When is a field irrigated and when is it not irrigated? A family who have cultivated a rehabilitated quarry in Birzebbuga for long years have been told that their land does not qualify as irrigated. This despite the presence of old reservoirs built into the rock supplying all their irrigation needs through every season.

The site at Tal-Papa, which includes a habitat for native frogs, is one of many disputed extensions spilling over into land originally designated as protected under previous Outside Development Zone status.

Amendments to local plans were bulldozed through Parliament as Government chose to exempt the additional areas from a proper Strategic Environment Assessment. The excuse presented to the EU for this was that the unprecedented and sudden expansion of towns and villages all over Malta and Gozo into the countryside, mostly arable land, was a "continuation" of the local plans.

Ill-advised storm channel

A large open bay in early Neolithic and Bronze Age time and an important Roman port, Burmarrad harbour was still in use but already partially closed by silting in the Middle Ages. Today the port is buried under fields.

Silt still washes from the valleys, making today's fertile plain productive, playing an important role in keeping saline levels down by annual washing with rainwater in the storm season as part of a natural cycle. To the alarm of farmers, who have not been properly consulted, a plan to build diversion channels is being rushed ahead before the permitting process has been completed.

The second largest catchment area after Marsa, the plain is already well supplied with stone flood control channels built in Victorian times. Timothy Gambin, a specialist on ports from ancient times to the Middle Ages, has pointed out to the project managers that by spending a fraction of the cost to construct new channels the existing ones could be cleaned up and used to better advantage.

This opinion has also been expressed by numerous farmers who have been working the fields in the area for generations.

Perched for a fall

"You do not have to be a graduate to predict that the sand will disappear". An editorial in a local newspaper last month on the pilot artificial beach experiment at Bugibba speculated that the government must be planning to open up a new market in importation of sand.

In a counter-statement the Tourism Ministry cited extensive studies. To be more precise, the only study done for the Bugibba project was an economic report, apart from a project description statement for the perched beach. A separate environmental planning statement, normally required for such a project, was waived.

Beach replenishment exercises of this type in a number of bays in Malta and Gozo may turn out to be an expensive experiment in both economic and environmental terms.

In Bugibba the perched platform of sand covering the rocks was opened with fanfare last July, closed for bathing due to a hiccup in August involving a sewage leak, then reopened. With the first seasonal grigale, storm waves swept over the containing wall, washing some of the quarry grit away.

Not quite away... in the environment it always goes somewhere. In this case the pink-coloured grit, an alien material to natural coastal surroundings, ended up in the sea while some of it was washed up onto the rocky shore.

The casual manner in which beach replenishment projects are currently being addressed lends nothing to public confidence in their proper siting and management.

St George's Bay was the first artificial beach to be developed using sand imported from a quarry in Jordan. The development permit prohibited use of sand from the seabed. Earlier beach extension projects at Kalafrana and Pretty Bay used sand dredged from ports.

This practice was dropped after the Malta Council of Science and Technology (MCST) submitted the first State of the Environment Report to the Environment Protection Department in 1998. A potential problem was noted for beach reclamation projects which used sediments dredged from local ports and semi-enclosed creeks.

"Such areas are more often then not, exposed to a wide range of marine contaminants such as pesticides, hydrocarbons, heavy metals, etc. Many of such contaminants are known to accumulate in bottom sediments and are quite likely to present a potential health and environmental risk if used for beach reclamation."

Insufficient knowledge of hydrodynamics was also identified in the report. In some Mediterranean countries where efforts to reclaim eroded sandy beaches have succeeded, this was based on "long-term baseline information on local sea currents, nature of near-shore bottoms and sediment budget of the particular beach."

Any human intervention leading to beach reclamation must compliment and enhance already existing deposit of sand by natural forces (wind and waves). Otherwise, as the report says, such initiatives are bound to be a waste of time and sand, not to mention money. The final recommendation was that the level of information on coastal dynamics needed to be improved before projects of this type are carried out.

When Sannat council dumped sand at Mgarr ix-Xini without a permit MEPA issued a statement warning that beach replenishment projects "should be carried out with great sensitivity and only after an environmental impact assessment has been carried out".

The required environmental planning statement (a lesser form of EIA) for the development of a perched artificial beach in Bugibba was waived by MEPA. The authority claimed that the project description statement appeared to be sufficiently detailed.

"Trying to create a beach on an exposed piece of coastline only results in the sand being carried away by storms, never to return," declares the Project Description Statement. The report goes on to describe how an artificial perched beach is supposed to work, claiming that any wave overtopping in rough weather drains away quickly through pipes laid below. However it is clear that the beach is not performing as predicted with sand being swept out by the first storm of winter requiring a top up each year while producing a cumulative load over the years which will smother the seabed.

Concrete slabs protecting the drainpipes are stapled to the rock. Should the project not be successful the staples are to be cut flush with the rock with the drain pipes and concrete removed so that "nothing will be left visible" according to the developers.

MEPA's own structure plan policy RCO 16 calls for all beach and seabed enhancement to be subjected to environmental impact analyses. Even if certain beaches are now considered to be urban this does not reduce the negative effect which replenishment may have on the surrounding coastline and seabed.

Cornwall County Council has recently thrown out a beach project requiring regular replenishment simply because this is considered unsustainable.

Another MEPA structure plan policy, RCO 23, lays down that the enlargement of existing beaches and the creation of new ones will only be allowed following a scientific study of short- and long-term environmental, social, and economic impacts.

No reference was made to beach reclamation issues in the planning authority's 2005 update of the State of the Environment Report. Before Malta Tourism Authority's plans for more deposit of quarry sand on the beach near Ta' Fra Ben proceed all efforts should be made to see that this undergoes serious assessment through MEPA's environment protection department.

Two small bays at St Julian's have been earmarked in the local plans for silting up with more quarry sand to create artificial beaches near the Neptunes waterpolo pitch and the fishing quay next to Independence Garden.

Pivotal to the proposal to destroy natural coastline for development of a yacht marina village is the ability of the developers to sell the idea of a beach extension at Hondoq ir-Rummien. Simple folk who are more familiar with the wind and the waves are convinced that the Bugibba experience will be more than certain to repeat itself on such an exposed coastline.

Green procurement

Ministries participating in the government's Green Network are still not posted on the website (www.greennetwork.gov.mt). Some ninistries are reported to be doing better than others. If there is no sign of improvement from the slack ones then Minister George Pullincino has declared that he is prepared to name and shame the not-so-green ministries.

Bio-safety

While it is difficult for an EU member state to declare itself GMO-free it would still be possible to have GMO-free zones declared by the farmers. They would have to give economic reasons to support such a decision. Claims from farmers that planting of genetically modified crops in their region could contaminate organic crops may be considered as a valid argument for setting up such zones.

Members of the public can register for notification alert using the e-mail address bcc.secretariat@mepa.org.mt to be informed about GMO applications under review by MEPA and the Biosafety Co-ordinating Committee. The words "registration for notification alert" should be included in the e-mail subject title. When a new notification becomes available registered users will be informed of the deadline for submission of comments.

A draft of the National Biosafety Framework is now open for public consultation.

Eco-contribution and WEEE

Plug it in, switch it on and you can be certain there is an EU directive for it. Making landfills and incineration safer is one of the reasons behind the WEEE directive on waste electrical and electronic equipment.

Companies are prepared to accept responsibility for electric and electronic waste if the eco-contribution paid on these items by importers and retailers goes directly toward the cost of their recovery. A legal notice is due out shortly to refund eco-contributors according to the percentage of products recycled.