Further to the letter ‘Packaging waste collection system’ by Chris Ciantar and published on The Sunday Times (April 27th), Friends of the Earth (Malta) would like to point out the following issues.

In his letter, the newly appointed Permanent Secretary, clearly exhibits his annoyance at the public statement issued by the NGO. However, unless he has somehow forgotten, Malta is a democratic society and open criticism for this type of scheme is legitimate from all sectors of civil society.  As an environmental NGO, Friends of the Earth (Malta) feel that, for the benefit of the Maltese public as a whole, they have the duty to pose questions when things are unclear, or when ,in someway or other, they are not being managed according to the best possible solution Despite its lack of financial and human resources, should FoE have been asked to serve on a consultation board with adequately scheduled meetings regarding packing waste collection schemes, it would have been more than willing to participate and contribute constructively in the process.

Rather than allowing what started as constructive criticism degenerate into a public argument, we would like to pose, once again, the questions which so far have remained unanswered. The first questions focus on the Sant’Antnin plant. The website of the now obsolete Ministry for the Environment and Rural Affairs, states that the Sant’Antnin Plant  “ is expected to lead to an improvement of the environmental, social and economic impacts experienced from the operations of the current plant. …….It will also help in achieving this through improved work conditions for the work force……..”

However, Dr Ciantar in his letter, clearly states that the material will be hand-sorted. Maybe the ‘work conditions for the work force’ were momentarily sidelined when the door-to-door collection scheme was designed. FoE recalls that the EIA for the Upgrade of the Sant Antnin Plant states that the plant is designed to accept separate waste material. Probably this is the reason why the Ministry has now resorted to hand sorting once again! Additionally, Dr. Ciantar argues that the system will ensure ‘that the quality of the scrap material is optimal for recycling’. It is common knowledge within the waste management sector that the cleanest and optimal material for recycling is that which is disposed of and collected in separate containers. It is rather presumptuous of the Ministry to assume that the mixed paper, plastic and metal (and God knows what else might end up in these bags!) will constitute optimal material for recycling.
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The ministry has finally made it clear that the public will have to purchase the grey bags in order to participate in this scheme.  This discourages households from separating waste since it is easier for them to just dump all their mixed waste into a ‘free’ plastic carrier bag and leave it on their door step. The public is being taxed for separating its waste – instead of the other way round. Contrary to Dr. Ciantar’s claim, this goes directly against the Polluter Pays Principle! On the other hand a good number of civic minded households are already separating their waste and making effective use of the BI sites – a fact that WasteServ has made publicly known. In other words this system will only be reinforcing bad practices or work in direct competition to the BI sites.

Dr. Ciantar makes several assumptions and claims without explaining how he has come to these conclusions. He states that “such a scheme will also help to recover more packaging waste which would otherwise end up in the waste stream”. He elaborates on this by saying that “for families that have difficulties using bring-in sites…an alternative set-up is being launched”.  How can we be sure that the tonnes of waste collected via the door-to-door scheme are additional to that being collected from BI sites?  An interesting study will be to research the potential decline in waste disposed of in BI sites. The scheme together with the media campaign is targeting society at large when in his own admission, Dr. Ciantar is aiming to attract those families that do not use the BI sites. With the cooperation of local parishes and other organisations, the Ministry could have obtained sufficient data that would have given a true picture of which families need the door-to-door scheme.  With this valuable data in hand, the ministry could have then embarked upon designing and promoting a scheme with this specific category of households in mind thus saving on  financial and human resources.

FoE fails to understand why the Ministry chose to create a new nation-wide system for household packaging waste collection rather than invest in the better use of bring-in sites which could serve our county well enough.  If the ministry desperately needs to meet the recycling targets, then it should focus on the large waste producers as these will boost the figures.  Other EU countries were only able to reach the recovery and recycling targets when they included the secondary and tertiary packaging material into their waste collection schemes. Â

Finally, in the true interest of Maltese tax payers, FoE would like an explanation regarding the funding of the marketing and operations of this door-to-door scheme.  Dr. Ciantar refers to the scheme as “fully privatised initiatives” and gives the impression that this is part of the Polluter Pays Principle whereby the packaging waste producers take responsibility of the waste they put on the market.  In view of this FoE would like the Ministry to inform the general public whether this scheme is being funded from the country’s coffers or via the packaging producers.  Who has paid for the media campaign? Who has paid for the civil servants’ involvement? Who has paid for the mailshot and the delivery of bags to Local Councils? Who is paying for the collection and transportation of the waste? The taxpaying public is eagerly awaiting answers. FoE has no objection to the Producer Pays Principle as long as it is implemented the way it was intended to be….surely the complying households separating their waste are not the polluters – can Dr. Ciantar explain why these will be punished and made to purchase the grey bags? He claims that the scheme is for those families who are unable to use the BI sites, so in other words, he intends to punish the elderly, disabled, the sick, and other specific sectors within our society by making them pay for the grey bags as these have no other real option available to them.  Social environmental justice indeed!!!