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

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.

Increasing environmental awareness

 

 

 

The publication of the draft National Environment Policy (NEP) is a useful exercise irrespective of Government’s intentions, which, to put it mildly, are not always clear.

Government’s intense rhetoric coupled with action motivated primarily by the need to overcome threats of EU infringement proceedings is not the best way to move forward in environmental issues. Labour would certainly be no better. Past experience indicates that Labour are on the same wavelength as the PN even though their policies on a number of issues are not yet spelt out, in public at least.

In April 2010 Ernst & Young had concluded a Public Attitudes Survey on environmental issues commissioned by MEPA. The analysis of the results, available on the MEPA website makes interesting reading.

Of central importance are the conclusions relative to the inter-relationship between the environment and the economy: 69% of respondents held that the environment was as important as the economy, 23% held that the environment was more important than the economy whilst only 8% held that the economy is of over-riding importance.   

Air quality, waste management and land use top the list of the environmental concerns of the Maltese. In fact these are the most worrying issues, though certainly not the only ones.

The draft NEP collects in one document a detailed list of government’s environmental responsibilities, primarily resulting from the EU environmental acquis. There are also some areas covered by the draft NEP in respect of which the EU has no role. Government has erroneously described these as an indication of its determination to go beyond EU requirements.

A logical and down to earth reaction to the draft NEP is that we have been there before. A National Sustainable Development Strategy approved by Cabinet in late 2007 had approved practically a similar (although less detailed) document. It even had some specific targets all of which have been ignored by the Cabinet Minister who was responsible for their implementation: the Honourable Lawrence Gonzi whose portfolio of political responsibilities included and still includes Sustainable Development .

Is it ethical, I ask, for the Prime Minister to approve a strategy (through Cabinet)  with specific targets, ignore them, abolish the Commission which drew up the strategy and then re-present substantially the same strategy and proposals in a different form? Would you believe him if he now says that he is serious about implementation of strategies and proposals originally proposed in 2007 but ignored  by the government which he has led uninterruptedly since 2004?  Speaking for myself I don’t believe one word of what he says on the subject.       

The National Sustainable Development Strategy identified various targets. Most were undated, but some basic ones had a specific timeframe by which they had to be delivered.

Among the specific targets which Dr Gonzi as Prime Minister first approved but subsequently ignored are the following :

  1. By 2008 draw up a strategy to enhance the use of economic instruments (eco-taxation strategy),
  2. By 2008 put in place a permanent structure appropriately staffed and funded to monitor and review the implementation of the National Strategy for Sustainable Development,
  3. Within 18 months of the adoption of the National Strategy for Sustainable Development (that is by mid-2009) Ministries had to prepare their action plans on the implementation of the strategy in their portfolio of responsibilities,
  4. By 2010 draw up an integrated Spatial Development Plan to take forward the Sustainable Development Strategy, with the participation of major stakeholders.

None of the above targets have been met.

 Among the general targets approved in 2007 (4 years ago), before the re-election of Dr Gonzi as Prime Minister he had promised : 

  1. the drawing up and implementation of a policy addressing the issue of light pollution,
  2. the drawing up and implementation of a dust-control policy,
  3. a nationwide public footpath policy which delineates paths that the public can use,
  4. promotion of a culture of Corporate Social Responsibility by major firms,
  5. enhancing enforcement and monitoring to reduce the destabilising  effects on society of construction and quarrying activities.

  None of the above targets have been addressed.

 All the above nine proposals and many others originally forming part of the National Sustainable Development Strategy have re-surfaced in the draft NEP after being ignored for a number of years. Dr Gonzi’s proposals have a habit of hopping from one policy document to the other.

This is not a serious way of doing politics. Those who like Dr Gonzi proposed strategies and failed to implement them should have the decency of explaining why they failed in their mission. Instead of doing so Dr Gonzi organised a media circus at Xrobb l-Għaġin to explain to the media the “greening of his government”. Unfortunately no record is available of any of the journalists present taking him to task for trying to hide his failures.

 Notwithstanding the above some benefit will surely arise out of the debate on the draft NEP: even if we have been there before and discussed it not once, not twice but many times over without any tangible result to date. The public’s sensitivity to environmental issues is on the rise. Its environmental awareness is increasing rapidly.  Just 18 months before a general election I do not think that anyone can be deceived anymore on green issues.

Like the PL before it the PN in government has had its chance to deliver and failed.

 

 Published in the Independent n Sunday – Environment Supplement

October 2, 2011 

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

The Politics of Waste

times_of_malta196x703

by Carmel Cacopardo

pubished September 26, 2009

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WEEE_Waste_II

The Italian Mafia eco threat through the sinking in the Mediterranean of at least 42 ships laden with toxic and nuclear waste has far-reaching implications. The real impact, however, will not be clear for some time until all relative details are known.

Last week, the announcement was made of a settlement relative to the dispute that arose after the dumping in 2006 of some 500 tonnes of toxic waste around Abidjan, the capital city of Ivory Coast. This settlement was denounced by both the association of the victims (31,000 residents of Abidjan) and by the international NGO Greenpeace that described it as an exploitation of African poverty.

Going through e-mails published by Greenpeace in the UK newspaper The Guardian last week, it is clear that at one point the toxic waste that ended up at Abidjan was to be processed at the fuel terminal of La Skhira, Tunisia. It appears however that the Tunisian management asked too many questions after examining a sample of the toxic waste such that other destinations were considered more appropriate!

Within this context it would be reasonable to consider what is being done locally with the toxic waste generated on these islands. I will limit myself to the discarding of electric and electronic equipment in Malta, a source of toxic waste. This is regulated by the provisions of the Waste (from) Electric and Electronic Equipment Directive of the EU. Known as the WEEE Directive, it has been transposed into Maltese law through Legal Notice 63 of 2007, yet, to date, it is not being implemented.

On the basis of the producer responsibility principle, producers of the electrical and electronic equipment placed on the Maltese market, as well as their representatives, are responsible in terms of the WEEE Directive for taking back obsolete/discarded equipment. In the long term this would mean that the design of the equipment is improved thereby facilitating repair, possible upgrading, reuse, disassembly and recycling and, consequently, cut the costs of disposal.

Taking back obsolete/discarded equipment involves a cost. Producers and their representatives are objecting because the government is forcing them to pay twice over for the waste they generate. Since 2004, on the basis of the polluter-pays principle, the government is already charging an eco contribution, which was specifically designed to pay for waste management costs. Subsequently, as a result of the transposition of the WEEE Directive, the responsibility for the managing of WEEE waste was hived off to the private sector. However, the government is still collecting the eco contribution while the private sector is expected to foot the bill for taking back obsolete/discarded electric and electronic equipment.

The government is collecting payment to make good for responsibilities it no longer shoulders. While it has a new role, as a regulator, through WasteServe it still insists on direct involvement. One would have expected this attitude from a government that advocates state intervention but not from one that is prolific on rhetoric relative to the pivotal role of the private sector.

The government’s attitude is impeding the private sector from developing a service, responsibility for which has been specifically assigned to it by EU legislation. This has been going on for the past 30 months and, as a result, most of the waste generated during this time by items listed in the WEEE Directive is unaccounted for.

The WEEE Directive is applicable to: household appliances (small and large), IT and telecommunications equipment, consumer equipment, lightning equipment, electrical and electronic tools, toys, leisure and sports equipment, medical devices, monitoring and control instruments and automatic dispensers.

Consumers are entitled to return to a supplier any obsolete/discarded item to which the WEEE Directive applies. The supplier, on behalf of the producer, will then ensure that the item is reconditioned, recycled or else stripped into its component parts, which can then be reused as raw materials or else appropriately disposed of. This obviously involves an expense that suppliers are entitled to recover by charging the consumer the real cost of waste management. Consumers are, however, already being charged an eco contribution, this being a waste management fee for costs that are not incurred anymore.

Late last year, the EU embarked on a revision of the WEEE Directive. Through this revision the EU aims to fine-tune the provisions of the directive such that it is more effective. In Malta, having not yet initiated implementation of the WEEE Directive, we are in the ridiculous situation of having a government that proclaims it is environment friendly but then whenever possible goes out of its way to torpedo the implementation of the environmental acqui.

It is the importers who are now directly responsible for implementing the provisions of the WEEE Directive. However, this does not exonerate the government whose double charging for WEEE waste is clearly the sole reason for WEEE’s non-implementation in Malta.

Green Icing on half-baked cake

times_of_malta196x703published on 15 November 2008

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by Carmel Cacopardo

 

 

The budget environmental initiatives can best be described as green icing on the cake. However,once you cut through the icing there is not much to be overjoyed with. These initiatives could be considered as a declaration of intent: the good intentions being severely hampered by the government’s lack of action in the past, even the very recent past. As a result it is very difficult for these initiatives to yield positive results at the present time.

A number of initiatives are linked to transport. While the proposal to refund 15.25 per cent of a bicycle’s cost is welcome, it lacks the support of the necessary infrastructure thereby severely diluting its significance and possible impact. There are very few cycle lanes on our roads, and those that exist are frequently obstructed or else end abruptly. Few bicycle racks were installed in our towns and villages, the most notable being the ones in Birkirkara installed by the local council on the initiative of Green local councillor Mario Mallia during his term of office some years ago.

Others exist in Attard, a credit to Attard Green councillor Ralph Cassar. But very few exist elsewhere. AD is insisting through its local councillors in Attard (Ralph Cassar), Sliema (Michael Briguglio) and Ta’ Sannat (John Mizzi) for more initiatives which would make our roads bicycle friendly. It is only thus that the budget bicycle initiative could make any sense. What about some action by ADT?

The new car tax regime (both registration tax and circulation tax) could have been designed in a better manner. The age of a car, for example, is not necessarily conducive to increased environmental impacts.

The actual emissions as resulting from the VRT test would have been a much better point of reference than vehicle age in determining car taxation. This would encourage and reward those who keep their cars in good working order.

The budget also increased the licence fees (circulation tax) to be paid relative to cars currently on the road. When viewed within the context of the practical inexistence of a reliable public transport service, in the short term this is bad policy.

In the long term, however, it could be an adequate policy tool to encourage the reduction of the 295,000 cars currently on the road. In order to function properly eco taxation requires the existence of an alternative to what is being taxed: the alternative in this case being public transport. In the absence of an alternative the end result will be socially regressive: reduced accessibility to those at the lower end of the social ladder. If the real objective of the new car licence rates (circulation tax) is environmental, it would have been much better for all if they were not applicable immediately. Their applicability should be linked to the reform of the public transport system.

Government’s encouragement of photovoltaic panel installation is very limited. It is generous but due to financial constraints it will be limited to around 200 households.

It is also hampered by other issues which have not yet been addressed. Issues of ownership of airspace have to be examined and new concepts as to its use have to be developed. Likewise from a land use planning point of view any future increase of permissible building heights has to be balanced against the right of access to solar energy.

The direct subsidy of photovoltaic panel purchase is not the only way to encourage installation. The government should explore schemes through which the purchase price is paid through the electrical energy generated. An initiative such as this would render solar energy accessible to those who do not have the required capital outlay readily available.

The eco tax applicable to incandescent light bulbs and the increase in eco tax payable on plastic bags were long overdue. However, the government must explain how it will tackle its major loophole in this respect. It is a known fact, at times documented in the media, that the manner in which eco taxes are being evaded is through overland supplies from neighbouring Sicily. It is eco tax versus the free movement of goods. Will checks be introduced at the border to control blatant and obvious tax evasion?

It is also amusing to note that the government is a late convert to the applicability of eco taxation in the tourism sector. The rate to be applied as from 2010 is insignificant but at last this green principle, which was under attack on the eve of the 2004 European Parliament elections, has now been accepted. Tourism has to date been excluded from the applicability of the polluter pays principle. Hopefully it will slowly come in line. Next to follow should be MTA encouragement of eco and agro tourism. These are forms of tourism with substantially lower environmental impacts than conventional tourism.

The green icing may be fine, but if the cake is half-baked what’s the use?