The accumulated cost of incompetence

After last Monday’s storm the usual comments were read and heard: the damage sustained, the cost to the insurers, the cleaning operations, the near misses.

There was no comment on the real culprit for a substantial part of the damage.

No one commented on the excessive building development taking over agricultural land over the years. No one commented on the building in and along valleys. No one commented on the lack of water cisterns in residential units which although a legal requirement since 1881 is more honoured in the breach.

Who is responsible for all this?

Successive governments and the public administration in the last 50 years is responsible for this mess. It is in fact the cost of incompetence.

The storm would have happened anyway, but :

If all residential units are provided with rainwater cisterns there would certainly be less stormwater gushing around in the streets. Certainly no overflowing sewers as still happens in a number of localities.

If less building development was permitted over the years there would be more land available for the recharge of the aquifer.  We would also have substantially less vacant dwellings

If rubble walls along valleys are properly and regularly maintained there would be less obstruction to the natural flow of water.

If  no dumping of waste occurs in valleys, there would be less obstruction to the natural flow of storm water.

But this has not been so.  Hence the scale of the damage.

The damage caused by last Monday’s storm is the accumulated cost of incompetence.


published at on 7 September 2012


The government must lead by example

The consultation re­port issued by the Climate Change Committee for Adaptation serves as a good basis for discussion on issues which have not been given sufficient attention over the years.

One of the issues tackled is that concerning the absence of rainwater cisterns in dwellings. Recommendation 35 deals with the matter.

It consists of three proposals. First, it emphasises the need to implement the existing legal provisions and then goes on to suggest the year 2007 as a cut-off point. It does this by referring to the uptake by the Malta Environment and Planning Authority of provisions relative to rainwater storage. Finally, it proceeds with recommending a one-off flood fine on those properties which, not having a rainwater cistern, contribute to flooding during heavy rainfall.

The recommendation ignores the fact that the duty to collect rainwater in cisterns was not introduced in 2007 but way back in 1880 through legislation. So the point of departure in this discussion is that all residential properties constructed after 1880 should be provided with a rainwater cistern.

The 1880 legislation was an important milestone. The provision of damp proofing, measures emphasising the importance of ventilation, the provision of an adequately sized rainwater cistern and many other matters were introduced. They are incorporated in article 97 of the Code of Police Laws. The relevant legislative provision on rainwater cisterns is regulated by the director of public health and states that “every house shall also have a cistern of a capacity of at least three cubic metres for every five square metres of the surface of the floor of each room of such house”.

One could justifiably argue that the rainwater cistern dimensions resulting from the above quoted legal provision are on the high side and that after 130 years they need revisiting. When this legal provision was introduced, the most common type of dwelling was one of two floors.

Applying the law’s dimensions to blocks of flats would result in very large water cisterns, of such dimensions that would never be fully utilised. The existing dimensions can be revisited by referring to the footprint of a building rather than to its total floor space. This would result in dimensions that are reasonable and achievable given today’s predominant building typology. It would also iron out discrepancies between the dimensions for rainwater cisterns in the Code of Police Laws and those indicated elsewhere. The establishment of the year 2007 as a cut-off point would exempt dwellings constructed before that date from shouldering their contribution to flooding.

This would discriminate and would mean that a substantial number of dwellings are left free to continue contributing to the flooding problem.

Recommendation 35 suggests the introduction of a one-off flood fine to be paid by the owners of those properties which do not have a rainwater cistern. A one-off fine will not solve anything unless it is substantial. The fine should be payable annually until such time that a rainwater cistern of an appropriate size is introduced.

How should one proceed? As a first point no one should be exempt. To reduce flooding, rainwater should be collected in every dwelling.

Secondly, it has to be recognised that, in some cases, a solution may be beyond the financial means of current owners of buildings without rainwater cisterns. In such cases some form of financial assistance should be considered as the politics of climate change should not be socially regressive.

A third consideration would be that in a number of cases the construction of a rainwater cistern may not be technically possible. In such cases the solution may well be the pooling of resources to construct communal rainwater reservoirs or to fund the maintenance of existing ones. Such funds could be administered by local councils with the owners of defaulting properties being obliged to contribute an amount equivalent to what it would cost to construct a rainwater cistern in their property.

The tangible results of such an initiative would be manifold. Having an alternative source of water some would be in a position to reduce their water bills. With less rainwater flowing in our streets flooding can be substantially reduced and our streets will be generally safer both during as well as immediately after a storm. We will also end up with less sewage overflowing into our streets if rainwater is collected instead of ending up in the public sewer. Finally, our sewage purification plants will have a reduced load during storms thereby reducing their running costs.

Alternattiva Demokratika has been emphasising the above for a number of years.

A good point to start implementation would be for the government to set the example by embarking on an exercise of providing rainwater cisterns in all government-constructed housing estates. Most of them have none.

If the government leads by example the rest will slowly follow.

Published in The Times of Malta : Saturday 13th November 2010

The Cost of Incompetence

times_of_malta196x703by Carmel Cacopardo

published Saturday, January 17, 2009


Walking or driving through some of our roads during or immediately after heavy rainfall is no easy task. If you are lucky you will “just” encounter large quantities of ankle-deep rainwater. It may, however, be worse if the rainwater is mixed with sewage.

This is happening so often that it is hardly news any more!

Three issues should be underlined. The first is rainwater literally going down the drain!

Secondly, it is an issue of civil protection: life and property are endangered.

Thirdly, it’s a case of an overloaded public sewer and, consequently, an unnecessary increase in the costs of sewage purification.

Local building regulations applicable since 1880 established the capacity of rainwater cisterns that are to be provided as an integral part of a dwelling. Unfortunately, a number of residential properties constructed over the last 45 years have not been provided with cisterns for rainwater storage.

The major culprits are a substantial portion of the developers of blocks of flats and maisonettes. In particular, in cases where basement or semi-basement garages are constructed, the duty to provide for rainwater storage is very rarely complied with. In those instances where a rainwater cistern has not been provided, rainwater is being disposed of either directly onto the street or else straight into the public sewer.

When disposed of onto the streets, rainwater is a contributor to flooding whereas when discharged down the drain it overloads the public sewer which, subsequently, overflows onto our streets.

As a result, this adds a health hazard to an already alarming situation.

Mepa has since 1992 been responsible for determining and ensuring the observance of the conditions of development permits, which, in most cases, specify the required capacity of a rainwater cistern. Mepa shares this responsibility with the public health authorities.

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

Is the WSC verifying that it is only the house drains that are connected and, in particular, that rainwater pipes are not connected to the public sewer too? The answer is provided by our streets on a rainy day. No one is bothering to check.

This leads to the conclusion that, while the culprit for the present state of affairs is the building industry as, more often than not, it does not provide for rainwater storage in new development, it is not the only one to blame. The authorities and government departments have a substantial share of the blame for not shouldering their responsibilities.

A number of areas are out of bounds whenever heavy or continuous rainfall hits the Maltese islands. This is a source of danger and, in fact, the Civil Protection Department is heavily involved in assisting residents or motorists who are trapped as a result of flooding. The Birkirkara local council had some years ago installed a storm warning system to alert residents and passers by that “danger was on the way”!

Public authorities, unfortunately, have developed the habit of dealing with the effects but continuously ignore the cause of flooding!

Austin Gatt, as the minister responsible for the WSC, recently announced that the government will introduce a drainage tariff as of next year. He stressed that, in terms of the EU Water Framework Directive, the government has to recover costs related to the treatment of urban wastewater. Leaving aside for the time being the discharge of the treated wastewater into the sea (I have dealt with this elsewhere) it is clear that the cost of treating urban wastewater includes an expense which can easily be avoided if the public sewer is not overloaded with rainwater during the rainy season. All of us will thus be forced to pay the cost for the gross incompetence of the government through its authorities.

We have also been informed that part of the €855 million made available by the EU will be used to fund a project for the construction of underground tunnels through which it is planned to collect rainwater from our streets and roads. It is planned not only to store the rainwater underground but, possibly, also to make use of it in order recharge the depleted water table!

No one has yet explained how it is intended to deal with the contamination of rainwater by sewage prior to it being collected in the projected tunnels. But even if this is remedied, the EU funds will be effectively subsidising a number of developers who, once more, will shift their responsibilities and expenses onto the taxpayer. EU monies are taxpayers’ funds too!

This is the accumulated cost of incompetence!