The Earth Systems Association (ESA) greatly appreciates the efforts of ERA in achieving a sustainable future for Malta. At the same time, we have some concerns that we feel must be addressed.

Upon evaluation, ESA considers the strategic objectives of the National Strategy for the Environment (NSE) 2050 to lack detail in several areas. Furthermore, the suggestions made in the strategy do not provide a clear path for Malta’s environmental future since a number of the points presented have already been mentioned in previous reports and acted on, therefore the public might feel that a repetition of former events might occur again.

In the NSE 2050, the need for more understanding regarding particular scientific topics is emphasized; however, data is already available on many of the topics included, such as air pollution's effects on human health. ESA would also like to highlight that there is no timeline provided in the report regarding how each improvement will be implemented. This step should be taken to offer a general idea to the public about the required changes and how long each one would take to execute.

Furthermore, an increase in public briefings would also encourage actions to be taken faster and more effectively due to concise deadlines; this would also help with prioritising more critical issues over others.
 

Strategic Objective 1

Objective 1.1:

• Set times for delivery trucks out of traffic rush hours to reduce congestion/pollution. Delivery and construction industry drivers stuck in traffic may have to rush to complete their deliveries/tasks or be fatigued, thereby increasing risks for car drivers, motorbikes, and bikes as well as other traffic-related accidents. By forcing a change in operating hours not only would there be a reduction in emissions, due to lower traffic congestion, but there would also be an increase in operational efficiency and cost-effectiveness due to lower fuel costs, thus serving as a good incentive for businesses.

• A push notification service that indicates accidents, road closures, and construction sites to reduce traffic congestion, thereby reducing air pollution and improving the public transport system.

• Implement an alternative grid, with a segregated infrastructural network to provide a safe and efficient alternative for those wishing to cycle to their destination. This would require maintaining and possibly fixing some country lanes as well as possibly creating pedestrian bridges. Such a design has already been envisioned by Perit Daniel Scerri.

Objective 1.4:

• Urban greening initiatives need to be constructed in areas considered to be hotspots near vulnerable groups. These will help reduce air pollution levels, mainly
CO2 and Particulate Matter, however, they will also help reduce the urban heat island effect through evapotranspiration, thereby driving down the need for lower air conditioning temperatures as well as acting as noise buffers. In the case of private residencies, stronger incentives need to be given for the construction of roof gardens, and possibly free gardening classes should be given so that people are not discouraged from taking care of roofs or facades.

STRATEGIC OBJECTIVE 2

Objective 2.1:

• An area encompassing anywhere between 7% and 10% of any given district shall be allocated for the sole purpose of green spaces, containing endemic and pollinating vegetation (such as Cercis siliquastrum and Laurus nobilis), particularly the kind that provides shade. Furthermore, elements of a community garden can be included in the plan to build a stronger sense of community and raise interaction with nature and within the community itself.

Objective 2.2:

• Make incentives for green and blue infrastructure more readily available and accessible. For people unable to afford such a project, but wishing to take on such an initiative, the government should make available funds, along with building and maintenance guidelines, to increase green infrastructure and encourage green jobs.

Objective 2.3:

• The public transport system should increase the frequency of bus routes so that buses pass by their respective stops more often. Until improvements are made to the public transport system, the Tal-Linja direct service should be enhanced and incorporated nationwide. Furthermore, a push notification system should be implemented on the Tal-Linja app, indicating delays and rerouting of the Tal-Linja service.

Objective 2.5:

• Employ more security systems (e.g. motion sensors etc) in public spaces such as schools to reduce the number of lights turned on during the night. This will improve human health, particularly concerning sleep as well as reduce interference with the natural environment. Furthermore, night lights should be switched to red lights as these have a lower tendency of interrupting the natural sleep cycle.

• Heavy-duty vehicles should not be allowed on roads between 23:00 hours and 05:00 hours to reduce the amount of noise generated.

• Parks and green spaces should be left with a natural surface where possible to diffuse noise and allow for rain infiltration.

Objective 2.7:

• Redefine the word commitment and allocate a time period to it, or reword the objective to make it more long-term or appealing.

• Create a task force dedicated to taking care of vegetation planted by the community, thereby increasing green jobs.

STRATEGIC OBJECTIVE 3

As a whole, the strategic objectives under goal 3 are very similar and it is difficult to make a distinction between every one of them. We recommend being clear and specific with further details provided.

Objective 3.2:

• Nurseries can be used to help within the initial growth stages of plants, to reduce their vulnerability. These will then be transplanted into their natural ecosystems.

Objective 3.3:

• Once an ecosystem is restored, particularly a large one, trained staff should be employed with a role such as that of a ranger to maintain and safeguard that same area.

• Encourage the use of community gardening and outdoor classes thereby increasing appreciation for the ecosystem.

STRATEGIC OBJECTIVE 4

Objective 4.2:

• In reference to “The private sector will be encouraged and enabled to invest in eco- friendly activities to reduce their environmental footprint,” ESA believes that while encouragement is admirable, stricter and more stringent action needs to be taken. A focus should be placed on legislation and regulation with stronger enforcement across all sectors, both private and public.

Objective 4.3:

• While some members of the public are already well educated about waste, there is still room for improvement; we feel more focus should be placed on behavioural change alongside educating the public. The focus should be put on creating law and more importantly, enforcing it.

• Monitoring systems should be placed in rural areas to minimise illegal dumping. Polluters should be made to do community service and pay a fine for the damages caused.

Objective 4.4:

• A system of self-reliance should be drafted in cases of global emergencies, such as conflict, whereby waste cannot be exported.

• Stricter control needs to be placed on waste carriers, concerning documentation, road behaviour, site upkeep, and waste disposal methods.

Objective 4.6:

• Encourage and support local producers in packaging their products sustainably.

• Incentivise local sellers and retailers to acquire their goods from more sustainable producers.

• Encourage locals to purchase products that have been produced on the Maltese Islands, such as through subsidies.

STRATEGIC OBJECTIVE 5

Objective 5.1:

• Developers should be encouraged to build on land containing existing property before considering building on agricultural or ODZ land.

Objective 5.2:

• A monitoring system beforehand and a prevention system after. The monitoring systems should form part of the EIA process, to halt or downsize any projects which may prove to cause mass degradation/impact.

Objective 5.4:

• Certain strategies in the EU’s 2021 Common Agricultural Policy should be better interlinked to the Maltese agricultural situation and made to address small agricultural holdings.

• The government should provide incentives for landowners to rent out their fields to the government. This would result in the creation of new green jobs, increased production of local goods, and a reduction in the effects of soil erosion and land degradation.

Objective 5.6:

• Encourage quarry owners to increase operational capacity by using all by-products generated in their day-to-day operations.

• Create a grant for construction companies to upgrade their vehicles, machines, and equipment to be more sustainable.

STRATEGIC OBJECTIVE 6

Objective 6.1:

• Organise organic farming workshops and offer incentives for farmers, to reduce pesticide and fertiliser use, thereby reducing the harm caused to the marine and terrestrial environment (also applies to strategic goal 5.2).

• Research and funding are to be allocated for the creation of an ALDFG circular economy.

• A yearly stock-take is to be imposed on all fishermen regarding their fishing gear. Any torn, or damaged fishing gear is to be disposed of at the landing site upon logbook submission and taken note of by the relevant authorities. The fishermen are to be fined for any ALDFG which is unaccounted for.

• Enforce and monitor the current tracking system to ensure that all the fishermen are using it correctly.

Objective 6.2:

• MAFA should be included as a key player in the protection of MPAs, considering the ministry has access to fishing efforts.

Objective 6.3:

• Define a reasonable time scale. A natural recovery is an optimistic approach. Given that it is harder to fully observe the marine environment and activities occurring within it, such as trawling, already degraded environments would not have sufficient time to recover. Restoration and rehabilitation should therefore be
given priority.

Objective 6.4:

• Why are we considering oil and gas exploration when we are aiming to go carbon neutral?

• Can sea-driven sustainable energies such as Ocean Thermal Energy Conversion and wave-derived energy be considered?

STRATEGIC OBJECTIVE 7

In general, a lot of rainwater gets wasted - this can be used for agriculture or other purposes. There is also a need to focus on practical and feasible solutions for aquifer recharge (such as rainwater).

Objective 7.2/3:

• Educate and encourage people (through awareness campaigns, incentives, and subsidising equipment) to utilise air-conditioning water for gardening or other purposes.

Objective 7.4:

• Non-residential water tariffs should be revised and should correspond to electricity, i.e., the more you use, the more you pay.

STRATEGIC OBJECTIVE 8

Objective 8.6:

• Make environmental education obligatory at primary and secondary school levels.

• Promote and support training courses and certification in relevant ISOs, EMAS and BREEAM.