In response to the very thorough article written by Denis Zammit Cutajar, on 25th January entitled “A golden opportunity to rethink the waste-management strategy,” I would like to thank the author, and reiterate many of the same points. We should take this opportunity to reevaluate the need for a large incinerator on Malta.

The European Union has set a target of no further landfilling of waste (beyond 10%) by 2035. However, investment in incineration technology ultimately discourages waste reduction efforts as, in order to make the most economic benefit from installing an incineration facility, more waste would need to be burned rather than repurposed or recycled. And, despite regulations, there are cases around Europe where the surrounding community has been affected by dioxin and other toxic contamination from incinerator emissions. Incineration results in ash, which usually contains concentrated toxins, which must still be landfilled. This is not the right solution for a small, densely populated island like Malta. Incineration may have a limited place for hazardous waste, but for municipal waste, many other measures could be put in place to reduce waste in the first place. Malta has a Long Term Waste Management Plan 2021-2030 and as a member of the EU, is also subject to the EU’s Circular Economy Plan, which include numerous initiatives that could prevent waste. 

As mentioned Malta first needs “aggressive waste reduction, extended producer responsibility, improved separation at source, composting of organic waste and high-quality recycling.” As also mentioned, stricter enforcement, and more public education, including of children, among other measures are needed. I would add to this list, policies such as pay-as-you-throw, which is a system where residents pay for each bag they dispose of. Through this system, smart bins typically calculate by weight or number of bags thrown out per residence. This encourages better sorting out of recyclables and organics. A similar suggestion is “restricted residual”- a certain number of bags is given free per household (based on the number of people) and then the resident pays for more bags. Some other countries are using Material Recovery and Biological Treatment of waste (MRBT) to sort out plastics, metals and paper from municipal mixed waste. We also need right-to-repair policy implementation, and more effective textile waste reduction initiatives. 

Friends of the Earth Malta is a member of Zero Waste Europe, and through them we see examples of successful measures being put in place by leading countries such as Germany, Sweden, and the Netherlands that yield significant results. For example, Germany separates waste into six or more categories (paper, plastics, organics, residual, glass by color). This pre-sorting increases the rate of material recycling.  For example, our next door neighbor Italy, which recycles over 70% of its waste. There is also a Green Dot symbol found on packaging in Germany and other European countries, which indicates that the manufacturer or distributor has paid into a system that ensures the packaging will be collected, sorted, and recycled properly. Croatia has made Krk Europe’s first Zero Waste Island, which involves multiple measures such as a focus on recycling, compost, packaging reduction, materials reuse, and wide public education. This should be the goal for Comino, at the very least. One step to help address food waste is to create policy to ensure that hospitality and retail food providers are not allowed to dispose of leftover food which is in safe, edible condition. It should be required for grocery stores and restaurants over a certain size to donate to food banks or charities. This has already been the case in France since 2016. We also have a project called Food Connect through which food businesses can donate excess edible food via an app to those in need.

Beyond focusing on residential waste, mandatory measures for waste-reduction and recycling for commercial and industrial sectors are needed with strict enforcement. As construction waste accounts for 80% of Malta’s waste, moving this waste sector towards circularity/repurposing should be a priority. There should be measures such as mandating a minimum percentage of recycled material in building construction. Malta could also establish centralized reuse centers for construction materials. Municipal projects should be required to follow green purchasing policies.

These are just some of the measures that could help prevent the need for a large incinerator on Malta. If the relevant agencies such as ERA, Circular Economy Malta, and NGOs worked collaboratively, Malta could be a shining example of how to do things right rather than putting in place a costly strategy that we will regret later.