“Never have Malta’s groundwater resources been in such a precarious state. Ground water is being severely over-exploited.”

This grim state of affairs was noted two years ago by a member of the Malta Water Association, an organisation which describes itself as a think tank of water and sustainability professionals.

Even though agriculture is a major consumer of water, national plans for water and agriculture are being developed in isolation from each other. Occasional inter-ministerial consultations have not been enough to ensure that these two policies point in the same direction.

Our main groundwater resources are in a poor state. Groundwater has, for many decades, been over-exploited beyond the sustainable replacement by rainwater recharge.

The Sustainable Energy and Water Conservation Unit has been tasked with drawing up the national water management plan and has recently issued a second river basin management plan for the EU.

Malta is under tremendous pressure to conform with the requirements of the EU water framework directive. On the other hand, the sluggish pace of a national policy for water in Malta may be partly due to the reluctance to confront major controversial issues – especially the private, free, and often illegal extraction of groundwater.

Warnings about the island’s water situation, and particularly its impact on Maltese agriculture, stretch back over a decade. Ten years have slipped by since a UN study by food and agriculture experts concluded that Malta’s main stumbling block with regard to an impending water crisis was lack of good governance.

“Tough decisions will have to be made immediately if the environmental sustainability of Malta’s aquifer systems is to be achieved,” said the 2006 report.

Curbing the amount of water consumed by agriculture was one of several recommendations. Among the stumbling blocks highlighted in the report were fragmented decision-making, poorly aligned policies and scant awareness of the consequences of continuing to mismanage the underground water table.

Today, with an ever worsening water status, these same challenges will stay with us as long as politicians fail to come to grips with reality and act.

Although there is high demand for domestic, tourism and industrial uses, agriculture remains the principle consumer of national water resources.

A National Agriculture Policy conference was held recently to identify issues inhibiting both economic growth and sustainability in the agricultural sector. The discussion was intended to guide those drafting a national plan for agriculture for the years 2016 to 2025.

Government policy does not foresee the introduction of charges for groundwater extracted from agricultural boreholes. The cost to the farmer for borehole drilling and pumping is around 20 cents but can stretch to €5 for low-production boreholes.

The cost of production per cubic metre of reverse osmosis water at desalination plants is estimated to be about 75 cents. These are basically operational costs.

Popular policy is not the same as sound policy. It may win elections, but does little to solve endemic problems, such as those with which Malta struggles in almost all sectors, including agriculture- Malta Water Association

Costs related to pollution of groundwater (saline intrusion, nitrification) which are not currently being factored in, will have to be met by Maltese society in future.

The government paper acknowledges that there are data gaps when it comes to the amount of water demand, what amount is taken from boreholes and what types of crops are planted.

As the paper admits, all this results in “an inability to produce extraction control mechanisms”.

Choosing to plant crops that need less water to grow would help conserve water. This type of crop planning could make a difference if only the organisational structures for it were set up.

During the public consultation process there was a strong reaction from the Malta Water Association (MWA) as can be seen by their response:

“The weakness of the government paper lies with it being restricted to factors internal to the agriculture sector without locating the national policy within the economy and in relation to other sectors.

“There are many factors which decide the economic, social and environmental effectiveness of a sector. All should be considered within any policy framework.

“The national policy sets the worthy goal of increasing incomes from agriculture. Yet it speaks of agriculture in isolation. It avoids consideration of the sector’s position as it relates to other sectors. A national policy must locate each sector within the economy.”

Good policy development depends on the quality of the information and analysis that underpins it. As much of this evidence is lacking, the basis of the policy balances rather sketchily on ideas, discussions and popular political goals. Public discussion is insufficient to draw sound and reliable conclusions.

“The Ministry of Agriculture has decided on a potentially perilous path of consulting the public and stakeholders before any serious analysis was done – floating ideas before determining their cost, viability and expected contribution.”

A productive framework for consultation should outline the main findings of research and policy analysis. It should be candid about the bad news and never a simple reiteration of electoral promises.

“People instantly know when the motive of consultation is to seek votes.”

This is not the first time farmers have participated in “exploring of ideas” sessions with ministry staff.

Sadly, the same unresolved problems and uncertainties have persisted. The MWA says that now these appear worse than ever with a drought year, deteriorating water status and apparent confusion within the government as to what to do.

“The ministry really doesn’t know with any certainty whether the various ideas they are proposing are feasible, affordable or transformative because they are not armed with reliable analytical information. If they are pressed on specifics they will either be guessing or taking big risks.

“Effective policy cannot be created purely from promises made in election manifestos, opinions and group debates, however creative and inclusive these may be. All of these are a valid and important part of the process but on their own they do not create sound policy.

“Popular policy is not the same as sound policy. It may win elections, but does little to solve endemic problems, such as those with which Malta struggles in almost all sectors, including agriculture.”

Many observations in the paper appear to be speculative, not based on facts. A deficient ‘economic analysis’ in a companion paper does not make up for this weakness. There are many valid ideas in the paper. However, these need to be analysed and tested prior to the formulation of an agricultural policy.

The association has cautioned that it makes no sense for the agricultural policy and the water policy to be prepared separately. Otherwise Malta will have an agriculture sector policy that burdens the water sector with expectations before the latter sector has been able to come up with the analytical framework needed to derive its own policy.

For these two major policy sectors there is no appropriate process of analysis to develop policy frameworks as a basis for developing national plans and sound policy.

The Today Public Policy Institute delved into this issue in detail in a report published last year.

Government is the custodian of the nation’s resources and is responsible for making the most effective possible public investments. Just because an idea seems popular is not enough reason to invest in it.

The most important missing element is the fact that Maltese agriculture exists within a wider EU market. Any assumptions about demand must be based on research, not opinion and limited consultation.

It is doubtful whether 2016 will be the year in which a national water policy finally sees the light of day. Hope springs eternal.

https://drive.google.com/file/d/0BzKiit7NebRaMDFjY3c4N3g2RFk/view