The Church Environment Commission has issued a Report outlining its “Reactions to the Consultation Document: Waste Management Plan for the Maltese Islands – A Resource Management Approach 2013 – 2020.”

The Report is shown in full below:

Introduction

“This time of year is a reminder that God, in his infinite love, chose to become human to share with us our realities and help us through the ordeals we face. The Church of Christ – if it is worthy of that name – cannot shun this commitment towards humanity. Yet, judging from certain comments in the media, certain people seem to be torn between wanting a Church that is lost in mystic rituals and a Church that is relevant to our times. Conscious that the latter vision of the Church can be uneasy and controversial, the Kummissjoni Interdjocesana Ambjent (KA) has chosen to provide insights about current issues that impact our quality of life. The KA hopes that whoever hears or reads its Opinions (rather than the bits and pieces reported in the media), whether a practicing Catholic or not, does so with a heart that thirsts for truth and justice – irrespective of its source.

“The KA’s current Opinion follows a series of other Opinions, published over these last eight years, about waste management issues.* The reasons behind the KA’s concern about waste management are mirrored in the challenges expressed by the consultation document** , i.e. “Malta’s high population density, limited land space and lack of economies of scale coupled with the effects of its climatic conditions” (p.9). However, irrespective of these limiting conditions we, as a nation, tend to opt for short-term goals with promises of great national economic gains fed into our psyche by short-sighted economists and developers.

“The need to break away from this trend, that has invariably resulted in gain for a handful of entrepreneurs and irreparable loss for our nation, is also acknowledged by the document: “… the Maltese government aims to break the link between economic growth and waste production” (p.9). The current document should be seen as a means to achieve this end and not as an end in itself. In other words, our efforts should spearhead change in this sector rather than just generate a document that satisfies (at least on paper) our commitments towards EU directives. You cannot respond effectively to new realities with old technologies and obsolete models of economic growth. “New wine must be poured into new wineskins” (Lk 5:38).

“Our vulnerable situation (see above) and our commitments towards the international community are crying out for the need for our country to clearly identify the underlying sustainable targets that we need to achieve and structure the strategy accordingly, thus breaking the vicious circle of trying to fashion our lifestyle to fit directives. This reactive mode drains our resources and energies and prevents us from adopting a proactive role.

“EU directives should not be an end in themselves and we need to be bold enough to confront directives that may not be congruent to our realities … as we should have done re the change from glass to plastic soft drink bottles. Although being a small country may have its downs due to the economies of scale, being small also allows us (if we are committed enough) to easily and rapidly implement solutions that might not be financially feasible or applicable for larger countries.

“KA welcomes the concept of merging “a Strategy, intended for local policy guidance, and a Plan, intended for local policy guidance and compliance to the Directive, within one National Waste Management Plan” (p.12). This highlights the need to do something tangible to ensure a good quality of life in our home so that it can then welcome guests. It is also a constant reminder of the transboundary impact of environmental issues.

“The KA favourably notes that, while learning from past mistakes, the document acknowledges and builds upon the good practices and decisions that have been established by other administrations. As a country we cannot afford starting all over again every time there is a change in government. Putting sustainability targets at the top of our nation’s agenda is a bold political step forward. Referring to one of the suggestions made in its pre- election document *** , the KA would like to reiterate: “The environment belongs to every Maltese citizen and therefore its wellbeing should be the responsibility of the whole parliament. All stakeholders should be involved in the drawing up of a National Policy for the Environment and Sustainable Development from the start of the legislature. This policy … rather than the decisions of the party that just happens to be in government … will then become the norm on which future decisions are based. Such a move requires a political maturity that perhaps the political parties in our country have not yet achieved.”

“This joint responsibility for environmental strategies would also rid our country of politically motivated debates aimed at gaining political mileage from ‘uncomfortable’ but necessary actions. There is an urgent need to be politically bold and address certain sectors and individuals who are either indifferent of the impact of their actions on the general wellbeing of the community or who have been getting away with murder.

General principles concerning the document

(a) An updated vision of sustainable development

“Having sustainable development as an underlying principle is very commendable as long as it remains a basic value against which decisions taken are compared (p.34). Considering its centrality one might need to consider a further development of the concept, i.e. the inclusion of culture as a 4th pillar (alongside the other pillars: environment, society and economy). The image of intersecting circles neatly served the needs of academics, but has proved to be impractical. Culture needs to feature in sustainable development discourse since it ultimately defines what we mean by development and determines how we act. While making this suggestion to reflect the evolution of the concept, the KA is fully conscious that certain individuals still erroneously relegate sustainable development issues to just environmental concerns.

(b) Informed decision making

“Section 2 of the document evidences one of the major problems that sustainable progress in the waste management sector faces: conflicting, variable and missing data. The lack of accurate data does not allow us to appropriately define the dimension of the issue and consequently decisions taken in this context are usually flawed. The KA notes that the need to “improve data collection” was identified in section 3.10, pt.2. The strategy needs to include measures that ensure data collection on a regular basis and mechanisms that review, and possibly repropose, policies in the light of new emerging evidence. There is an urgent need for the setting up of a central agency that establishes clear parameters for data collection, collects, stores and disseminates information.

“The KA is rather concerned that certain decisions are still being proposed even in the (acknowledged) absence of reliable data. For example, Section 2.5.3 evidently highlights the lack of information available for disposal at sea; nevertheless, this has not only not reduced sea dumping (in fact Section 3.5.3 is still considering it as an option albeit “as the last resort, in view of its potential impacts to the marine environment”), but we are actively promoting land reclamation!

(c) Polluter Pays Principle

“The Directive also introduces the ‘polluter pays principle’ and the ‘extended producer responsibility’ approaches, which involves the producer or that person who put the product on the market to take care of the treatment of waste himself” (p.16). The implication of this stance is that concern for waste reduction should be factored in at the product design stage rather than as an end of pipe consideration. In other words, the ‘polluter’ should avoid being a ‘polluter’ and strive to avoid creating unnecessary waste.

“In this context, the KA also favourably acknowledges the document’s concern re “wastes being dumped in States that were not capable to handle the wastes in an environmentally sound manner” (p.17).

(d) Waste as a resource

“The document acknowledges that the whole strategy hinges upon “a transition from waste being seen as a problem to it being considered as a resource” (p.14). Inevitably this necessitates a diametrically opposite view of how waste is conceived by the general public – a view that needs to be promoted through education (see next section).

“However, there is an inherent pitfall in this line of thought. Considering waste as a resource is an attempt to recreate the natural cycles that ensure that resources are not depleted and pollutants are not accumulated. Consequently considering waste as a resource implies reducing the generation of waste (to safeguard the resource from which the product is made) and carefully treating the generated waste (so that it can be used again). Waste as a resource surely does not mean encouraging waste generation so that it can be used to maintain a waste-to-energy stream going.

“Contradictions in the way we treat resources, let alone considering waste as a resource, abound. A classical example is how we treat construction and demolition (C&D) waste. We appease our conscience by using it for land reclamation (and rehabilitation of quarries) and mask the basic truth, i.e. that we are essentially disposing of a non-renewable resource (stone). The relative recent heavy reliance on the use of concrete bricks is probably an indication that maybe we have already gone beyond the limit and deprived future generations of Maltese from their right to use this resource. Changing the predominant mentality about waste necessitates that we channel our creativity and industrial prowess to achieve sustainable solutions – as promoted by the new Waste Framework Directive’s new ‘end-of-waste’ status concept that acknowledges that certain “waste” can achieve “product” status (p.16).

(e) A change in mentality

“The document acknowledges that the change in mentality required for the successful implementation of the proposed strategy necessitates a two-pronged approach: a legal infrastructure (Section 3.11) and a far-reaching educational programme (Section 3.7).

“Despite the regulatory framework that has been set up in the field of waste management, the compliance and enforcement functions still need to be strengthened further” (p.51). Moreover, efforts to strengthen law enforcement need to be monitored over a period of time to ensure sustained compliance and identify loopholes and instances where conflicting policies create ‘legal no man’s lands’. These encourage people, who profit from unsustainable practices, to discover ways of circumventing the law and continue unabated with their plans – making a mockery of the law. A classic example is the way the regulation banning the use plastic carrier bag has been abused. Rapid intervention is required to sort out these contradictions and consequently catch non-compliants and, what the document defines as, free-riders; as both are a constant reminder of the injustice that compliants have to face on a regular basis.

“The important role of education has always been acknowledged in local waste management strategies. The 2001 strategy defined environmental education/awareness as “a constant one-way process (i.e. selected concepts, ideas and information are continually presented and transferred to particular target groups)” (p.57). **** Nevertheless, this is just a communication campaign aimed at transferring information with the vain hope that it will flourish (unaided) into the skills, attitudes and values that are the basis of an environmental ethic that is indispensible for the implementation of such a strategy. While this same strategy identified the centrality of an educational programme spanning the whole duration of the strategy (op cit, Table 13, p. 70) there was no specified budgetary allocation for the process – a possible indication that the educational process was an afterthought and not an integral part of the strategy’s development.

“Once again the current document acknowledges that “Education and awareness is considered to be key to the success of this plan … it is envisaged that, as far as possible, initiatives will be accompanied by an educational and awareness …” (p.142). The KA is also pleased to note that some thought was given to the provision of education that is practical, moves away from just information transfer, addresses different audiences from different sectors and uses a variety of tools. However, the type of tools suggested and the fact that no indicators to monitor its progress have been identified in Section 3.9 are indicative that information transfer is still the dominant educational paradigm adopted.

“One would never dream of building a house without consulting an architect or developing a technology without involving engineers. However, when education for sustainable development campaigns are designed, professional environmental educators are rarely if ever consulted. Consequently, these campaigns are characterised by unclear educational objectives, a waste of resources and dubious results. Educational campaigns need to be meticulously planned to avoid ending up in situations where you have to struggle to unlearn what was learnt. For example, the introduction of the Irricikla t-Tlieta initiative after citizens were successfully learning how to separate waste into three different streams; and Wastserv’s initial undue emphasis on recycling, at the expense of the first 2 Rs, as the environmentally preferred option.

“Therefore, the threat “… associated with the way society responds to developments in technology, to information and awareness raising campaigns, and to measures that aim to influence their behaviour” (p.57) might not be the result of a defective audience, but of an ineffective transmitter. The KA feels that the effectiveness of certain so-called awareness campaigns needs to be evaluated seriously against clear educational indicators. The weight of the amount of waste collected is not a reliable indicator of sustainable choices. It could be just an indication of how much waste (already destined for recycling) got detoured into schools or households before reaching its intended destination. Moreover, there is also evidence that certain competitions aimed at fostering recycling resulted in the generation of more waste.

(f) Calling a spade a spade

“While it is appropriate to target the general public in a waste management strategy, one needs to ensure that the principle of moving waste up the waste hierarchy should apply across the board. Construction and demolition waste remains the greatest fraction of waste generated, irrespective of the way data about waste is collated and presented. Consequently most of the measures of this strategy should therefore target this sector. There is an urgent need to analyse waste generation data in a way that does not mask the true impact of C&D waste. For example, it is questionable whether the backfilling of quarries can really be considered as ‘Recovery’ (p.35). Irrespective of whether the definition is in accordance with the definition laid down in Commission Decision 2011/753/EU (p.73), the fact remains that this practice is still a glorified form of landfilling with a non-renewable resource that cannot be reused. The same applies to disposal at sea and land reclamation where, once again, the net result is resource wastage. This is an important consideration as it, once again, highlights what should be the ultimate aim of our actions: paper compliance with EU directives or ensuring the sustainable use of our resources.

“Moreover, it is also most likely that, in this case, the polluter pays principle is not being sufficiently applied and the market price of stone still does not reflect the real price that we are already ‘paying’ due to the environmental damage and resource wastage that we have endured. The situation is further compounded by the relentless eating up of more land for the edification of more vacant properties and the high prices that couples have to fork out when buying property for the first time. This is generating further problems not just on our environment, but on our social fabric and economy. Thus there is no net profit for the community from this resource wastage and consequently such a document needs to clearly acknowledge this situation.

Nevertheless, households are still being blamed:

“Malta’s waste treatment still relies on extensive landfilling without any form of pre- treatment. This may be attributed to a lack of commitment by a significant portion of Maltese households to commit themselves to recycling at source thereby producing a lower amount of recyclables and directing higher volumes of waste to landfill.” (p.52).

“On the other hand, in the eventuality that the projected targets are not achieved, households might need to be prepared to face the true costs involved in community waste management – as is the practice in other countries. This is a crucial issue that needs a detailed assessment and ownership by all political parties to avoid gaining political mileage from a national need.”

Conclusion

In conclusion the the KA said that it shares the document’s concern that “All this exercise will prove futile unless society commits itself to investing some of its time to secure better waste management practices” (p.183).

* Opinion papers were issued dealing with:

(a) Specific projects: e.g. the Restoration of Quarries by landfilling at ix-Xaghra tal-Maghlaq and il- Qasam il-Kbir – Qrendi/Siggiewi (18.03.04).

(b) Policy documents: e.g. the Solid Waste Management Strategy for the Maltese Islands (29.07.05 and 20.03.09).

(c) The re-development of the existing waste facility at Sant’Antnin: (02.09.05 and 24.09.05).

** References made to the “document” and page numbers refer, unless otherwise stated, to the Waste Management Plan for the Maltese Islands: A Resource Management Approach 2013 – 2020. Consultation Document October 2013. Ministry for Sustainable Development, Environment and Climate Change.

*** Kummissjoni Interdjocesana Ambjent (2013). Elezzjoni Generali 2013: Rakkomandazzjonijiet dwar ghazliet li l-partiti u l-poplu jridu jaghmlu fuq l-ambjent u l-izvilupp sostenibbli. Kurja tal-Arcisqof.

**** Ministry for the Environment (2001). A Solid Waste Management Strategy for the Maltese Islands. Office of the Director General, Works Division, Malta: Floriana.

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