The Environment and Resources Authority – ERA – has published a National Strategy for the Environment 2050 for public consultation.

One might ask what is the need for such public consultation when most of the strategies listed are already legal obligations of the EU Environment Acquis, as also transposed to the local legislation. In fact, most, not all, of such national and international legal instruments are also referred to in the document itself.

Furthermore, other strategies listed are just cosmetic and only show how far ERA is detached from the implementation of its obligations. To list such strategies for public consultation is just a poor effort by ERA.

The publication is either a smokescreen for ERA to hide its failures in implementing and enforcing such national and international obligations or it wants to borrow time by procrastinating implementation to 2050.

By that time, if lack of environmental professionalism shown by ERA prevails, what is left of the environment would have been completely destroyed.

This time-wasting exercise at the expense of the economic, social and ecological fabric of the Maltese islands is also confirmed by the views of the public who expressed their worries and the need for urgent implementation of these legal obligations.

The lowest percentage in favour of urgent action on the seven strategic goals, as shown in the document, is 61 per cent; the highest is 93 per cent. This is an average of 77 per cent. So the public has already spoken out about the urgent need of environmental action. (Source: ERA 2022).

A number of eNGOs too have already expressed their opinion that the strategy is a waste of time.

Some of the cosmetic strategies, for example, include the pruning of trees in a professional way. Isn’t this already an ERA policy found in the Guidelines on Works Involving Trees, which nobody pays any attention to, not even ERA?

Does the setting up of a nursery for the propagation of indigenous trees need any public consultation? If ERA is conscious enough of the benefits of such measures it would long have implemented them without the need of any public consultation.

Who would oppose such measures that make a social, economic and ecological contribution? It seems that ERA has doubts on these and wants to procrastinate sine die with the excuse of public consultation.

ERA’s statement that birds listed in the EU Bird Directive “have shown an increasing or stable population, both in the short and long term” torpedoes the scientific approach of the document. There is no scientific reference to back up this statement, as there are in other ERA statements. This is far from the truth and only confirms ERA’s failure in this field.

ERA states that there is collaboration to support “the rehabilitation of injured native wildlife, such as turtles, hedgehogs and bats”. There is also a rehabilitation centre for injured protected birds. It seems that ERA has a bird phobia or is this a force majeure insertion?

The publication is either a smokescreen for ERA to hide its failures or it wants to borrow time by procrastinating implementation to 2050- Alfred Baldacchino

Under every strategy there is a section on “What we’ve achieved”. Again, due to its bird phobia, ERA has ignored the fact that, because of its lack of implementation and enforcement of the Birds Directive, Malta has been taken to the European Court of Justice. Quite an achievement for the competent authority!

“Nature and biodiversity considerations are being integrated in the national sectorial policies and economic sectors,” the document says, such as land use and rural developments.

If there was any doubt that ERA has hit rock bottom in its lack of will to professionally protect the environment, this is clearly a self-confession. The permitting authority (officially known as the Planning Authority), ERA’s bed partner, dishes out permits without concern for the country’s characteristics, let alone for the protection of the economic, ecological and social fabrics of the islands. And there were and still are instances when ERA endorses these permits.

Such a statement shows that the scriptwriter has no conscience, no ethics, no professionalism and believes that the ERA document will only be read by village idiots. But the intelligent reader today is not surprised by such official antics from ERA. Official statements torpedo the whole ERA document and renders it a laughing stock to the intelligent community of the islands. The writer must have been influenced by the Topper and Beano comics.

The ERA document has close to 1,000 promises that “will” be achieved by 2050. When most of these strategies are legal obligations resulting from national and international obligations and ERA has almost completely distanced itself from them, how can one be convinced that ERA can implement these 1,000 promises, which do not have any legal standing? It is a document of 1,000 “wills”.

Key players that were involved in each strategic goal are included. Some important ones are left out of certain related strategies. One glaring omission is the Church Environment Commission. Was someone embarrassed to invite this entity?

ERA has published quite a number of guidelines, on trees, invasive species, landscaping and other matters. But these are ignored by almost everybody, including ERA itself. This also convinces many that the document is another futile exercise to divert attention from ERA’s failure to rise to its responsibilities to protect our environment.

In the National Strategy for the Environment 2050, ERA lists close to 1,000 promises to deliver by 2050.

ERA confirms that Malta has a number of ecological terrestrial and marine Natura 2000 sites approved by the EU. These had to have a management plan by six years after accession. The EU granted an extension and financed the drawing up of such management plans, which EU subsequently approved. Most of these management plans are still not implemented such as those for Buskett, Comino, Ta’ Ċenċ and others.

Now ERA states that it has initiated a “revision process for the conservation objectives and measures for these sites”. Naturally, these have to be approved by the EU, meaning that Malta has failed to implement the management plans financed and approved by the EU, especially if these are watered down.

ERA promises that the management of invasive species “will be implemented”. EU regulation No. 1143/20-14 on invasive species forms part of the local legislation in toto. ERA has also published guidelines on the control of invasive species. Nothing can be changed from the EU regulations. Unless, of course, ERA wants to make them much stronger, which is very, very much doubtful.

ERA also states that “other impacts on habitat loss, the disruption of water processes and pollution regulations, the loss of Malta’s rural character, need to be better understood”. Without doubt, ERA has to understand the implementation and enforcing such measures in the national interest. In the meantime, ERA has endorsed some of their negative impacts when in company with its bedfellow, the PA

The document also addresses pollinators, promising “a policy will be set up”. The problems facing pollinators, including bees, is the loss of natural habitat, such as garigue, and the uncontrolled spraying of herbicides and pesticides, some financed by the government and managed by local councils and official landscapers. So, ERA wants to “foster training and research to beekeepers”. Perhaps the first urgent action ERA should take is to stop the importation of exotic bees (invasive species) which are destroying local endemic bees.

Green spaces are also mentioned ad nauseam. What exactly does ERA mean by open spaces?- Alfred Baldacchino

Other promises regard “limitation of the maximum area of soil sealing” and “soil health assessments”. Another ERA failure when, with EU funds, most of the valley beds were all concreted over in Malta and in Gozo. Recently, photos on social media showed concrete mixers covering Wied ir-Ramla, in Gozo. ERA wants to wait till 2050 to take any action on this negative biodiversity impacts.

“The contribution of nature to our mental and physical well-being will also be studied, assessed and integrated into decision-making” and, then, “spending time and exercising in nature is known to benefit both

mental and physical well-being”. Mismanagement of biodiversity in a professional way by ERA.

Light, noise and air pollution are also included. If ERA were to visit the

Attard Central Link, close to San Anton Gardens, there is a long stretch of lighting from beneath the trees. This negative impact on biodiversity affects the micro habitat and nocturnal fauna and is also a nuisance to residents. What was the need for such expenses, except perhaps to lavishly spend EU funds while making some friends happy?

Studies on air pollution have been going on for a long time now, without any policies or legislation being implemented and enforced.

An achievement for ERA is that “Malta attends the Ministerial Conference on Environment and Health organised by the World Health Organisation”. It would have been an achievement if the knowledge gained would have been implemented an enforced.

Green spaces are also mentioned ad nauseam. What exactly does ERA mean by open spaces? Perhaps new playing fields? Or perhaps a monstrous concrete building with monstrous steps and lifts over a car park, which are adorned by a green leaf or two and no trees and surrounded by traffic exhaust, especially from heavy vehicles?

“Zero waste to landfill” by 2050 has also been promised. There is little reference to liquid waste. The permitting authority has just approved the Għallis dump to rise by 15m to avoid a waste crisis, despite the visual impact. Seems 2050 is a long, long way away.

It is a well-known fact that primary education and secondary education students are well aware of the importance of biodiversity. Surprisingly this all disappears at tertiary level, like the air in a burst inflated balloon. Why?

Other promises regard tourism, population density, green facades, green walls, green roofs, front gardens and, surprisingly enough, “crowdfunding”.

ERA itself confirms that “the transposition of the EU Environmental Community Acquis into Maltese legislation is the most important driving force for regulatory policy intervention”. We should have a public consultation before these are implemented.

What is urgently needed is a professional political will. Not only is there no political professional will but there is no will at all.

The involvement of qualified and experienced academics to give their input in the national interest is so lacking. But these do not say what ERA wants to hear because their involvement is professional.

The one good thing about this document is that today’s and future generations will have an official ERA- signed document showing why the environment is in such a pitiful state of destruction.

Alfred Baldacchino is a former MEPA assistant director.