjoni tagħna.

Ħarsu lejn in-natura: din ma taħlix. Il-weraq li jaqgħu mis-siġra jkunu assorbiti mill-ħamrija bħala sors ta’ nutrijenti u b’hekk il-weraq ikunu rriċiklati. L-ekonomija ċirkulari hi imfassla fuq dak li tgħallimna n-natura li taħdem b’mod ċikliku.

Din hi t-triq ‘il-quddiem. Għandna bżonn ta’ viżjoni strateġika mhux biss dwar x’ser nagħmlu fuq l-iskart ġġenerat mill-plastik imma iktar dwar kif nistgħu u għandna nużaw il-plastik biex nibnu ekonomija ċirkulari.

 

Ippubblikat fuq Illum : Il-Ħadd 9 ta’ Ġunju 2019

Plastic in our life

The Environment and Resources Authority (ERA) is currently engaged in a public consultation regarding single use plastic. This contrasts with the more wide-ranging EU strategy which considers plastic in a wider and more holistic context.

The basic issue to be addressed is the need to entrench life-cycle thinking in our policy making. This signifies, in particular, that in the manufacture and use of materials, the environmental impacts at each stage of a product’s “life” are considered and analysed at the drawing board. This is a process which runs from the very resources used in the production right to the disposal or reuse of the product.

The current debate is concerned with the disposal of single use plastic which is the source of a waste stream that needs to be urgently addressed as it has increased exponentially over the years.

The public consultation document issued by the ERA is entitled: Single-Use plastic products Strategy for Malta. On the other hand, the EU strategy document is entitled A European Strategy for Plastics in a Circular Economy.

The local debate is being channelled towards addressing the minimisation of waste in contrast to the EU debate which is more wide ranging, focusing on the role of the circular economy. The contrast is significant and identifies the lack of depth in local policy making.

The most obvious issue with plastic is the need to reduce its contribution to the waste stream. In this respect, the Maltese consultation document adequately addresses the need to reduce consumption as well as the improvement of the economics and quality of recycling. It identifies a number of items in daily use which are part of the problem. Essentially it focuses on the disposal society with disposable cups, straws, cutlery, bottles and food containers topping the list. We have to address our behaviour and opt more often to use non-disposables! It is an uphill struggle to avoid moving along the road we have been led for so long.

Ironically, among the policy options which the Maltese consultation document highlights are economic disincentives and fiscal measures. This might remind readers of the “eco-contribution” which was introduced in a haphazard manner by the Lawrence Gonzi administration way back in 2005. This fiscal measure was brought about in order to address the waste generated by single-use plastics: primarily  plastic water bottles.

The eco-contribution was scrapped by the current government. It would be interesting if we could have more information as to what fiscal measures are being contemplated as part of the implementation process of the local plastics strategy because through a perusal of the consultation document, we are none the wiser.

It would be pertinent to point out that one of the practical measures being contemplated to address head-on the recycling of plastic bottles is a plastic packaging deposit scheme. If implemented, this would go a long way to addressing the plastic waste stream. Way back in 2004/5 this same proposal was put forward by beverage producers in Malta as an alternative to the introduction of the eco-contribution. The proposal was unfortunately shot down by representatives of retailers as they did not want to deal with waste.

Less bickering in the past would have placed the country in a much better position to address plastic waste today. Fifteen years of productive work have been lost as the then government did not have the will to proceed.

The EU plastics strategy goes much further than addressing the plastic waste stream. We require a clear vision on the role of plastics in the circular economy, a point which is missed by the local strategy. Challenges must be transformed into opportunities through which the use of resources is maximised.

Take a look at nature. It does not waste anything. The leaves which a tree sheds are taken up by the soil as a source of nutrition and recycled. The basic idea of the circular economy is modelled on nature, which works in a cyclical manner.

This ought to be the way forward. We need a strategic vision not just on how to deal with plastic waste, but more on how the use of plastic could contribute to the circular economy.

 

Published in The Malta Independent on Sunday : 9th June 2019

Karmenu Vella and the plastic tax

Karmenu Vella, EU Commissioner for the Environment, is enthusiastic about the possibility of a plastic tax being introduced throughout the EU. In his view, this tax – if properly designed – could be one of a number of tools for delivering environmental objectives as well as providing budgetary income. Planet Earth is drowning in plastic.

Vella made these comments in an interview published on Euractive last week on the subject of the EU’s new plastics strategy.

We have been there before and maybe it is time to consider the matter once more in Malta. Some 10 years ago in Malta we had an environmental tax which was known as an “eco-contribution”. It was a valid proposal, badly designed and arrogantly implemented. The lessons learnt from that exercise could, if properly analysed, lead to the development of effective policy tools addressing the generation of waste in the Maltese islands. Policies should be well thought out and not developed as a result of panic – as is clearly the case with the current government incineration proposal.

Ten years ago, the eco-contribution tried to address the generation of plastic waste including “single-use plastic”. This is one of the primary targets of the EU plastics strategy published on the 16 January.

Its title is very clear : A European Strategy for Plastics in a Circular Economy. Plastic is ubiquitous: it is present in all aspects of our economy and our daily lives. The plastics we use must be such that they can be re-used rather than thrown away. It is an important resource which can be put to good use rather than thrown away or incinerated.

It is for this purpose that the newly-published plastics strategy lays the foundations for a new plastics economy where “the design and production of plastics and plastic products fully respect reuse, repair and recycling needs and more sustainable materials are developed and promoted”.

A plastics economy would definitely not send “waste plastic” to the incinerator to be converted into energy. Even Malta’s latest version of the Waste Management Strategy, approved in 2014, emphasises that our approach to waste must be one based on the sustainable use of resources and, in line with the EU waste hierarchy, gives priority to recycling over incineration.

In fairness, it has to be said that our government’s advisors on incineration have already sounded the alarm. Apparently this has not, as yet, been understood – either by the government or by the Opposition. It would be pertinent to point out that the Special Assignment Report by Jaspers dated 23 February 2017 on a Waste to Energy (WtE) project in Malta specifically emphasises that “it would be difficult to justify a WtE facility that is not based on low waste growth and high recycling”.

Rather than talking about incineration, it is about time we discussed in detail the implementation of our Waste Management Strategy in order to identify why it has not to date succeeded in increasing Malta’s recycling rates. What initiatives need to be taken in order that the waste generated in Malta is minimised?

Malta’s waste management strategy, now complemented by the EU’s Plastic Strategy, is definitely a much better roadmap than the documentation encouraging incineration. And what about our commitments to encourage a “circular economy” : gone with the wind?

Karmenu Vella’s plastics tax is food for thought.

It is about time that Wasteserve is managed properly. As a first step, it should stick to its brief and seek to implement carefully the Waste Management Strategy, which establishes the year 2050 as the year when we should achieve a “Zero Waste Target”. This target will not be achieved through the use of incineration but through a policy encouraging waste minimisation as well as recycling.

This is not just a task for the Minister responsible for the Environment. The Minister responsible for the Development of the Economy also has a very important role to play in achieving a successful implementation of the Waste Management Strategy.

Unfortunately he is apparently completely absent.

Zero waste municipalities in Europe are continuously indicating that an 80 to 90 per cent recycling rate is achievable. The fact that Malta’s recycling rate is, at best, estimated at around 12 per cent, is a clear indication that there is room for substantial improvement – with or without Karmenu Vella’s plastics tax.

Published in The Malta Independent on Sunday 28 January 2018

 

The politics of e-waste

WEEE Electrical and Electronic Waste

 

Last Monday’s budget has placed waste on the national agenda once more.  This time the focus is on waste generated by electric and electronic equipment. Put simply the issue is that there exists conflicting legislation on the Maltese statute book. On the one hand it is the applicability of the Eco-Contribution Act. On the other hand its the WEEE Directive of the EU which has been transposed into Maltese legislation as of 2007 (Legal Notice 63 of 2007 since replaced by Legal Notice 204 of 2014). WEEE meaning Waste from Electric and Electronic Equipment.

The Eco-Contribution Act of 2004 established the quantum of an eco-contribution to be paid on electric and electronic equipment. This eco-tax was added on to the price of the various electric and electronic equipment sold in local shops: fridges, ovens, telephones, computers, electronic games, calculators, vending machines ………………….  The  amount of tax payable ranging from 25 euro cents to €69.88.

Eco-contribution collected peaked in 2008 at slightly over €15.6 million. It is estimated that around €7.8 million will be collected in 2014 and another €6 million in 2015.

As of 2007 producers (and their representatives), in addition to being responsible for the payment of the eco-contribution, have also been responsible for implementing the WEEE Directive in Malta. This Directive forms part of a number of a set of EU Directives which address different waste streams with the objective of ensuring that waste is considered as a precious resource. Hence the need to recover this resource in order to reintegrate it into the economy.  This means the transformation of all waste into useable resources.

The Directive applied the principle of extended producer responsibility throughout the life of the equipment.  This signifies that producers of electric and electronic equipment, directly as well as through their representatives (the importers) and those dealing with such equipment at points of sale retain responsibility throughout the life cycle of the products. This life cycle thinking has its first impact on the drawing board as producers seek to minimise the use of resources not only cost-wise but also due to the fact that if they do so they will have less to recover. This encourages eco-design. Thereby designing and subsequently producing products whilst keeping in mind their impact throughout their life. It is much more that a cradle to grave view. In fact it is considered as a cradle to cradle approach as at the end of its useful life a product will through recovery of the materials of which it is made up give rise to new products.

What does it signify for us?

Producers and their representatives have the direct responsibility of recovering  electric and electronic waste. In terms of the Directive they will either recondition the equipment or else strip it into its component parts and recycle the resulting materials. This will be done at a cost.  Depending on the efficiency of the process the producers and their representatives will recover a proportion of their costs when they sell the recovered resources.  The unrecovered costs may, in terms of the Directive, be added on to the price of the products. Producers’ representatives in Malta maintain that it is possible for the quantum of the unrecovered costs to be much lower than  what is currently being paid as an eco-contribution. Hence the net impact could be not only environmentally beneficial but also of direct benefit to the consumer.

The budget has announced a transition period lasting up to the end of August 2015 when it is planned that the eco-contribution on electric and electronic equipment is removed and producers (through their local representatives) assume their full extended responsibilities.

Electric and Electronic waste is currently collected by local councils through their bulky refuse service. It is also collected at bring-in sites operated by Wasteserve.  Producers will seek to coordinate these existing collection services with their already operational recovery schemes.

Alternattiva Demokratika-The Green Party as well as GRTU and other producers representatives have been insisting for ages that this is the way forward. In order to achieve results everyone must however play his part.

The net result will be beneficial for both the environment as well as the economy.

 

published in The Independent on Sunday – 23 November 2014

Reforming eco-taxation

Time for Radical Change

Malta Today reports this morning that in tomorrow’s Budget Speech Government will be proposing a reform of the Eco-Contribution Act. Malta Today further reports that the eco-contribution due on electric and electronic equipment will be discontinued. Instead, states Malta Today, Government will proceed with ensuring the implementation of the Waste from Electric and Electronic Equipment  (WEEE) Directive of the EU.

The WEEE Directive shifts responsibility for the recovery of waste from electric and electronic equipment to producers and their representatives. It is an Extended Producer Responsibility which has so far not been implemented in Malta notwithstanding various warnings  and infringement proceedings initiated by the EU Commission. It requires the  direct involvement of the private sector who will now have to assume direct responsibility for waste recovery in the WEEE stream.

The matter is dealt with extensively in AD’s Electoral Manifesto. In fact in the Environmental Chapter of AD’s 2013 Manifesto it is stated that :

“We encourage waste separation in localities. However we recognise that this is not enough. As a country we still lag behind and have failed to reach targets on packaging waste as well as waste generated by electrical and electronic equipment.

It is essential to address the operation of scrapyards. These process waste which is subject to at least three Directives of the EU, namely the WEEE Directive, the End of life Vehicles Directive and the Batteries Directive. The manner in which scrapyards have been permitted to operate signifies a total disregard of the principles and safeguards listed in the said Directives. The fact that after more than eight years of EU membership we are still discussing these issues signifies the low level of preparedness to shoulder environmental responsibilities resulting from EU adhesion.

It is essential that environmental taxation (eco-contribution) is reformed in order that it be ascertained that environmental objectives are attained. The private sector should not be penalised through double payment in order that it fulfils its responsibilities relevant to waste on which eco-contribution was due.

Environmental taxation has two objectives. Generating funds to be used by the exchequer as well as to serve as a deterrent and consequently to reduce environmental impacts. For the deterrent to be effective it is essential that when environmental taxes are proposed it be ensured that as far as possible an alternative product or service to the one being taxed which generates less impacts than the taxed product or service is available.

On the other hand we are aware that environmental taxes which are not properly designed can be regressive. That is they can have a negative social impact due to their impacting the quality of life of those with limited means. In order to ensure that the primary objective of environmental taxation would be environmental improvement AD proposes that environmental taxation should be the joint responsibility of the Ministry of the Environment and the Ministry of Finance.”

Eco-taxation can be of considerable benefit. It however needs to be properly designed. Alternattiva Demokratika looks forward to a discussion on the new proposals.

Waste Management politics

scrapyard

“We encourage waste separation in localities. However we recognise that this is not enough. As a country we still lag behind and have failed to reach targets on packaging waste as well as waste generated by electrical and electronic equipment.

It is essential to address the operation of scrapyards. These process waste which is subject to at least three Directives of the EU, namely the WEEE Directive, the End of Life Vehicles Directive and the Batteries Directive. The manner in which scrapyards have been permitted to operate signifies a total disregard of the principles and safeguards listed in the said Directives. The fact that after more than eight years of EU membership we are still discussing these issues signifies the low level of preparedness to shoulder environmental responsibilities resulting from EU adhesion.” (AD’s Electoral Manifesto, pages 89-90, March 2013)

The existence of operational scrapyards is an affront to Malta’s environmental obligations.

In scrapyards one finds discarded vehicles and other objects made primarily of metal  beyond their useful life. There are a number of operational scrapyards in various areas in Malta.  A major one was closed by MEPA some years back in Birżebbuġa. This is now in the process of reopening as an up to standard End of Life Vehicle facility based in Ħal-Far. The relative planning and environmental applications have been processed by MEPA and Malta Enterprise and the facility should be operational in the not too distant future.  There are other scrapyards (large and small) in various parts of the island. They are mostly an eyesore, generally a blot on the landscape as well as being the cause of negative environmental impacts.

Recycling scrap metal (and other materials) is an important economic activity which ensures that resources originally  extracted from the earth are kept in use and not discarded as waste. Recycling activity if properly managed is an important economic activity which is environmentally friendly. Employment created in this type of activity is an important source of green jobs.

Vehicles and equipment beyond its useful life cannot be disposed of haphazardly. Three specific EU Directives,  namely the End of Life Vehicle Directive (ELV), the Batteries Directive and the Waste from Electric and Electronic Equipment Directive (WEEE) establish  the responsibilities of EU member states to regulate in detail these specific waste streams.  The objective is to recover metals and other materials which would otherwise go to waste. Their recovery should however be carried out in an environmental friendly manner.

Each and every part of a vehicle or a piece of equipment should be dismantled with particular care being given to the collection of fluids and gases. No such care is afforded in scrapyards.

Similarly it is to be pointed out that the electric and electronic waste directive (WEEE) is not being properly implemented in Malta. This is due to the fact that there is a conflict between the responsibilities spelt out in the Directive and the eco-contribution charged in Malta on electric, electronic and white goods.

The WEEE Directive spells out and applies the responsibility of producers for disposing of the electric and electornic waste generated by their products. It does so to encourage producers to put on the market products which are easily recoverable and which can be recycled without much difficulty and expense. The recovery from consumers of electric/electronic products and white goods beyond their useful life can be carried out an at expense which in terms of the WEEE Directive is to be added to the purchase price. But the situation in Malta is such that the cost of processing the waste generated by electric/electronic products and white goods is already quantified as an eco-contribution. This was fairplay when there was no WEEE Directve in operation. But now producers would have to pay twice for the same service. They pay an eco-contribution on placing the product on the market and then they must pay once more to honour their WEEE committments.

In view of the above the WEEE Directive has not yet been properly implemented in Malta.

It is about time that we get our house in order. The politics of waste is a very important matter which has not yet been given sufficient thought.  Except that is for the siting of waste management faciltiies, which seems to be the only waste issue which has interested the public in recent years.

The Issues Paper published recently by Minister Leo Brincat makes scant reference to the above. Maybe this is because it is a preliminary document preceeeding the actual Waste Management Plan for 2014-20.

A structured discussion on waste policy will certainly be of help. Having a multitiude of public consultation exercises by the different Ministries launched during the summer period is not  good practice. It is an old trick played by those who want to  nominally honour their obligations to consult.  Hopefully when the actual draft Waste Management  Plan 2014-20 is available for consultation we will have ample time to discuss.

published in The Times of Malta, Saturday August 31, 2013

Time to realign actions with words

On Budget Day next week, the government ought to explain the extent to which its actions are consistent with its political programme read during Parliament’s inauguration by the President in 2008.

It would be pertinent to remember that the President had then 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.” Sustainable development, the President had informed Parliament, was a main goal of this government.

Well, since then, and for a number of months before that too, the National Commission for Sustainable Development has not met. It has been dormant for three years. Not a good sign for a government that considers it should direct itself onto the sustainability path. In addition, targets and objectives of the National Sustainable Development Strategy have been ignored.

Alternattiva Demokratika considers that next week’s Budget could be the opportunity for the government to realign its actions with its declarations.

Cabinet approved a national strategy for sustainable development towards the end of 2007 after extensive consultations with civil society carried out by the NCSD. This strategy laid down a number of specific actions for government ministries to follow. These have been honoured in the breach.

The selected method for implementation of the strategy is through action plans drawn up by ministries. Within 18 months from the strategy’s adoption, that is by mid-2009, ministries were required to prepare their action plans to implement the strategy. They are already 12 months late.

This has occurred because, at least to date, the government has considered the NCSD as a formality.

The mere fact that the Prime Minister, who ex-ufficio is chairman of the NCSD, hardly ever attended commission meetings since 2004 is, in itself, the clearest indication of the mismatch between declarations and actions, the end result being the prevailing state of affairs.

The NSDS identified 20 priority areas: environment (eight areas), economy (three areas), society (four areas), cross-cutting issues (three areas) and implementation (two areas).

Priority area 19, for example, established that, by 2008, that is 24 months ago, a permanent structure properly staffed and funded had to be in place to monitor and review the strategy’s implementation. A role for major stakeholders was also envisaged in order to “critically evaluate progress relating to the strategy”.

Priority area 17 identified the year 2008 as the target for the drawing up of a strategy “to enhance the use of economic instruments such as charges, taxes, subsidies, deposit refund schemes and trading schemes” in order to apply the polluter-pays principle and to promote sustainable development in Malta. Instead of drawing up this strategy, the government drew up a national environment policy issues paper and queried whether and to what extent the public considers it advisable “to move towards a taxation system that penalises pollution rather than jobs”.

To add further to the indecision, the pre-Budget document published in July declared the government was considering introducing a carbon tax. It further advocates a tax shifting mechanism whereby the taxes collected through this carbon tax are offset by the reduction of taxes that “penalise jobs”. Has a study analysing the impacts of this proposal been carried out? While reducing carbon emissions would be positive, what analysis has been made of the economic and the social impacts of such a measure?

On behalf of AD I have sought an answer to this question. In terms of the Freedom of Access to Information on the Environment Regulations 2005 I requested the release of studies commissioned by the Ministry of Finance.

The reply I received last Monday is another proof of the amateurism prevalent at policy formation level. The reply drew my attention to a number of academic journals dealing with tax shifting. I was further informed that the issue (of tax shifting) is being discussed in the Green Economy Working Group, which is expected to present its initial findings to the government by the end of 2010. These findings, it was stated, will be subject to public consultation in early 2011.

While consultation is always to be viewed positively, my point is that the announcement in the pre-Budget document that carbon taxation and tax shifting are being considered was premature in view of the fact that no studies have been concluded to date. Not even preliminary ones.

It seems the government has not yet learned its lessons from the introduction of eco contribution.

Serious policy formation and announcements have to be accompanied by studies detailing impacts of the proposals. Premature policy declarations serve no purpose except to mislead.

Ending all this by realigning actions with words would be a good first step. Our future depends on it.

Published in The Times, October 23, 2010

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.

 

Eco-taxation

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.    

Information

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

AD on Government’s Environment Policy

During a press conference in Valletta, Michael Briguglio, AD Chairperson, said: ‘Alternattiva Demokratika is presenting its reactions to Government’s proposed environment policy. In a nutshell we believe that it would have been wiser if Government implemented the recommendations of the National Commission for Sustainable Development, which have been ignored by Government for over two years. A holistic and effective environment policy should be based on the concept of sustainable development through which environmental, social and economic considerations are given due importance in order to improve the quality of life of people and to protect species. This is precisely what is being proposed in our policy paper, which covers various areas’.
 
Carmel Cacopardo, AD Spokesman on Sustainable Development and Local Government said that AD’s detailed reaction to the National Environment Policy Issues Paper was presented to Parliamentary Secretary Mario de Marco yesterday during a cordial meeting.
 
AD, said Cacopardo, is of the opinion that environment policy and environment measures have to be buttressed by studies which analyse the economic, social and environmental impacts of the proposals. Environmental research is absent from the list of issues dealt with by the document government published for public discussion. This is not a surprise for AD as acting without analysing impacts a priori is this government’s preferred method of action as has already happened when the eco-contribution legislation was introduced.
 
Government has just announced that it is toying with the idea of introducing tax shifting by reducing taxes on labour and introducing a carbon tax. This proposal communicated in the pre-budget document is scant on details such that it is not at all clear what Government is considering. In addition no studies indicating targets, methods and impacts has been published. Nor is it known whether in fact any studies have been carried out. It is for this reason that AD has 15 days ago requested the release of studies on the “carbon tax” proposal in terms of the provisions of LN 116 of 2005 (Freedom of Access to Information on the Environment Regulations).
 
The use of economic instruments for environmental improvement should be the responsibility of the Ministry of the Environment and not of the Ministry of Finance. This would ensure that environmental objectives and not fiscal ones are the primary objectives when such instruments are used
 
The Issues Paper added Cacopardo does not consider a number of important areas of action such as : Light Pollution, Environmental Impacts of Organisations, CSR, environmental nuisance, land contamination, the role of civil society and eNGOs in environment policy formulation, access to environment information and environment research.
            
AD considers that in view of the large number of vacant properties a moratorium on large scale residential development is long overdue. The regulating of funding of political parties would also ease the pressure of the building development lobby on politicians.  
 
Press here to download full AD paper

Environment Policy and the Budget

The National Environment Policy Issues Paper, launched by the Parliamentary Secretary for the Environment, Mario de Marco, on July 27 requested the views of the public on a move towards a taxation system that “penalises pollution rather than jobs”.

When launching the 2011 pre-Budget document on the same day, Finance Minister Tonio Fenech was more clear as to the government’s intentions. Under the heading Tax Shifting, he proposed the shifting of taxes from economic goods to economic bads. The pre-Budget document goes on to say: “In order to incentivise the creation of work by making labour less costly we are proposing the lowering of government-induced employee costs as well as corporate and income taxation.” The pre-Budget document then praises the merits of a carbon tax as a fiscal tool.

It seems that both the minister and the parliamentary secretary have forgotten that taxation does not penalise jobs. It is an instrument for the attainment of social solidarity. That is what the post-1977 Nationalist Party I remember was in favour of. It seems that time has changed the PN. It cannot be anymore described as being “un partito di centro che guarda a sinistra” (a party of the centre that looks to the left), as the old guard, quoting Alcide de Gasperi, justifiably boasted.

The drafters of the documents launched could have consulted the Cabinet-approved National Sustainable Development Strategy for the Maltese Islands (page 59), which established 2008 for the conclusion of a strategy on environmental taxation. The year 2008 is 32 months away and the strategy on the use of economic instruments to regulate environmental impacts is still not in place. Instead of asking for views of the public they should have drafted the strategy that has been promised but not delivered. It could be a useful guide for the finance minister.

At issue in this debate on tax shifting are points already emphasised during the eco-contribution legislation debate in 2004/05. Which ministry will be in the driving seat of environment taxation policy: Finance or the environment? Will the primary objectives of environment taxation be environmental or fiscal?

The strategy to be adopted and, thus, the specific proposals to be brought forward will depend on whether fiscal policy is used to regulate and reduce environmental impacts or whether the environment will be used to compensate for shortfalls in tax revenue.

After 17 years, the government has woken up to the proposals of a Jacques Delors EU White Paper in 1993 on growth, competitiveness and employment [COM (93) 700 final] who had the argued in favour of taxing environmental impacts and resource use.

In its 2008 electoral manifesto, the PN promised it will reduce income tax in the higher bands. It is now seeking ways to deliver without subjecting the Exchequer to further problems. It is very unfortunate that an inappropriate tool was selected. As a result of the tax shifting proposal, a tax, which is socially progressive (income tax) will be partially substituted with a carbon tax that, viewed on its own, can be socially regressive. The proposal aims to reduce taxation from a band which is paid mostly by companies and those who have a substantial income. To compensate for the resulting shortfall, it will spread the tax-load on everyone without discrimination, irrespective of their means.

Once the government decided on the reduction of the higher band income tax, I understand that it did not have much of a choice. In order to ensure a regular flow of income, which would have to substitute a reduction of the forfeited income tax, it had to select a subject in respect of which (at least, in the short term) demand is largely inelastic to tax-induced price changes.

It would be interesting if any studies on the impacts of the pre-Budget tax-shifting proposal are available. Such studies should clearly demonstrate the two basic flaws of the proposal: first it’s being socially regressive and, secondly, it’s exploiting of the environment as a tax revenue generator without ensuring environmental improvement as a primary objective.

If environmental improvement was a primary objective, the projected tax revenues would not be generated as they would be reduced gradually, in line with environmental improvement.

A carbon tax would force business and industry to address their environmental impacts. However, the impacts of a carbon tax on SMEs and households have to be assessed more carefully before policy declarations are made in view of the limited size of the former and the lack of resources of both. Given that most of Malta’s business is in the SME sector, matters should first be studied in their proper perspective before declarations are made or decisions taken.

There are various alternatives to the government’s proposals. Each one of them must however be tested through studies to ensure that the social and environmental impacts of fiscal policy are either positive or else substantially mitigated.

Studies made must be available at this stage. Otherwise, the discussions on both the National Environment Policy and the pre-Budget document would be just kite flying exercises.

 

published in The Times Saturday, September 4, 2010