This chapter will first check whether the methodology adopted has answered the question set in the introduction of this dissertation, that is, whether the scoping process in EIAs for the extractive industry is being carried out in an appropriate manner and the significant impacts are being identified. It will proceed to highlight the areas of concern which were identified and finally recommend solutions which would help to ameliorate the whole process.

The outcome of this dissertation has identified that scoping is not being carried out appropriately. The approach being adopted presently in the extractive industry was not recommended by the Wager report which was commissioned for the Planning Services Division. The study has shown that some issues which were considered important by the questionnaire respondents were not being considered. Again, one must stress the fact that some of the reports were the final result after an unknown number of draft reports being reviewed by the PA staff. This situation could be rectified, by adopting the following approach:

1. Site specific TOR should be issued. These should only study the significant impacts of the project.
2. Draft reports should only be reviewed once by the PA staff.
3. Comments on final report and recommendations made by the PA prior to decision should also include the possibility of refusal for lack of adherence to the stipulated TOR, previously issued. This should be clearly made to the developer and consultants at outset.
4. PA should adopt a professional approach to the whole EIA process and avoid entering into bargaining exercises with customers.

The study has also shown the lack of knowledge at all levels (decision making, advisory, consultancy, NGOs and Local Councils) regarding:

1. the importance of the EIA process;
2. knowledge of the whole process and the importance of its iterative mechanism;
3. perception of significant impacts;
4. management of the EIA process at the PA.

There is a need for the EIA process to be handled in a more professional manner. This was also reiterated in the questionnaire results. This could be done through short courses aimed at different levels of the public, but priority should be given to the PA staff, consultants, developers. This would show them the importance of all the stages in the whole process. The aim would also be to disseminate information and as a result change the attitude towards the EIA process. Local, as well as foreign consultants, could be engaged to coordinate such courses. Persons appointed on decision making boards of the Authority should also be briefed about important aspects of the planning process, such as EIAs. This would put them in a better position to understand recommendations for a decision made by the PA staff.

The study has also shown that there is lack of baseline information. This is very important to identify the significant impacts of a project. This is a role which should be shouldered by the Environment Protection Department, EPD, so that it could establish a database for the local natural environment. The University of Malta could also collaborate in such a project by utilizing science students through field work and dissertations.

The EIS and EPS reports have shown that there is lack of expertise in some areas, amongst which were the economic impacts and also noise. One must first know the exact reason why economic impacts were nearly always ignored. There is the possibility of lack of information forthcoming from the developer but there is also the second possibility which is that of lack of knowledge from experts in the economic field. Whereas in the former case, it is the developer who will have to face the consequences of his actions, in the second case, one might be able to offer short courses to those interested in the subject. A similar approach could be adopted for noise impacts. One could also study the feasibility of getting foreign consultants to do the job.

The initial part of the study showed that the questionnaire method presently adopted by the Central Office of Statistics to collect production and sales information from the quarry industry is not giving correct results. These results are of prime importance especially when one considers the information collected from the Mineral Resource Assessment. The PA is in a position to rectify the situation by routine monitoring of the quarry sizes. It could also collect information from all planning applications of the approximate quantities of different materials which will be used in the developments and thus, it would have a more accurate view of where the mineral resource balance stands. Thus, the PA could act accordingly, even in giving planning applications to large developments which consume large amounts of mineral resource. One could consider taxing such developments, thus safeguarding mineral overuse. It would be a system of planning gain, the benefits of which will be reaped in eighty to one hundred years’ time.

The study showed the need to address the alternative sites and technology issue. This should be viewed at different levels namely:

• legislative;
• quarry industry;
• Planning Authority.

The introduction of mining legislation in Malta will open up the possibility of changing extractive technologies. Secondly, it will clarify any doubt about land ownership within a mining area. Thirdly, mines could have a smaller visual impact and should produce less environmental damage. This would be possible because, with the exception of the opening and processing area, the surface of the land would remain intact. One could also consider digging up mines from existing quarries, thus avoiding new openings. Unused parts of the quarry could be restored and embellished accordingly, possibly reducing some of the visual impacts.

Aquilina (pers. comm., 1998) said that the quarry industry is not considered as an industry by the Malta Development Corporation (MDC) and so is not eligible to subsidy funds for restructuring. This has resulted in little modernization in the industry throughout the years. Apart from this, the prices of the product have not changed much and also owners tend to undermine each others efforts when anyone tries to increase the prices. This problem could be analysed through a Government commissioned study.

The aims of the study should be:

1. The restructuring of the industry to meet present standards using modern technology with special reference to care of the environment. This will probably lead to an increase in the price of the product provided it will be still be feasible to extract locally and not import foreign rock which is much stronger.
2. The possibility of pooling resources between quarry owners who are family concerns and so have limited financial resources.
3. The possibility of diversification of products by the same owners (e.g. recycling of old stone etc.).

The planning Authority should start working on the Minerals Subject Plan which should address the extractive industry holistically. This view was also stated by two questionnaire respondents. The TOR of the Plan have not been published and so it is as yet unknown whether the Plan will be considered within the present traditional working practices or whether it would be within the framework for the possible modernisation of the industry and introduction of new technologies.

The Planning Authority needs to restructure the Environment Management Unit, which is the team of people who are responsible for the EPS and EIS. The present system whereby there is the possibility of a Transport Impact Statement, TIS, done by a different section of the Authority has to be modified. A transport impact assessment is part of an EIA and should be treated likewise. Transport impacts cannot be limited to road design and flow rate of cars. Transport generates other impacts namely, noise, air quality and road impacts. Respondents from Local Councils stated that the construction vehicles were damaging local roads and are a cause of public nuisance in village centres. Such an impact was not appropriately addressed in the EIA reports studied.

The restructuring must be followed by a clear definition of roles in the EIA process whether those of the PA, the EPD, developers and consultants. This was also stated in the Wager report (1993).

The EPD should be given the role of:

• issuing TOR to study the significant impacts of the development. The PA should still have an input as regards to planning policies and consultation with EPD. Restoration schemes should also form part of the EIA report.
• Establishing a baseline Database for the local environment. This is important to identify the significant impacts.
• Keeping a register of qualified consultants and EIA coordinators in the respective fields.
• Reviewing the draft reports from a technical point of view.
• Monitoring environmental impacts on a regular basis. Monitoring should help in the introduction of Post Development audit and also as feedback for future EIAs.

The role of the PA should be limited to:

• Screening the development applications and deciding what type of reports should be prepared. Their decision should be clearly stated in writing and backed up by reasons.
• Reviewing the quality of the draft reports prepared using standard methods, such as the Lee and Colley method.
• PA should introduce the necessary regulations for Post Development Audits of projects which have been subject to an EIA report.

Developers should ensure that the coordinators they engage are duly qualified to do the job properly. The co-ordinators could then be responsible for engaging the right experts for the job. They should be responsible for the final coordinated report and its presentation.

The study has identified :

• the lack of knowledge and appreciation of the EIA process at all levels under investigation;
• the lack of baseline studies and information necessary to identify significant impacts;
• that the PA accepted EIA reports which had several items required in the TOR missing;
• that the quarry industry is reluctant to change under the present circumstances.

To overcome these problems, the study recommends:

• The restructuring of:

1. the quarry industry, after an appropriate study to identify bottleneck areas for its modernization and duly propose appropriate solutions;
2. the Environment Management Unit within the Planning Authority, to include all aspects of assessment, including that of transport, under its umbrella;
3. the Environment Protection Department, EPD, to act as a complementary part in the technical nature of the EIA process.

• Introduction of short courses on the EIA process, aimed at different levels. The aim would be to change the present attitude of the key participants in the process and make them aware of it importance.

One hopes that if these recommendations are accepted, the key players in the EIA process would be in a better position to understand its importance and implications. This could also lead to a better scoping process and the eventual production of reports of a better quality.