Friends of the Earth Malta would like to thank Project Green and the Ministry of the Environment for the opportunity to provide input on Malta’s newly planned parks.

General Feedback:

Design:

• Carry out extensive ecological surveys in both dry and wet season before starting any works with heavy machinery. FoEM is concerned that recent media reports show that heavy machinery has already entered one of the sites to commence cleanups. 
• Site evaluation: When carrying out cleanups it is of utmost importance to first study the area and be aware of any local wildlife nesting on site or rare species of flora. These should guide the cleanup actions. Avoid removing any trees during bird nesting season. Cleanups tackling any abandoned open structures or stone walls should pay close attention to avoid disturbing wildlife. Long years of abandonment usually means that hedgehogs, bats, birds, reptiles could be finding refuge in such areas. Have wildlife and botanic experts at hand to monitor any works and consider careful relocation of established animals in case their refuge is to be impacted.
• Incorporate Green Infrastructure which lasts and which is effective – for instance native species of climber plants could easily be grown to create green walls for biodiversity, or canopies for shade.
• Friends of the Earth Malta would like to encourage focusing on rewilding initiatives as much as possible to make up for all the natural habitats that have been lost. Rewilding aims to  support nature-driven processes – to encourage the return of wildlife with the aim of eventually allowing nature to take care of itself. Parks should encourage a rich biodiversity which should be a continuation of any nearby existing habitats or restoration of what was on site before development/disturbance. The aim should be to have spaces which are then left to nature with minimal human intervention needed in the long term. 
• The national parks should not be manicured spaces where spontaneous plants are ripped as soon as they sprout – these should not be standard formal garden areas with desert soil but should bring back nature and allow whatever healthy ecosystems are present already on site to continue flourishing  without being tarmacked over. 
• Due to lack of foraging areas for many pollinators these spaces should encourage and support pollinators by selecting appropriate plants, shrubs and trees which flower at different times of year to provide food even in the dry season. For reference we recommend using this manual, which although created for schools can be applied to larger areas and includes a whole annex of indigenous Pollinator plants: Lets Make a Wildlife Garden – Friends Of the Earth Malta
• Choose plants which are climate resilient and do not require much water – refer to above Wildlife Garden manual as well as ERA’s own guidelines: Guidelines on trees, shrubs and plants for planting and landscaping in the Maltese Islands – ERA 
• Select trees that create layers and shade – some can be faster growing than others. Avoid using extensive rows of pine trees – the greater the diversity the better and this should not be a regimented planting area.
• Although invasive alien species may need to be tackled, we strongly recommend that mature trees which have already established shade and are not invasive to be retained and supplemented with appropriate native species. 
• As foraging is becoming increasingly popular these parks could include local fruit trees which can be enjoyed by all visitors (fig trees, mulberry, hawthorn, almond, pomegranate, Jujube, Strawberry Tree, Myrtle as well as some cultivated varieties which fare well in our climate and do not require much care). 
• Natural Hedges can be created with a mix of bay laurel , myrtle, etc These provide vital shelter and shaded areas with microclimates which can support many organisms.
• These national parks should aim to propagate as many endemic and endangered species as possible and some seed collection should be allowed under guidance so as to encourage the public to grow more local flora. 
• Interactive signage to promote knowledge and awareness on the importance of biodiversity.

Community aspects

• Allow space for Community garden initiatives in degraded areas – can be based on permaculture principles (see https://www.socialpeas.eu/ on Social Permaculture). There has been an increasing demand by locals for such spaces, especially for all those who do not have the luxury of having a garden or outdoor space in their homes. 
• Shade – most gardens and open spaces have absolutely no shade and cannot be used for most of the long hot season during daytime. Use materials such as cane which can be incorporated as windbreakers but also to create shade. 

Activities

• No hunting or trapping should be allowed in any part of the national park.
• No fires should be allowed in the park
• Parks should have a ranger/educator who can also act on enforcement as necessary
• Encourage citizen science initiatives
• No cars or motorised vehicles should be allowed inside parks. 
• There should be limited economic activity within the parks. There is an appropriate level to be able to provide refreshments but not that this dominates the space.

Waste & Plastics Reduction: 

• We encourage installation of colorized and/or clearly labeled waste bins with lids, and signage in multiple languages that easily direct people to correctly separate their waste. Waste companies should add these parks to their pickup routes, and dispose of waste properly.
• We encourage the use of recycled materials for items such as benches and jungle gyms, and to avoid the use of virgin plastic in construction. If new materials are to be purchased, favor use of metals, wood, stone, or other non-plastic materials.
• If kiosks are permitted in parks, they should refrain from providing plastic utensils/paperware. Cutlery, plates, etc. should be made of biodegradable materials.
• Water refill stations should be made available for people to be able to refill reusable containers rather than purchasing beverages in plastic containers.
• Ashtrays for cigarette butts should be made available in easily accessible locations, and emptied on a regular basis.
• Upcycle used materials to create benches and outdoor spaces for relaxation. These could also be done on site with the community during purposely held workshops 
• Reuse stones to create dry stone walling features as refugia for wildlife and to reduce soil erosion. Avoid the use of concrete when creating dry stone walls!

Toxins:

• For all parks, Friends of the Earth Malta would like to encourage the government to avoid the use of synthetic turf, which is made from crumbled tyres. While we encourage the use of recycled materials, the crumbled rubber used in synthetic fields can be contaminated with toxins such as benzene (a carcinogen), phthalates, and heavy metals. These crumbles can migrate from the fields into local waterways when it rains.  
• FoEMalta recommends these parks to be 100% pesticide free. Several synthetic pesticides, depending on the chemical, may sometimes be linked to diseases such as cancer, endocrine disruption, or nerve damage. There are often natural alternatives to address pests, including physical measures such as mulching and planting native species to prevent the appearance of invasive weeds.

Noise and Light Pollution:

• Lighting should favor use of soft-light that is efficient in terms of energy usage, or no light at all where not necessary.
• All parks should consider downward facing lighting so as not to create night time light pollution, or to leave some areas without light.
• Strict measures should be taken to minimise any light pollution on site. Lighting should be minimal. For guidelines please follow the Light Pollution Awareness Group’s recommendations L.P.A.G. – Guidelines for the reduction of light pollution – L-Għaqda Maltija tal-Astronomija as well as ERA’s own draft Guidelines . Light pollution indexes in Malta are extremely high and it is now well documented that it has a negative effect on human physical and mental health and disrupts wildlife and ecosystems. Furthermore, dark sky heritage should be a right for all to access – we have already lost a big part of our night sky. 
• Lighting fixtures should be minimal but where necessary they could be solar powered.  
• Noise Pollution and the Preservation of Quietness:- Peaceful Soundscapes should be taken into consideration with no loud artificial noise being allowed on site =  people in Malta require quiet spaces to rest in and these are increasingly becoming a luxury to find. Noise pollution is well known to have negative health repercussions: “A special report by the Citizens Policy Department of the European Parliament has placed Malta’s noise pollution under detailed EU scrutiny, highlighting significant health impacts and calling for stronger action to address sources not covered by the EU Noise Directive…. Noise is recognised across Europe as the second most significant environmental health risk after air pollution, and Malta’s high population density and limited mitigation options exacerbate the problem.” (Source: EU report flags Malta’s noise as major health threat ). The recent Citizens Policy Department of the European Parliament recommendations should be taken into account in addition to the ERA Noise Action Plan (NAP). National parks should be peaceful areas where one can relax. FoEM strongly encourages the delineation of QA’s: Quiet Areas. 

Water:

• Ensure that rainwater runoff from buildings on site is collected in reservoirs and used for irrigation on site. 
• Use minimal concrete or other impermeable surfaces for paving. Rain Water and runoff  needs to be allowed to replenish the aquifer and reservoirs or reach any localised rockpools if present. 
• If toilet facilities are to be installed on site they should be designed sustainably with great emphasis on water conservation and reuse