We the Maltese environmental NGOs, meeting
in Valletta, on the 28th of June 2001 to draw up the Position
Paper of the Maltese NGOs on the implementation of the Acquis
Communitaire by the Government of Malta, propose the following
comments and suggestions:
1. The Maltese NGOs welcome the government's
initiative to:
a. Amend the Public Transport Authority Act that provides a framework
for subsidiary legislation, and establishes the Malta Transport
Authority
b. Amend the Merchant Shipping Act to
align Maltese legislation with the Community Acquis on crew qualifications
and other maritime standards.
c. No longer accept maritime vessels
over 25 years old as new entrants onto the Maltese register.
However the NGOs believe that no ship, irrespective of age, should
be registered under the Maltese flag if it is not completely
safe.
d. Provide a regular national bus service
in Malta that is in line with regulation (EEC) 1191/69 and Regulation
(EEC) 1107/70. Inspite of this the Maltese NGOs are seriously
concerned about the inefficient and ineffective bus service that
entices the use of private vehicles contributing significantly
to air pollution in Malta.
2. The Maltese NGOs welcome the government's
decision:
a. To adopt the new legislation by the fourth quarter of 2002
to transpose Directive 94/55/EC (transport of dangerous goods
by road), Directive 95/50/EC (uniform procedures for checks on
the transport of dangerous goods by road), and Directive 96/35/EC
(appointment and vocational qualification of safety advisers
for the transport of dangerous goods by road, rail and inland
waterway). We also agree that Malta will adhere to the European
Agreement concerning the International Carriage of Dangerous
Goods by Road by the fourth Quarter of 2002.
b. To amend the Dangerous Cargo Ships,
Marine Terminals and Facilities and Bunkering Regulations of
1996 by the fourth quarter of 2001 to achieve full compliance
with Directive 93/75/EEC (reporting requirements for vessels
bound or leaving Community and carrying dangerous or polluting
goods).
c. To comply with Directive 92/14/EEC
(operation of aeroplanes), Directive 89/629/EEC (noise emission
from civil subsonic jet aeroplanes), Directive 80/51/EEC (limitations
of noise emissions from subsonic aircraft) and Regulation (EEC)
925/99 (hushkitted aircraft) till accession.
3. The Maltese NGOs disagree with the
transitional period for:
a. Directive 96/96/EC (roadworthiness tests for motor vehicles
and their trailers) whereby the government is asking for a 2
year transition period. The Maltese NGOs insist that this directive
be transposed, implemented and enforced with immediate effect.
4. The Maltese NGOs DEMAND:
a. The necessary capacity building to increase the efficiency
and effectiveness of the implementation process, particularly
in the maritime safety field.
b. That the Maltese government intensifies
its efforts to transpose, apply and enforce the acquis in the
transport field.
c. That motor vehicles testing stations
(VRT) be really accountable and responsible, and that cars that
fail the test are in actual fact removed from circulation.
5. The Maltese NGOs also suggest that
in implementing the acquis on Transport the following actions
be taken into consideration:
a. The launch of an educational campaign, in collaboration with
NGOs and the Malta Transport Authority, whereby the advantages
of public transport are explained and public transport is promoted
as the BEST option.
b. To promote the concepts of "Producers'
responsibility", "The polluter pays principle"
and "The precautionary principle" for maritime, land
and air transport.
c. That the Malta Maritime Authority
enforces regulations and standards, to ensure that Maltese registered
ships (that are currently responsible for a large part of accidents
and therefore pollution) are no longer responsible for maritime
pollution due to accidents. We demand that the implementation
and enforcement of international maritime safety and pollution
standards be standard procedure to ensure maritime safety for
present and future generations. The NGOs are concerned about
the age and condition on some of the tankers flying the Maltese
flag.
d. That the transportation of dangerous
goods by land, sea and air be given priority.
e. That when dealing with transport,
its effects on health, air pollution, noise pollution, and climate
change be taken into consideration, as well as the social effects.
f. The end of the monopolies in the fields
of public transport, which will enable competition and a better,
more environmental friendly and widespread service.
g. The setting up of a tram and/or metro
system/s.
h. That ecologically friendly fuels (liquid
gas/unleaded petrol etc) be promoted (especially by reducing
the taxes on such fuels). That the quality of unleaded petrol
and diesel be further improved.
i. The creation of bicycle lanes and
pedestrian zones to promote these healthy and clean means of
transport, in view of the short distances travelled within villages
and towns in the Maltese Islands.
j. The extreme use of cars (in relation
to the population and infrastructure, due to size) means unsafe
roads, increased noise, terrible congestion, and very much higher
deaths and chronic illness from air pollution directly attributable
to cars.
k. Public transport needs to be supported
and revitalised: it needs better environmental performance and
a better service offer. Although public transport is generally
better than private car transport in its safety and environmental
performance, it is also the case that lack of investment and
old and poorly maintained vehicles undermine public transport's
environmental advantage. More importantly, public transport needs
to improve its image and service.
6. The Maltese NGOs insist that the transposition
of EU legislation is only a means to an end. We request the government
to state how it intends to ensure that these directives are being
IMPLEMENTED and to specify what instruments will be used to ensure
implementation of directives. Furthermore, the Maltese NGOs demand
that the government specify how this will be ENFORCED and what
corrective action will be taken against infringement.
Conclusion
We, the Maltese NGOs reiterate our commitment to act as "watch
dogs" over the accession process paying particular attention
to the transposition, implementation and enforcement of EU legislation
and its consequences on the Maltese environment. We commit ourselves
to discuss national strategies as well as to evaluate least cost
options for implementing the acquis communautaire.
