ERA asked to be more courageous
Nine eNGOs have joined forces to submit their responses to the draft National Strategy for the Environment. The eNGOs are Din l-Art Ħelwa, The Archaeological Society Malta, BirdLife Malta, Flimkien għal Ambjent Aħjar, Friends of the Earth Malta, Għawdix, Moviment Graffitti, Nature Trust-FEE Malta, and the Ramblers’ Association of Malta. Whilst acknowledging the work that was done to prepare this draft, the eNGOs are calling on ERA to be bolder and more ambitious in their vision for the environment, to 2050. The eNGOs called for greater courage to address the difficult controversial issues that are currently hovering around the national agendas, such as land reclamation, over-abstraction of ground water, demography and carrying capacity of the islands; and to avoid terminology which gives the impression of progressive environmental action but which does not properly commit fully to it.
It was felt that the document almost completely omits reference to Climate Change, which surely is the most important environmental issue to affect our islands over the coming years. Mitigating and especially adapting to Climate Change should really have been the guiding principles for such a document, given the context of urgency and emergency which faces us. It was felt that there should have been a specific reference to different environmental strategies for different regions, such as Gozo, Comino, or specific areas in Malta, such as Marsa.
The eNGOs praised the fact that the document called for changes in consumer patterns, and raised the question of how sustainable economic growth ought to be measured, beyond GDP, even if it fell short of proposing any of the methods that are being adopted around the world. The document also fell short of proposing tangible metrics, by which progress on the achievement of the strategic objectives could be monitored.
The eNGOs criticised the fact that over a third of the proposed “strategic objectives” were not really specific targets to be reached, but ancillary activities, which are relevant and important, but which cannot be called “strategic objectives”. The document contains 64 strategic objectives, but of these eight were related to research and study, four were related to ongoing monitoring, four were related to ongoing future scanning, four related to a greater commitment to enforcement of legislation and compliance, and cleansing and maintenance, and another three related to continuing maintenance (of the marine environment and of water resources) or international cooperation. There are also a couple of fiscal proposals, which could better be placed within the Action Plans, since they are about how to achieve specific targets, rather than targets in themselves.
At the same time, the eNGOs criticised that fact that the document did not give any indication of how the proposed strategic objectives were going to be achieved. Although the document promises that the publication of the Strategy would be followed by 10-year Action Plans, it was felt that given the urgency of the situation, the first Action Plan for at least the coming five to 10 years would be published as an Annex to the Strategy document.
The eNGOs called on the Government ensure that when the National Strategy was finalised, the document would be given a legal status which guaranteed enforceability, to avoid another strategy document picking dust on a shelf. It also called on Government to give ERA a stronger voice on all issues that impacted the environment, and, in particular, building development.
The eNGOs called on the authorities to engage in a real process of consultation with eNGOs and civil society, in the formulation of such important national strategies – eNGOs were willing to give their full contribution, even if their resources were limited. The eNGOS looked forward to a serious discussion on the detailed issues that they have raised in their submissions.