A burning hot waste disposal development has been slipping quietly through the back door down at Marsa. Just as you were busy thinking what sort of trees might look (and smell) nice on the Maghtab rehabilitated landfill park, it is time to sit up and take notice.

In Malta the public are being treated like trash when it comes to Government fully communicating its long-term strategy for waste management. At the beginning of the year we were told that a revised waste management strategy would be published "shortly". Nine months later we are still waiting. In spite of a documented promise to set up a specific programme for keeping the public updated with strategy as it unfolds this is not being honoured in all areas of waste facility development.

St Luke's, Mater Dei, abattoir

The discovery of how a new Lm4 million incinerator installed at the Marsa abbatoir was too large for abbatoir needs drew the curiosity of the Sunday newspaper It-Torca in March.

The Federation of Industry, which holds a favourable opinion on controlled incineration as a solution to packaging waste and expected to be consulted, balked at the surprise news that WasteServ was to operate an over-capacity incinerator. The FOI saw this as a sure indication that the incinerator was intended for waste other than animal carcases. Chief among the FOI's concerns were fears that there would be no stopping the waste company charging whatever it liked to incinerate waste generated by industry (mostly packaging).

A "technical committee" concluded that the new incinerator at the abattoir could, with some minor changes, handle waste from the Mater Dei Hospital. Suddenly the spectre of a mixed waste incinerator was being floated. The "treatment" (burning) of abbatoir, packaging, clinical and possibly other types of waste was becoming more than a notion. Observers wonder how far down the chute we have already come toward a full blown municipal waste incinerator, against all recommendations for alternative solutions.

If one incinerator breaks down then another will be needed as a stand-by or untreated waste would pile up and EU directives would be broken. A series of tender delays have reduced confidence that an improved incinerator would be operational at St Luke's by the time Mater Dei Hospital opens.

Consultation up in smoke

There are many questions surrounding the increase of incineration in Malta. None of them are being fully and openly addressed.

No one seemed in the least alarmed when a permit was issued for the burning of abattoir waste at the beginning of the year. It was well known that the Marsa abattoir incinerator, like its counterpart in Gozo, was not up to scratch and in dire need of improvement.

In a press release last January, government concern about the impact of the landfill on people's lives was expressed alongside the news that it was again considering incineration by 2013. The target date had been set in a draft waste management strategy but no decision had been announced until this year. WasteServ and Government are pointing a finger at the EU deadlines faced by Malta to pre-treat waste before sending it to landfill.

Public attention at the time the press release appeared was taken up with reports of a "shackled, ineffective, toothless, unaccountable" MEPA in the face of last February's criminal mudslide at Xemxija. With even greater planning controversies just around the corner, any murmurs in the press about the need for "additional facilities" to treat waste went by largely without comment.

As long as black smoke continues to curl maliciously out of the St Luke's Hospital incinerator, endangering the health of all in the vicinity, Government and its closely related waste management company prefer to say as little as possible about future plans to incinerate waste.

Breaching the regulations

It is becoming evident that this government is ignoring a number of legal planning requirements.

Tweaking existing permits for the incineration of abattoir waste (Category II) behind closed doors to switch to hazardous waste treatment ( Category I ) is simply not good enough. The purpose of the present incinerator at the abattoir as declared in PA 2201/01 was "to process abattoir and various food-derived waste streams." The use of the incinerator for hazardous wastes was not taken into account under this permit, which was only subjected to a lesser form of Environment Impact Assessment known as an Environmental Planning Statement. 

The Solid Waste Management Strategy 2001 refers to pharmaceutical waste as "potentially hazardous waste." Industrial and clinical waste are also considered problematic types of waste.

In an article in The Times ("Abattoir Incinerator to be fully utilised", August 14), the Environment Ministry was quoted as saying that "the government was drawing up a comprehensive plan to incinerate waste at the abbattoir, including industrial, clinical and pharmaceutical waste." Once these operations begin it will mean that the facility has graduated to a Category I incinerator which requires a full blown Environment Impact Assessment (EIA).

According to section 2.7 of Schedule 1 of the EIA regulations (LN 204/01) transposed from the EU directive an Environmental Impact Statement must be drawn up following the correct procedure for incinerators which treat hazardous waste. An Environment Impact Statement based on the findings of the assessment must be made available to the general public during a public consultation phase. Following this, and before a final decision is taken, a public hearing must be held. According to Maltese legislations, the public should have a right to comment on where the incineration project is sited or whether or not it is feasible.

The EU introduced measures in 2000 to prevent and reduce the effects of incinerating dangerous waste on the environment and public health. A list of strict conditions has been put forward for the operation of waste incineration plants and emission limits have been established. The EU includes cement kilns and power plants in its incineration policy.

Strategy under fire

A series of tender flops has plagued a ten-year plea to stem the flow of deadly emissions into the Pietà environment. Four Greenpeace activists faced criminal proceedings in 2001 after they unfurled a banner on the chimney stack of the incinerator at St Luke's Hospital. The environment organisation retorted that it was the authorities themselves which should be held accountable for their failure to protect public health and the environment rather than attempt to restrain peaceful protesters.

The activists noted that commitments made by the Maltese government on a national level towards environmental protection continue to be postponed or disregarded. They added that the Environment Minister was also failing on an international level since Malta had signed an international convention, aimed at banning Persistent Organic Pollutants (POPs) such as cancer-causing dioxins, which are emitted by incinerators, such as the one at Pietà.

Greenpeace was concerned that the same minister was proposing a waste management strategy which includes the development of more incinerators. It was envisaged at the time that Malta could hold out against incineration until 2013 but the decision seems to have been rushed in much too soon and without attention to the correct procedures.

Maltese environment groups have long pointed out that the strategy did not properly address the primary aim of waste prevention and reduction since it lacked targets to reduce the amount and toxicity of materials entering the island which eventually enter the waste stream.

The strategy's proposals for production of refuse-derived fuel (RDF) from projected waste treatement facilities, such as MBT (mechanical biological treatment) and MRF (materials recycling facility), which both feature in the 2001 waste strategy, all point to incineration.

Lack of faith

Government has not learnt any lessons on how not to handle sensitive waste issues with regard to public involvement. It has not understood that public participation in the planning process is something to which the EU gives full recognition and takes very seriously.

Skimping on EIA's and public consultation only to run into trouble later, as we have seen with the Sant'Antnin plant, is a clear example of planning gone wrong. Allowing the Labour Party leverage with its claims of solving the St Luke's incinerator problem within six months of election is inviting sure disaster in the political scramble over waste management developments.

Perhaps public fears surrounding incineration are not unfounded. Faith in technology advancements may be cultivated to some extent by making people more familiar with the processes involved. More difficult to secure is faith in the operator.

Polidano Bros Co Ltd has claimed that a permit exists for the dumping by barge directly out to sea. While this may be correct, how are we to be sure that other demolition waste, temporarily stored in a quarry under payment, was not being illegally dumped out of the Freeport?

The firm has been awarded a contract for disposal of tyres. While quantities of fine tyre dust in another quarry belonging to the operator are evident there is no official explanation so far on what is being done with the tyres. EU directives permit the burning of used tyres as fuel only under certain conditions.

Building construction suppliers, such as Polidano Bros, Blokrete Ltd and Ballut Blocks have shown an interest in poor quality limestone for uses not requiring the strongest kind of concrete. One way to dispose of incinerator ash is to put it into building blocks.

Involvement in waste management of operators, some of whom may have a highly questionable track record, is possibly the aspect that is most worrying to a public fast losing its faith in the way things are done in this country.