BACKGROUND
Agriculture in Malta accounted for 2.3%
of Gross Value Added in 2000, continuing a downward trend (2.5%
in 1999, 2.7% in 1998) . Employment in agriculture has remained
stable in 2000, accounting for 1.9% of total employment .
Approximately 47% of the cultivated land
is used for fodder crops, 42% for vegetables and most of the
remainder for vines and fruit trees. The Maltese climate enables
two crops to be grown each year in dry-land farming. About 8%
of Malta's cultivated land is irrigated, either from groundwater
or by treated wastewater from reservoirs around the Sant' Antnin
plant.
Malta has a large agricultural trade
deficit with the EU, with imports exceeding exports by an average
ratio of around 26:1. In 2000, EC imports of agricultural products
originating in Malta amounted to € 7.7 million while exports
to Malta amounted to € 209.5 million. On average, spring
potatoes account for around 70% of our agricultural exports,
whereas imports are made up of a much wider range of products.
According to the regular report published
in November 2001, the Commission states that "As regards
the transposition of the acquis, there has been little progress
in this area during the past year. Malta is still far from full
alignment and considerable efforts are still needed as regards
administrative capacity. However, the Maltese authorities have
progressed in assessing the impact of applying the Common Agriculture
Policy to Maltese agriculture and in preparing measures to accompany
this move. This must, as a matter of urgency, be translated into
concrete measures."
The regular report of the Commission
underlines that little progress has been made in the field of
Rural development and Forestry. The Trees and Woodlands
(Protection) regulations were issued in January 2001 as subsidiary
legislation under the Environment Protection Act for the preservation
of existing woodland and trees. In the area of Rural Development,
the Commission states that Malta needs to step up the efforts
to build up the administrative capacity to devise and, later
on, manage a rural development strategy. While rural development
support schemes would be important for Malta, administrative
preparations for the design and setting-up of such schemes have
not started yet. In particular, measures concerning less-favoured
areas could be important for rural development in Malta. Furthermore,
the implementation of agri-environmental measures is mandatory
upon accession. The administrative preparations for implementing
such measures have not started yet.
As for phytosanitary legislation,
the Parliament adopted an Act on the control of pesticides in
March 2001 and an Act on the control of plant pests and diseases
in July 2001. In spite of this progress, continuing alignment
of veterinary and phytosanitary legislation and upgrading of
inspection arrangements, in particular at future external borders,
should be pursued. The proposed Veterinary Act, which aims to
provide the legal framework for future alignment with the acquis,
still has to be adopted. Progress is also needed in the field
of animal nutrition. As regards administrative capacity in this
field, the veterinary service staff check all relevant activities,
from the issuing of licences, certificates for importation/exportation
and regular inspections in farms and slaughterhouses, to agri-food
processing establishments and retail outlets. The Department
can impose sanctions in the event of non-compliance with regulations.
The report also underlines that "No
progress can be reported…in relation to organic farming."
As regards food safety, in April 2001,
Malta has produced a Food Safety Strategy which outlines the
systems for co-ordination between the various official bodies
involved, their competencies, organisation and staffing. In particular,
it foresees the establishment of a Food Safety Commission that
would be the competent authority for food safety and the upgrading
of laboratories.
MALTA'S OBLIGATIONS WITH REGARD TO
AGRICULTURE-RELATED ACTIVITIES UNDER EU LEGISLATION
Pollution and nuisances
Council Directive 96/61/EC concerning
integrated pollution prevention and control
has as its objective the establishment of an integrated approach
to pollution control so as to prevent emissions into air, water
or soil wherever this is practicable. The activities stipulated
in the Directive which are most likely to apply to Malta are
large-scale slaughtering of livestock (more than 50 tonnes per
day), treatment and processing of vegetable raw materials to
produce food products (more than 300 tonnes per day) and treatment
and processing of milk (more than 200 tonnes per day). Although
such activities do take place in Malta, the likelihood is that
their average output does not reach the minimum level set by
the directive.
Water protection and management
Council Directive 76/464/EEC on pollution
caused by certain dangerous substances discharged into the aquatic
environment of the Community
is no longer so relevant to the Maltese situation now that another
directive on ground water has come into existence.
Council Decision 77/795/EEC establishing
a common procedure for the exchange of information on the quality
of surface fresh water. The effect
of this Directive in the Community is also bound to be limited
in Malta's case, simply because the Islands have almost no fresh
water bodies to speak of. The only sizeable body of water is
located at Chadwick Lakes, and it dries up almost completely
in Summer.
Council Directive 91/676/EEC of 12
December 1991 concerning the protection of waters against pollution
caused by nitrates from agricultural sources. Under Article 3,1 Member States are required
to identify in accordance with the criteria set out in Annex
I all waters affected by pollution and waters which could be
affected by pollution if action pursuant in Article 5 is not
taken. Annex I contains two lists which act as a guide in the
identification of such waters: one is a list of sectors of activity
whilst the other is a list of categories of substances. The following
sectors of activities may be identified as being involved in
the practice of agriculture in Malta, namely: agriculture itself,
fertiliser production, animal husbandry and disposal of sewage
sludge. On the other hand, the following are the categories of
substances most encountered in local agriculture-related activities:
"biocides and their derivatives", and "compounds
of nitrogen and phosphorus and other substances which may cause
euthrophication". Malta must then designate as vulnerable
all lands from which drainage of those waters identified as above
stated takes place, and inform the Commission within 6 months.
Designation of vulnerable waters has
in actual fact already started and is currently being carried
out by the Planning Authority. Every designation of a source
of such water leads to the establishment of a conceptual zone
of 100 m around the said source which is meant to be left free
of development. However, it appears that the implementation of
this rule is being compromised by the illegal abstraction of
water. Moreover, presently development of land is continuing
even within NVZs.
Article 4 binds Malta, within two years
of the notification of the Directive, (a) to establish a code
or codes of good agricultural practice, to be implemented by
farmers on a voluntary basis, (which should contain provisions
covering at least the items involving the storage and application
of manure and fertilizers , and (b) to set up where necessary
a programme, including the provision of training and information
for farmers, promoting the application of the code(s) of good
agricultural practice.
Article 5 sets a two-year period, following
the initial designation referred to in Article 3, (2) within
which Malta is bound by article 5 to establish action programmes
in respect of designated vulnerable zones as a means of reducing
water pollution caused or induced by nitrates from agricultural
sources and preventing further such pollution. These action programmes
are to contain the measures stipulated in Annex III of the Directive
as well as those measures prescribed in the code(s) of good agricultural
practice established in accordance with Article 4.
The obligation to take and test samples
of water as the means of identification of vulnerable zones is
established by article 6, through which the Maltese authorities
are given a maximum period of two years from the notification
of the Directive within which to monitor the nitrate concentration
in freshwaters over a period of one year: (i) at surface water
sampling stations as well as (ii) at sampling stations which
are representative of the groundwater aquifers of the Maltese
Islands. Such monitoring is to be carried out at regular intervals
and taking into account the provisions of Directive 80/778/EEC.
It is clear that compliance with the
above Directive requires a tight administrative setup. Indeed,
Article 12 lays down that Member States are to bring into force
the laws, regulations and administrative provisions necessary
to comply with this Directive within two years of its notification.
Chemicals, industrial risk and biotechnology
Genetically modified organisms are regulated
mainly by Directive 2001/18/EC on the deliberate release into
the environment of genetically modified organisms. So far
as is known, Malta does not presently host any actual production
of GMOs. Hence, Directive 2001/18 has only a limited impact on
our Islands. In view of the circumstances, the most relevant
provisions of the Directive may be identified as being those
under article 4, which relates to general obligations of Member
States. Under this article, Malta will be obliged to ensure -
in accordance with the precautionary principle - that all appropriate
measures are taken to avoid adverse effects on human health and
the environment which might arise from the deliberate release
or the placing on the market of GMOs, and to designate the competent
authority or authorities responsible for complying with the requirements
of the Directive. The authorities will also have to ensure that
the competent authority organises inspections and other control
measures as appropriate, to ensure compliance with the Directive.
In the event of a release of GMO(s) or placing on the market
as or in products for which no authorisation was given, they
are to a) see that the necessary measures are taken to terminate
the release or placing on the market, b) initiate remedial action
if necessary, and c) inform the public, the Commission and other
Member States.
Waste management and clean technology
Council Directive 86/278/EEC of 12
June 1986 on the protection of the environment, and in particular
of the soil, when sewage sludge is used in agriculture: The relevant parts of the sewage sludge directive
86/278/EEC for Malta are basically those contained in articles
5 to 8 and 10 to 11. Briefly, these deal with regulation of the
use of sludge so as to avoid heavy metal accumulation in the
soil (article 5), conditions for the allowable use of untreated
sludge (article 6), circumstances when the use of sludge on grasslands
and soil is to be prohibited (article 7), rules to be observed
when utilising sludge (article 8), the keeping of up-to-date
records relating to sludge use (article 10), and allowable exemptions
(article 11)
Presently, there is only one sewage treatment
plant in the Maltese Islands, and this is the Sant' Antnin recycling
plant, which has been specifically intended to supply farmers
with water for crop cultivation. There may be plans to increase
the number of sewage treatment plants, especially in view of
Malta's high population density. However, it is likely that the
majority of these plants would be intended to offload the treated
sewage into the sea. Due to the small size of local farms, private
plants are not feasible; the main danger to the environment and
human health would seem more likely to come from the illegal
but nevertheless still occurring use of raw sewage from farm
cess-pits.
International cooperation
"Protocol for the protection
of the Mediterranean sea against pollution from land-based sources
and activities": Part A of Annex I of the Protocol lists
the sectors of activity to which the Protocol applies. The following
have been identified as being those sectors which are most related
to agricultural activity: fertiliser production; agriculture;
animal husbandry; disposal of sewage sludge.
In Part C of Annex I, the following categories
of substances and sources of pollution have been identified as
being most liable to be generated by agricultural activity. The
Protocol states that these categories of substances will serve
as guidance in the preparation of action plans, programmes and
measures (emphasis added). The point here is that the list of
substances is not intended by the legislator to be exhaustive;
it is merely indicative. In fact, Member States are directed
to look out for any other substances likely to fall within the
scope of the Protocol using as guidance as well Part B of Annex
I.
THE NGOS RECOMMENDATIONS
The Maltese NGOs regretfully point out
that the whole discussion over the agricultural acquis in Malta,
in centred around the issue that Malta's agricultural sector
is not as competitive as that in Europe. The only concern of
the Maltese people seems to be the removal of protection in this
sector, and the assistance programmes that we might be eligible
to, with little or no attention given to the importance of sustainable
agriculture.
Although the Government's Position on
agriculture had not been made public by the time that this paper
was prepared, the Maltese NGOs would like to caution against
a policy based on intensive agriculture production. Experience
in Member States is showing that this policy is not sustainable
and has led to:
- specialisation (monocultures) and concentration
of crops and livestock which could lead to the extinction of
local species both in terms of flora and fauna and consequent
loss of genetic diversity. With regard to flora, the negative
effects of intensive production may affect both species which
are presently cultivated by Maltese farmers as well as species
growing in the wild;
- an increase in organic and mineral over-fertilisation, leading
to the favouring of the more nitrophilous species over the others;
- mechanisation
- substantial amounts of liquid and solid waste
These have led to deteriorating air,
water and soil quality, as well as biodiversity through the degradation
of habitats, whether through outright elimination (as in the
case of the particular habitat presently found in fields throughout
the Islands) or else through gradual destruction by toxification
and other means. Furthermore in Malta, this could lead to the
removal of rubble walls, which not only form part of our landscape
but are also a very important habitat for a number of species
- particularly certain plants as well as a number of invertebrates
and reptiles, and the weasel.
Furthermore, the NGOs want to draw attention
to a number of practices, some of which are illegal, which are
nevertheless still occurring in Maltese agriculture. Amongst
these is:
- over-extraction of water from the lower
water table, leading to increased salinisation of the remaining
water within the table with consequent eventual negative effects
on human health as well as on the soil on which the water is
used;
- the use of raw sewage for watering and/or fertilising purposes
Therefore the NGOs believe that a sound
agricultural policy for Malta should include the following aspects:
§
taking into consideration the particular environmental values
of the Maltese agricultural landscape;
§
effective consultation and communication with all the local formers'
organisations and agriculture lobbies
§
a protective orientation towards the environment entailing inter
alia the promotion of the more traditional farming methods (particularly
those which conserve and protect the natural environment and
are sustainable) and of good agricultural practices. This goal
may be achieved through measures such as the issuing of compensatory
payments (which should be area-based as opposed to headage-based),
as well as the operation of special training schemes for farmers,
which measures should have the effect of discouraging agriculture
based on intensive chemically supported and non-sustainable methods,
in crop-growing as well as breeding;
§
drawing up a Code of Good Agricultural Practice, the details
of which will need to be supplemented by further research and
development and which must ultimately be an expression of the
particular reality of Maltese agriculture;
§
supporting the creation of special agri environmental programmes,
whose goal will be the protection of biotic variety and nature;
§
a substantial reduction in the use of pesticides and fertilisers
possibly through taxes;
§
limiting the use of intensive production methods that have risky
side effects on food quality and can endanger health, biotic
diversity, environment, etc;
§
introducing compulsory eco-labelling of food products, including
those which contain genetically modified organisms.
§
promoting organic agriculture through loans and subsidies
§
implementation of the EU Directive on Nitrates before entering
the EU
§
applications of inorganic fertilisers, manures and treated sewage
by-products, including water, by farmers to be made only after
the determination of the Nitrate content of the soil and of the
crops' requirements have been determined. Also, the avoidance
of 'insurance ' application of Nitrates, and the keeping of detailed
records of the amount and dates of manure and fertilizer application,
irrigation, cropping and soil analyses;
§
Storage facilities for organic manures and dirty water need to
be structurally sound and impermeable, and large enough to deal
with livestock quantities for an appropriate duration
§
Crop covers to be established and maintained between September
and April, thus minimising the amount of bare soil and reducing
the risk of nitrate transfer through water drainage. Preferably,
nitrogen-utilising crops should be sown to create cover, rather
than simply leaving fields fallow;
§
the creation of new jobs for farmers in the sector of agro-tourism
and environmental protection activities.
§
furthering the use of organic waste in agriculture as fertiliser
§
the proper enforcement of laws relating to the disposal of liquid
and solid waste especially in livestock farms
§
production of second-class water from municipal liquid waste
§
the prohibiting of illegal farming of karst areas; these areas
are ecologically valuable habitats, which are also vital for
their role in the recycling of water to aquifers. Legislation
should therefore be modified - or enacted, as the case may be
- to provide for prohibiting the creation of new farmland, the
penalisation of the illegal dumping of development soil on karst
areas and monitoring of the farming practices of existing illegal
but registered farms.
