This document is set out as a summary viewpoint to ensure that a concise and clear viewpoint is provided by the Malta Water Association (MWA). This document looks at both the Water Policy (WP), as well as its interpretation through the SEA reports (i.e. Environmental Report, Scoping Report)

The SEA Environmental Report (page 91) outlines three alternatives with regard to the Water Policy: 1) do not implement; 2) implement within the limits of legal compliance; 3) implement in totality and beyond legal remits. The SEA report concludes that, due to resource limitations on part of key policy implementers, “option 2 is considered to be the most practical option at this stage. It is recommended, however, that implementation of the WP be closely monitored and opportunities to include additional measures during implementation of the WP should be pursued to ensure maximum benefits are accrued” (page 92). The MWA disagrees outright with this compromise, as shall be outlined below:

 

Option 2 – Implementation within the limits of legal compliance:

This essentially means implementation of the transposed water framework directive through individualized efforts, and within the official and legal obligations of the various entities concerned.  Whilst the WP effectively covers the main areas of water management within its 12 policy areas, it in intrinsically weak in establishing clear responsibilities, targets and timeframes for the key implementers concerned (such as MRA, WSC, MRRA, MEPA, PHRD…).  Taking one from a plethora of examples, measure 2.3 (and subsets) does clearly place the responsibility on the MRA to manage groundwater extraction, but fails entirely to mention extraction targets, apportionment figures, monitoring regimes, realistic implementation timeframes, and such.

Compounding this issue is that of the fact that very little use has been made of: a) vital knowledge on past water management successes/failures on the Island, b) international best practice techniques within the water sector, c) international performance indicators used within the water industry, d) international benchmarks. For example, in Policy Area 4, measure 4.1 (also measure 11.1) states the ‘optimization of operation of desalination plants’ with an ongoing timeframe and under the responsibility of the WSC.  So… is the present production of RO water by the WSC at some 3.6KWh per cubic metre comparable to best practice? If not, what are the short and possibly long range efficiency targets? What level of investment or effort will be used to achieve these target/s? All these questions remain unanswered. The WP is inundated with similar situations where generic statements are made, with little or no tangibility as to the implementation.

 

Option 3 – Implementation of an integrated water policy:

The SEA Environmental Report correctly observes that the WP fails to achieve an integrated water resources management (IWRM) approach.  To compensate for this, the SEA report places an emphasis on a) the implementation of effective governance mechanisms, complemented by b) adequate monitoring programmes.  This does not resolve the fragmented approach adopted within the WP, as the proposed solution of setting up of ‘inter-ministerial committees’ (SEA Report page 138) is simply the same fragmentation but at a higher level.  IWRM consists of the integration of water management initiatives for multiple purposes (domestic supply, irrigation, industry use, aquifer recharge…), for multiple objectives (human health, economic productivity, environmental quality, social equity…), and through multiple means (physical infrastructures, regulations, economic initiatives…).

This IWRM philosophy can only be achieved by having one entity or institution that is fully responsible for all of the socio-economic-environmental issues relating to water. It means promoting a chain of integrated measures that collectively lead towards water sustainability. It means devising a national agricultural policy with sustainable water use requirements. It means efficiently treating wastewater to provide an alternative to groundwater for irrigation and possibly other usages.  It means fair and reasonable tariffs for water, treated wastewater, and groundwater, incorporating the ‘polluter pays’ principle.  It means education as well as adequate regulation and control. It means constant technological innovation, with a respect for what has worked for us in the past.  It means looking at international best practice, and learning/trialing and then implementing where appropriate. It is our opinion that the WP should encompass all of these themes and measures, for it to be complete.