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STRATEGIC ENVIRONMENTAL ASSESSMENT ON MALTA’S AQUACULTURE

STRATEGY

ENVIRONMENTAL REPORT

Version 1: November 2012

i

Report Reference:

Adi Associates Environmental Consultants Ltd, 2012. Strategic

Environmental Assessment on Malta’s Aquaculture Strategy. Environmental

Report. San Gwann, November 2012; viii + 112pp + 1 Appendix.

THIS IS A DIGITAL COPY OF THE REPORT.

RESPECT THE ENVIRONMENT – KEEP IT DIGITAL


iii

This document has been prepared in accordance with the scope of Adi Associates’ appointment with its client and is subject to the terms of that appointment. It is addressed to and for the sole and

confidential use and reliance of Adi Associates’ client. Adi Associates accepts no liability for any use of this document other than by its client and only for the purposes for which it was

prepared and provided. Except as provided for by legislation, no person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior written

permission of Adi Associates. Any advice, opinions, or recommendations within this document should be read and relied

upon only in the context of the document as a whole. The

contents of this document do not provide legal or tax advice or opinion.

© Adi Associates Environmental Consultants Ltd 2011

Kappara Business Centre 113 Triq Birkirkara

San Gwann SGN 4197

MALTA

Tel. / Fax: 21378172 - 77

Email: [email protected]

Web: www.adi-associates.com

Quality Assurance

Strategic Environmental Assessment on Malta’s Aquaculture Strategy

Environmental Report November 2012

Report for: Ministry for Resources and Rural Affairs

Revision Schedule

Rev Date Details Written by: Checked by: Approved by:

00 Nov 2012 Submission to Client Krista Farrugia

Environmental Consultant

Rachel Xuereb Director

Adrian Mallia Director

File ref: G:\ADI\SEA\Aquaculture Strategy\Environmental report\Environmental report - Aquaculture Strategy

Nov 2012 for public consultation.docx


v

CONTENTS

GLOSSARY .............................................................................................. 1

CHAPTER 1: INTRODUCTION ............................................................ 3

STRATEGIC ENVIRONMENTAL ASSESSMENT PROCESS ............................................................ 3

Guidance ....................................................................................................................................................... 4

STRUCTURE OF ENVIRONMENTAL REPORT ................................................................................ 4

CHAPTER 2: An Aquaculture Strategy for Malta ................................ 6

INTRODUCTION ...................................................................................................................................... 6

Production capacities and areas for aquaculture production............................................................ 7

Production capacity scenarios presented in the Strategy .................................................................. 8

THE SEA PROCESS .................................................................................................................................. 15

RELATION OF THE AQUACULTURE STRATEGY TO OTHER NATIONAL

DOCUMENTS & LEGISLATION .......................................................................................................... 15

CHAPTER 3: SEA METHODOLOGY .................................................. 18

INTRODUCTION .................................................................................................................................... 18

DETERMINING THE SCOPE OF THE SEA ....................................................................................... 18

CONSULTATION .................................................................................................................................... 18

ASSESSMENT PROCESS ......................................................................................................................... 19

Link to Other Assessments .................................................................................................................... 19

ALTERNATIVES ........................................................................................................................................ 19

CHAPTER 4: ENVIRONMENTAL BASELINE ................................... 20

INTRODUCTION .................................................................................................................................... 20

LIMITATIONS OF DATA ....................................................................................................................... 22

Emissions to Air and Climate Change .................................................................................................. 22

Emissions to air .......................................................................................................................................... 22

Climatic Factors ......................................................................................................................................... 23

BIODIVERSITY .......................................................................................................................................... 24

Protected areas and species ................................................................................................................... 25

Marine biodiversity ................................................................................................................................... 30

WATER & Marine Sedimemts ................................................................................................................ 47

Effect of Aquaculture Activities ............................................................................................................. 49

LANDSCAPE.............................................................................................................................................. 53

CULTURAL HERITAGE .......................................................................................................................... 54

HUMAN HEALTH .................................................................................................................................... 54

MATERIAL ASSETS AND POPULATION .......................................................................................... 55

Evolution of the Baseline without the Strategy .................................................................................. 60

Emissions to air and Climate Change ................................................................................................... 60

Biodiversity ................................................................................................................................................. 60

vi

Water quality & marine sediments ....................................................................................................... 61

Landscape .................................................................................................................................................... 62

Cultural Heritage....................................................................................................................................... 62

Human Health ............................................................................................................................................ 62

Material Assets and Population .............................................................................................................. 62

CHAPTER 5: SEA FRAMEWORK ........................................................ 64

INTRODUCTION .................................................................................................................................... 64

SEA OBJECTIVES & INDICATORS ...................................................................................................... 64

CHAPTER 6: ASSESSMENT OF ALTERNATIVES ........................... 69

Alternatives assessment ........................................................................................................................... 71

Assessing significance................................................................................................................................ 71

Do-Nothing option ................................................................................................................................... 73

Production Capacity Scenario 1 ............................................................................................................ 73



Conclusions ................................................................................................................................................ 75

CHAPTER 7: ASSESSMENT OF ENVIRONMENTAL EFFECTS AND

PROPOSED MITIGATION ............................................................. 86

Introduction ................................................................................................................................................ 86

Assessing significance................................................................................................................................ 86

Impact assessment .................................................................................................................................... 86

Summary of the assessment ................................................................................................................. 103

Cumulative & Synergistic Impacts....................................................................................................... 104

CHAPTER 8: RECOMMENDATIONS ............................................... 107

Preferred alternative ............................................................................................................................. 107

Improve sustainability of the sector ................................................................................................... 108

Improve site specific management ..................................................................................................... 108

CHAPTER 9: MONITORING REQUIREMENTS .............................. 109

Introduction ............................................................................................................................................. 109

Monitoring plan ....................................................................................................................................... 109

Other data sources ................................................................................................................................ 112

Conclusions & next steps ..................................................................................................................... 112

FIGURES

Figure 2.1: Existing and proposed aquaculture production sites ................................................... 17

Figure 4.1: Greenhouse gas emissions by sector: 1990 – 2010 ..................................................... 24

Figure 4.2: Designated areas .................................................................................................................. 26

Figure 4.3: Natura 2000 sites ................................................................................................................ 27

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Figure 4.4: Marine SACs of International Importance ..................................................................... 28

Figure 4.5: Percentage protection of local species of international importance: 2002-2005 .. 29

Figure 4.6: Distribution of Posidonia meadows ................................................................................ 34

Figure 4.7: Extent of the maerl bed ..................................................................................................... 35

Figure 4.8: State of commercial fish stocks in Mediterranean Sea up to 2005 .......................... 37

Figure 4.9: State of commercial fish stocks in Mediterranean Sea up from 2001 to 2009 ...... 38

Figure 4.10: Reported catch for the East Atlantic and Mediterranean from Task I data from

1950 to 2010 split by main geographic areas (top panel) and by gears (bottom panel)

together with unreported catch estimated by the Committee (using fishing capacity and

mean catch rates over the last decade) and TAC levels since 1999. .................................. 42

Figure 4.11: Aquaculture production in Malta, 2001-2009. Figures in thousands per tonnes 44

Figure 4.12: Annual production of Sea Bream and Sea Bass from Maltese farms, in thousands

of tonnes ............................................................................................................................................ 45

Figure 4.13: Classification of bathing water sites according to EU Bathing Water Quality

Directive ............................................................................................................................................ 48

Figure 4.14: Bathing water quality from 2005 to 2009 .................................................................... 49

Figure 4.15: Sources and fate of nutrients released from tuna penning ...................................... 53

Figure 4.16: Reported aquaculture production in Malta (from 1950) (Source: FAO Fishery

Statistic) ............................................................................................................................................. 57

Figure 6.1: Existing and proposed aquaculture production sites ................................................... 78

Figure 6.2: Marine uses around the Maltese Islands ......................................................................... 79

Figure 6.3: Proposed aquaculture production sites and marine uses ........................................... 80

Figure 6.4: Preferred location of the North Aquaculture Zone .................................................... 81

Figure 6.5: Production capacity scenario 1 ......................................................................................... 82



TABLES

Table 1.1: Key stages in the SEA process .............................................................................................. 4

Table 2.1: Potential production capacity under different site availability scenarios .................. 10

Table 4.1: Environmental baseline ........................................................................................................ 21

Table 4.2: Current status of marine species ...................................................................................... 25

Table 4.3: Key for column numbers listed in Figure 4.9.................................................................. 36

Table 4.4: Production (volume and value) of main cultured species (Source: MRAE, 2011) .. 56

Table 4.5 Fish Farming operations in Malta ........................................................................................ 58

Table 4.5: Production of sea bass, sea bream and tuna by aquaculture units (2006) ............... 59

Table 5.1: SEA Environmental Objectives & Criteria for Assessing Impacts .............................. 66

Table 6.1: Proposed areas for aquaculture and other known uses within these areas ............ 69

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APPENDIX

Appendix I: Scoping Report

1

GLOSSARY

AMAs Area Management Agreements

AZ Aquaculture Zone

AZE Allowable Zone of Effect

BOD Biological Oxygen Demand

CCS Closed Cycle Species

CDDA Common Database of Designated Areas

CITES Convention of Endangered Species

CO2 Carbon dioxide

COGP Code of Good Practice

COP-15 15th Conference of the Parties to the UNFCCC

EC European Commission

EIA Environmental Impact Assessment

EIONET European Environment Information and Observation

Network

EQS Environmental Quality Standard

EU European Union

FAB Fisheries and Aquaculture Branch

FAO Food and Agriculture Organization

FFRC Fish & Farming Regulation and Control division

FOP Fisheries Operational Programme

FTE Full-time equivalent jobs

GFCM General Fisheries Council for the Mediterranean / General

Fishery Commission for the Mediterranean

GHG Greenhouse gas

GMO Genetically Modified Organism

GRDP Greening Regional Development Programme

GVA Gross Value Added

ICCAT International Commission for the Conservation of Atlantic Tunas

InDAM Indicators for Sustainable Development of Aquaculture and

Guidelines for their use in the Mediterranean

IPCC Intergovernmental Panel for Climate Change

LULUCF Land Use, Land-Use Change and Forestry

MARC Malta Aquaculture Research Centre

MCAST Malta College for Arts, Science and Technology

MDGs Millennium Development Goals

MEPA Malta Environment and Planning Authority

MOP-5 5th Meeting of the Parties to the Kyoto Protocol

MRAE Ministry for Rural Affairs and the Environment

MRRA Ministry for Resources and Rural Affairs

NAC National Aquaculture Centre

NOx Nitrogen oxides

NSO National Statistics Office

2

O3 Ozone

P2M P2M Company Limited

PCBs Polychlorinated biphenyls

PDG Policy & Design Guidelines – Fish Farming

PPP Public Private Partnership

R&D Research and Development

RO Reverse Osmosis

SAC Special Area of Conservation

SEA Strategic Environmental Assessment

SHoCMed Project in support to the GFCM CAQ Working Group on

Site Selection and Carrying Capacity (WGSC)

SPA Special Protected Area

SO2 Sulphur dioxide

SSE Site Selection Exercise

UN United Nations

UNESCO United Nations Educational, Scientific and Cultural

Organization

UNFCCC UN Framework Convention on Climate Change

VNN Viral Nervous Necrosis

WSC Water Services Corporation

3

CHAPTER 1: INTRODUCTION

1. This Environmental Report describes the Strategic Environmental Assessment (SEA)

in relation to an Aquaculture Strategy for Malta. The Strategy Report titled ‘An

Aquaculture Strategy for Malta: Preparatory study and recommendations prepared for the

Ministry for Resources and Rural Affairs (March 2012)’ was prepared by the University

of Stirling (acting through its consultancy arm, Stirling Aquaculture) for the Malta

Aquaculture Research Centre (MARC) within the Ministry for Resources and Rural

Affairs (MRRA). This document will hereafter be referred to as “the Strategy”.

2. The Strategic Environmental Assessment Regulations 2010, which implement

European Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment, require that a SEA of a wide range of plans and

programmes is carried out prior to the implementation of the plan or programme.

The Strategy falls within the scope of the Regulations.

3. Adi Associates Environmental Consultants Ltd (hereafter referred to as “the

Consultants”) was awarded the contract to undertake the SEA of the Strategy.

STRATEGIC ENVIRONMENTAL ASSESSMENT PROCESS

4. The objective of the SEA Directive is to provide a high level of protection of the

environment and to contribute to the integration of environmental considerations

into the preparation and adoption of plans with a view to promoting sustainable

development. It is the process of evaluating the environmental impacts of any

proposed plan/programme likely to have significant effects on the environment. The

SEA process helps to inform the decision making process and the final

plan/programme with the aim of improving it and promoting sustainable

development. In addition, the SEA process aims to increase public involvement in

decision making at a strategic level.

5. A Scoping Report was prepared and issued for public consultation in July 2012.

Appendix 1 contains the Scoping Report.

6. This Environmental Report is based on the Scoping Report. Consultation meetings

during the formulation of the Scoping Report were undertaken with the Malta

Environment & Planning Authority (MEPA), the Environmental Health Directorate, and the Malta Resources Authority. A meeting with the Fisheries Department will

also be carried out.

7. Public consultation on the Strategy and the Environmental Report will be undertaken

by MRRA.

8. The five main steps required as part of the SEA process are summarised in Table

1.1 below.

4

Table 1.1: Key stages in the SEA process

Stage in SEA

Process

Details of Process Required

Screening Screening is required to determine whether the proposed plan/programme

is likely to have significant environmental effects and whether an SEA is

required.

Scoping Scoping enables the coverage and level of detail of the Environmental

Report to be determined in conjunction with the statutory consultee/s; in

this case MEPA (Malta Environment and Planning Authority).

Environmental Report The Environmental Report details the anticipated environmental impacts of

the programme and any proposed amendments to the plan to mitigate its

effects. It must be consulted upon.

Adoption The Adoption Report details the results of consultation; how comments

have been incorporated into the programme; the final programme; and the

proposals for monitoring the environmental impacts of the programme.

Monitoring The Monitoring stage is undertaken during implementation of the

programme and serves to identify the level of monitoring required and,

should adverse impacts be identified, any remediation proposals.

Guidance

9. Draft guidance on SEA for Malta has not yet been published. The Environmental

Report therefore draws on other European Guidance, namely, the Greening Regional

Development Programme (GRDP) (2006) “Handbook on SEA for Cohesion Policy 2007-

2013”, the Commission’s “Implementation of Directive 2001/42 on the Assessment of the

Effects of Certain Plans and Programmes on the Environment” and the UK’s (2005) “A

Practical Guide to the Implementation of the SEA Directive”.

STRUCTURE OF ENVIRONMENTAL REPORT

10. The structure of the Environmental Report has been developed following

consideration of European Guidance and as described in the Scoping Report. The

Environmental Report structure is detailed below:

Non-technical summary;

Glossary of abbreviations;

Chapter 1 – Introduction (overview of the Strategy and its purpose; layout of

report);

Chapter 2 – Summary of the Strategy and its context (brief description of the

Strategy and related documents; links to other plans / programmes);

Chapter 3 – Methodology (identification of main options: approach taken, who

has been consulted, and when);

Chapter 4 – Baseline environmental information and trends (and limitations of

data) including evolution of baseline without the implementation of the Strategy;

5

Chapter 5 – SEA objectives and context (key environmental aspects, relevant

environmental objectives and criteria, and likely environmental implications

without the SEA);

Chapter 6 – Assessment of Alternatives including reasons for selecting

alternatives dealt with;

Chapter 7 – Assessment of environmental effects and proposed mitigation;

Chapter 8 – Recommendations; and

Chapter 9 – Monitoring requirements.

6

CHAPTER 2: AN AQUACULTURE STRATEGY FOR

MALTA

INTRODUCTION

11. This chapter describes Malta’s Aquaculture Strategy and the framework within which

it was prepared. It also includes a summary of the contents of the Strategy and its

main components. The links of the Strategy to other plans, programmes, and

legislation are also provided.

12. The Strategy presents four strategic objectives and associated desired outcomes.

These are:

Improved regulation: Streamlined regulatory environment under one MRRA Directorate, with a clear policy on site locations, minimal conflict with other

users, and standard conditions for all operators.

Improved operation: Efficient, profitable farms operating according to the

principles of best management practice, complying with their operating consents,

causing no nuisance to other coastal users and with a positive public image.

Improved environmental monitoring: A system that recognises the link

between biomass and impacts, specifies limits to what constitutes adverse impact

(Environmental Quality Standard - EQS), over what area such impacts are

acceptable i.e., the Allowable Zone of Effect (AZE), and is proportionate, practical

and cost effective.

Better innovation: Facilities, funding and human resources to allow high quality

applied research for the benefit of all industry operators.

13. The Strategy includes:

An introduction identifying the objectives, scope and approach of the study;

The methodology applied;

The international context;

A description of baseline information on aquaculture in Malta;

A description of existing policies and regulations;

A summary and assessment of the issues that were raised during consultation

meetings; and

Conclusions and recommendations.

7

PRODUCTION CAPACITIES AND AREAS FOR

AQUACULTURE PRODUCTION

14. The Strategy identifies a number of production capacity scenarios and different sites

for aquaculture production. The sites and areas that are considered in the Strategy

are shown in Figure 2.1. It should be noted that during the SEA process, it was

noted that search area 1, representing the proposed site for the north Aquaculture

Zone has, since the development of the Strategy, been changed. Figure 2.1 purposely

reproduces search areas as presented in the Strategy for the scope of this chapter

(wherein the Strategy proposals are summarised). However, the new proposed area

is depicted in subsequent maps of this Environmental Report. The production

capacity scenarios that are described below make reference to the use of the

different sites.

15. The characteristics of each area are described briefly hereunder.

Area 1: This area is made of sites K, J, L, M and N1. Sites J and K are found in a

sheltered area and have sufficient depth for CCS. Site K overlaps with an area

harbouring Posidonia oceanica meadows, a bird rafting zone, a trawling zone and

part of the proposed wind farm. Site L is found in deeper water yet can still be

adequate for CCS. Site L overlaps a bunkering area and trawl zone. Sites M and

N are adequate for tuna penning due to the depths present; however, these two

sites overlap an area of maerl. This area is also located within a marine protected

area.

Area 2: This area already supports aquaculture units but the Strategy proposes

its extension. This area is located within a marine protected area.

Area 3: This area is located between the bunkering area to the north and the Armed Forces of Malta firing ranges to the south. Sites R and S are closer to the

shore and are found in an area with approximately 30-50m depth of water whilst

the outer sites (O-Q) are within the 50-80m depth range. The former are

suitable for CCS whilst the latter are suitable for tuna penning operations. This

area is located within a marine protected area. The area also overlaps an area of

maerl.

Area 4: This area is located north of St George’s Point outside the Armed Forces of Malta firing ranges in waters having depths ranging between 20 and

50m. The site is suitable for a CCS site. The site is in the vicinity of the

Madalena shoals. It too is located within a marine protected area.

1 Following a Site Selection Exercise carried out in 2011 for the location of a suitable aquaculture zone off the

north-east of Malta, a more suitable location was selected, and the preferred area currently under

consideration is different to the one illustrated in the Strategy (see Figure 6.4).

8

Area 5: Sites U and V are located in the area of the former sewage outfall off

Wied Ghammieq, Xghajra. The area has been subjected to heavy impact by the

discharge of raw sewage over several decades. It is also one of the few areas

with no Posidonia oceanica meadows or other sensitive habitats. The water depth

in this area ranges from 10m to 50m and was suggested for a CCS nursery.

Area 6: Site W is found off St Thomas Point and meets the CCS requirement

since it is found between 30 and 50m depth and is not overlapped by any

environmental designation. The site is located 1.1 km away from the residential

area of Marsaskala.

Area 7: This area is situated between Area 8 and the existing south east

aquaculture zone. Sites X and Z are found in waters having a depth of around 50 to 60m and are suitable for the CCS whilst sites Y and ZI are more suitable for

tuna penning. The site overlaps maerl beds at its southern end.

Area 8: This area already supports aquaculture units but the strategy proposes its extension. The inner sites that fall in the 50m depth and 1nm from coast would

be used for CCS whilst the outer G and H would be used for tuna penning. A

bunkering area overlaps this area.

Production capacity scenarios presented in the Strategy

16. Three production capacity scenarios2 are presented in the Strategy as alternative

options.

Production capacity 1

17. This option largely reflects the status quo (with a relatively small industry that is

susceptible to price fluctuations and with little scope for market expansion) and

permit conditions for existing sites, with no new areas allocated except for extension

of sites G and H (see Area 8 in Figure 2.1) to allow tuna penning to be moved

further offshore. In summary, this option considers the following:

No North Aquaculture Zone (AZ);

All existing sites retained;

Such sites used for CCS with exception of the SE Zone and AJD site E (see Area

2 in Figure 2.1);

CCS capacity for sites A, G and H based on original PDG guidelines of 500t/site;

2 The Strategy makes a distinction between production capacities and production targets. The SEA will assess

capacities as a worst case scenario.

9

P2M sites unchanged3;

Nursery production at Marsaxlokk site I;

New outer site G for tuna penning 2km from shore, 1,500t (assumes shift in BA

4);

New outer site H for tuna penning 2km from shore, 1,500t (assumes shift in BA

4); and

Other tuna penning capacity as per current ICCAT permits.

18. The overall resulting capacity under option 1 is 2,500t CCS and 11,500t tuna.


19. This option is based on current policy intentions, for instance, to move existing cages

away from Comino to a new NE Aquaculture Zone, and move tuna production from

sites G and H (see Figure 2.1). In summary, this option includes the following:

North AZ approved;

Assumes Comino site is exchanged for 2,000t production in North AZ;

P2M sites unchanged;

Other existing sites used for CCS with exception of south east AZ and site E;

AJD site E retained for tuna penning operations (permit not as flexible as for F&F

and MFF sites G and H);

CCS capacity 1,000t/site;

Tuna penning capacity as per current ICCAT permits;



4); and


4).



21. Option 3 considers the retention of all existing sites, development of all potential

3 Including the retention of the nursery site at Mistra.

10

new sites, and all tuna farms are moved further offshore (see Figure 2.1). In

summary:

All existing sites retained;

North AZ approved;

P2M sites unchanged;

Newly identified sites approved;

Inshore sites (i.e. <1nm from shore/50m depth), used only for CCS;

Tuna farms at E, G and H moved further offshore;

Area around site E (E2, see Figure 1) used for 2 x 1,000t CCS sites;

CCS capacity 1,000t/site;

Tuna penning capacity as per current ICCAT permits;


New nursery production at Xghajra sites U and V (see Figure 1);


4); and


4).


23. Table 2.1 summarises the potential production capacity scenarios under different

site availability scenarios.

Table 2.1: Potential production capacity under different site availability

scenarios

Capacity 1 Capacity 2 Capacity 3

Site Location Tuna CCS Tuna CCS Tuna CCS

Existing Sites

A AJD

Comino

500 1,000

B-D P2M 1,000 1,000 1,000

E AJD St

Paul’s Bay

2,500 2,500 2,000

F South AZ 6,000 6,000 6,000

G MFF

Munxar

500 1,000 1,000

H F&F Il-

Hofra

500 1,000 1,000

11

Capacity 1 Capacity 2 Capacity 3

Site Location Tuna CCS Tuna CCS Tuna CCS

I MARC

Total 8,500 2,500 8,500 3,000 6,000 6,000

Potential New Sites

G outer MFF

Munxar

1,500 1,500 1,500

H outer F&F Il-

Hofra

1,500 1,500 1,500

J outer North

AZ-inner

1,000 1,000

K North

AZ-inner

1,000 1,000

L North

AZ-inner

1,000

M North

AZ-inner

1,500

N North

AZ-inner

1,500

O E Zone 1,500

P E Zone 1,500

Q E Zone 1,500

R E Zone 1,000

S E Zone 1,000

T Madalena

Shoals

1,000

U Xghajra Nursery

V Xghajra Nursery

W San Tumas

Point

1,000

X New SE

Zone

1,000

Y New SE

Zone

1,500

Z New SE

Zone

1,000

Z1 New SE

Zone

1,500

Total 3,000 0 3,000 2,000 13,500 9,000

Total all

sites

11,500 2,500 11,500 5,000 19,500 15,000

24. The recommendations from the Strategy are the following:

Aspect 1: The Tuna Penning Sector

1. Tuna farms on near shore sites should be relocated to sites with

more than 50m water depth and more than 1nm from shore to

limit impacts.

2. Consideration should be given to restricting the feeding of baitfish to

tuna cages during onshore wind conditions in the summer tourist

season if alternative solutions are not found.

12

3. A review of tuna offal disposal should be carried out.

Aspect 2: The Sea Bream and Sea Bass Sector

4. Sea Bass and Sea Bream will remain important species for the

industry for the foreseeable future so account must be made of this

in strategic planning.

Aspect 3: Alternative Species

5. The main emphasis with regard to development of alternative

species should be on amberjack.

6. A hatchery and spawning facility for amberjack, bluefin tuna and

other species should be established at the earliest opportunity.

7. Other species such as groupers, sparids, octopus and sea urchins

may have potential for production in Malta in the future, and

research into such species should be encouraged providing

commercial potential can be demonstrated.

Aspect 4: Identification of Sites and Potential Production Scenarios

8. Additional marine sites will be needed for future expansion of the

industry in both nearshore and offshore areas. Potential sites are

proposed together with possible production scenarios in the

Strategy.

Aspect 5: Aquaculture Policy

9. It is recommended that the 2004 policy document is updated to

reflect the findings of this study, making sure that it reflects the

needs of the industry and current issues, and taking into account

the views of all stakeholders, especially the growers themselves.

Aspect 6: Regulation

10. Whilst the concept of zoning is desirable in principle for existing sites as well as new sites, it should only be pursued providing that

operators are not financially or operationally disadvantaged and

they are fully consulted.

11. It is recommended that the minimum term for concessions is 25

years, or in accordance with normal commercial lease terms in

Malta, subject to compliance with operating conditions.

12. It is recommended that all tuna farms be located in more than

50m water depth and 1nm from shore, whilst CCS should mostly

13

be in less than 50m water depth at varying distance from the shore.

13. The present process by which farms are monitored and

enforcement instigated should be reviewed and strengthened.

14. The introduction of conditions regarding methods of feeding baitfish

to tuna should be considered.

15. The industry should be encouraged to prepare a COGP, if necessary

supported by funding from the Government.

16. MEPA must be made aware of the strategic intentions of the

Government regarding the industry through a revised policy

document based on the findings of this study.

17. It is recommended that an appropriate individual within MEPA is

trained as an aquaculture specialist to act as a liaison officer

between MEPA and the industry.

18. An Aquaculture Working Group made up of representatives from

the industry, MEPA and MRRA should be established to address

specific issues affecting the industry.

Aspect 7: R&D

19. A mechanism should be put in place to ensure regular (e.g. annual)

reviews of research priorities and funding are carried out involving

government, industry and academic stakeholders.

20. Resources should be committed to the development and testing of

alternative tuna feeds that reduce reliance on baitfish.

21. The PPP model of R&D funding appears to be working well and

should be developed further, although it must allow participation by

all growers in Malta.

22. The development of a new Marine Hatchery and R&D centre is a high priority under the Aquaculture Strategy and full costings and a

finance model, most likely using a PPP, should be developed as soon

as a site has been agreed.

23. Collaboration between MARC and the University of Malta and other

institutions in the Mediterranean, whether to provide access to

specialised research equipment or expertise is recommended.

Aspect 8: Environmental Monitoring

24. It is recommended that a review of environmental monitoring

14

methodology is carried out by an independent international

authority with relevant expertise and that procedures are brought

into line with guidance under development within the GFCM

workshops InDAM and SHoCMed.

25. It is recommended that a consultative forum is established to

develop formal vocational training programmes for Maltese

aquaculture. This should involve industry representatives, training

providers (e.g. MCAST) and the Malta Qualifications Council.

Aspect 9: Fish Health Control

26. It is recommended that disease control is strengthened through the

establishment of Area Management Agreements (AMAs) between

all operators in a zone or area.

27. It is recommended that a contingency plan is prepared by

Government and industry to deal with the possibility of a notifiable

or other serious disease becoming established in Malta.

28. In the event of increased production, the need for and delivery of an

improved fish disease diagnostic capability, such as the one that

used to be provided by the NAC, should be assessed.

Aspect 10: Socio-economic Impacts

29. A commitment to the development of the aquaculture industry is

needed to ensure potential future gains in economic impact are

realised. GVA from penned tuna has the potential to reach €21,

€47 and €73 million in 2015, 2020 and 2025 respectively; whilst

for Closed Cycle Species the equivalent figures could be €17, €26

and €46 million.

Aspect 11: Marketing

30. Support should be given to companies keen to improve the

marketing of their products especially with regard to provenance

and certification.

31. Market research should be conducted to identify specific

opportunities for value-added products from Malta, considering the

mix of product, target market and distribution logistics.

32. It is recommended that marketing budgets are spent on researching

customer needs, identifying competitive advantage and the

supporting actions necessary to exploit these.

33. With regard to amberjack, it is recommended that a marketing

15

study be carried out to identify the product attributes likely to

realise the best returns.

Aspect 12: Improving the image of aquaculture

34. In order to counteract negative views of aquaculture, compliance

with both statutory operating conditions and a publicly available

COGP should be demonstrated.

35. All means of promoting the positive aspects of aquaculture and

educating the public, including farm open days, school visits, and the

use of aquaculture facilities as tourist attractions, should be utilised.

THE SEA PROCESS

25. The first stage of the SEA process is scoping. This sets out the context for the

assessment and defines its scope. It is one of the most important stages in the

process as it identifies the issues for consideration in the Environmental Report.

Although no longer a legal requirement, it is considered good practice to clearly

document the scoping process. The draft Scoping Report was submitted to a

number of stakeholders to obtain their views on the document. The identified

stakeholders included the SEA Focal Point, the Malta Environment and Planning

Authority, the Malta Resources Authority, the Department of Agriculture, the

Department of Fisheries, the Environmental Health Directorate, and other relevant

stakeholders. In addition, the Scoping Report was made publically available on the

MRRA website and notices were published in the Government Gazette inviting

comments from the public.

RELATION OF THE AQUACULTURE STRATEGY TO

OTHER NATIONAL DOCUMENTS & LEGISLATION

26. Schedule 2 of the SEA Regulations requires a discussion of “the degree to which the

plan or programme sets a framework for projects and other activities, either with regard to

the location, nature, size and operating conditions or by allocating resources” and “the

relevance of the plan or programme for the implementation of Community legislation on the

environment, such as plans and programmes linked to waste-management or water

protection”.

27. A detailed analysis was carried out at the scoping stage and is presented in its

entirety in the Scoping Report (see Appendix 1). The analysis was subdivided into

the following main categories:

(i) International Commitments: this category covers the international

environment and sustainability policy framework within which Malta must

work. It includes a selection of global commitments, such as those arising

from the Millennium Development Goals (MDGs), UN Framework

Convention on Climate Change (UNFCCC) and Kyoto Protocol.

(ii) EU requirements: Relevant EU communications specifically concerning

16

fisheries and aquaculture have been included. In the case of European Union

Directives already transposed into national legislation, the Directives per se

will not be discussed; the section on national legislation is described below;

(iii) National Environmental & Planning Documents including the Structure

Plan for the Maltese Islands, the National Sustainable Development Strategy,

and the National Environment Policy. The review provided herein summarises the key issues raised; further information can be obtained from

the original documents;

(iv) National Sectoral Policies and Strategies: this section covers highest-

level policy and strategy documents published by the Government, such as the

National Reform Programme. Rather than summarise entire documents this

review seeks to emphasise the key sustainability objectives and priorities;

(iv) National legislation: no attempt was made to assess the individual

regulations, as is done at the project level EIA (Environmental Impact

Assessment). However, the main areas of concern for the Strategy are

highlighted. Given the scale (and evolutionary nature of this field) this review

is not exhaustive and represents a current (July 2012) snapshot.

17

Figure 2.1: Existing and proposed aquaculture production sites

18

CHAPTER 3: SEA METHODOLOGY

INTRODUCTION

28. This chapter describes the approach adopted in this SEA, the SEA process itself, its

limitations, and the consultation process.

29. As discussed in Chapter 1, the SEA process in Malta is regulated by Legal Notice

497 of 2010 (the SEA Regulations); this Legal Notice transposes Council Directive

2001/42/EC. Since guidance on SEA for Malta has not yet been published, this

assessment draws on other European Guidance, namely, the Greening Regional

Development Programme’s (GRDP) (2006) “Handbook on SEA for Cohesion Policy

2007- 2013”, the Commission’s “Implementation of Directive 2001/42 on the

Assessment of the Effects of Certain Plans and Programmes on the Environment”,

and the UK’s (2005) “A Practical Guide to the Implementation of the SEA Directive”.

30. This SEA began in May 2012, following a Call for Tenders by the Ministry for

Resources and Rural Affairs. The Consultants (Adi Associates Environmental

Consultants Ltd) have carried out the SEA in consultation with the proponents of the

Strategy.

DETERMINING THE SCOPE OF THE SEA

31. The scope of the SEA is identified in the Aquaculture Strategy SEA Scoping Report.

The Scoping Report identifies a range of relevant polices and plans that could be

influenced by, or which could influence, the Strategy.

32. The Scoping Report also contains an initial list of key environmental issues that were

identified and reasons for their inclusion in the Scoping Report are provided. SEA

objectives and indicators were also described. Monitoring based on the chosen SEA

indicators will provide information on the effectiveness of the Strategy in achieving

the SEA objectives.

CONSULTATION

33. The following entities were consulted during the drawing up of the Environmental

Report:

Malta Environment and Planning Authority;

Malta Resources Authority

Environmental Health Directorate;

Department of Fisheries;

Department of Agriculture; and

Local Councils Association.

19

34. Other Government entities, NGOs, and the commercial sector were also consulted.

35. Comments were received on the Scoping Report from the Environment Protection

Directorate of MEPA. These comments were addressed and the Scoping Report was

amended where relevant.

ASSESSMENT PROCESS

36. The SEA process provides the start of the 'green thread', having identified: a)

potential environmental impacts that could result from the implementation of specific

actions or strategies detailed in 12 Recommended Aspects of the Strategy; b) various

mitigation strategies and measures that could be used to minimise or negate the

impacts of these actions; and c) a number of future areas or activities for which

further environmental assessments may be required before and during the

implementation of the Strategy.

Link to Other Assessments

37. The SEA takes into account environmental issues in accordance with Schedule I(f) of

the SEA Regulations, 2010.

ALTERNATIVES

38. The SEA Directive requires the assessment to identify the likely significant effects on

the environment of implementing the plan or programme, as well as considering

reasonable alternatives, taking into account the objectives and the geographical scope

of the plan or programme. Chapter 6 provides an assessment of alternatives considered within the Strategy. These are related to alternative sites as well as to

alternative production capacity scenarios.

20

CHAPTER 4: ENVIRONMENTAL BASELINE

INTRODUCTION

39. A good understanding of the environment of the areas covered by the SEA is

essential for the performance of a sound assessment. It is therefore necessary to

establish the environmental baseline relevant to the plan or programme being

proposed. This provides a snapshot of the existing state of the environment and a

description of the likely future trends (based on past trends) without the programme

being in place.

40. Schedule I of the SEA Regulations requires that the Environmental Report includes a

description of "the relevant aspects of the current state of the environment". This

Chapter provides summary information on the current state of Malta’s environment,

environmental trends (where available), and indicates those issues that are

considered to be of particular relevance to the development of the Aquaculture

Strategy.

41. The data replicated here were collated from a number of sources; the SEA relies on

existing data. The description provided below is essentially a broad-brush4 "State of

the Environment" review of the Maltese Islands focusing on the main environmental

issues. Table 4.1 summarises this broad-brush description.

42. The National Sustainable Development Strategy 2006 to 2016 identifies Malta's

environmental challenges; it arises from a systematic review of official reports

including the State of the Environment Reports (1998, 2002, and 2005) and Malta's

National Report to the World Summit on Sustainable Development (2002), and an

extensive consultation process Malta’s National Environmental Policy, 2012 further

strengthens the environmental pillar of the Sustainable Development Strategy and

seeks to integrate environmental and development policies within the context of

Europe 2020. The following environmental challenges were identified:

Air quality and climate change;

Energy-efficiency and renewable energy resources;

Biodiversity / fauna and flora;

Water;

Soils;

4 This broad-brush review does not purport to be a complete treatise of environmental data available for the

Maltese Islands but aims solely to give an overview of the main environmental issues and trends applicable to

the sector under review in this SEA. Hence, there may be documents, papers, or reports that are not

referenced or referred to in this Environmental Report; this does not in any way devalue the content of this

environmental baseline.

21

Landscape;

Cultural heritage;

Human health; and

Material assets and population.

43. On the basis of the above challenges, and the scope of the SEA, Table 4.1 shows

how the Environmental Report draws together the relevant issues and baseline data.

Table 4.1: Environmental baseline

Issue Relevant baseline data Illustrative material

Air quality and climate

change

GHG inventory

Odour emissions from the sector (if

data is available)

Coastal erosion, sea level rise, changing

weather patterns resulting from climate

change

Graphs and figures.

Biodiversity / fauna and

flora

Areas protected and managed under

international and local legislation;

Areas known to support priority Annex

I habitats under the Habitats Directive

Protected species;

Areas for which surveys have been

carried out;

Potential new marine conservation

areas

Designated, managed and surveyed

areas; where relevant, any data

related to areas, habitats and/or

species that are not formally

protection although they are

considered to be of conservation

value

Water Information on the quality of the marine

environment

Information on groundwater

Water Framework Directive targets,

objectives, protected areas

Maps / graphs / tables

Soil Marine sediments

Published data and figures

Landscape Areas protected for landscape value

Landscape sensitivity areas and

protective designations

Cultural heritage Sites protected for cultural heritage

Maps

Human health Environmental health data (where

available);

Water users;

Consumers of fish and aquaculture

products

Graphs and tables

Published data

Material assets and

population

Commercial fishing/aquaculture

activities;

Waste management infrastructure;

Coastal and marine based tourism

interests/attractions;

Sea uses

Maps / figures

22

44. Where possible, quantitative data are presented in the form of maps, tables, and

figures. A brief description of the baseline and any trends are given, where available.

LIMITATIONS OF DATA

45. The data used to formulate the environment baseline were collated by a range of

organisations for a number of purposes; no information has been collated specifically

for the assessment of the environmental impacts of the Aquaculture Strategy.

However, given the specificity of the sector, much of the information collected to

date has a direct bearing on what the Strategy aims to achieve, thus facilitating the

inference of relationships between changes in the environmental baseline recorded

and the potential effects of the Strategy.

46. Examples of difficulties in locating data or suitable datasets include:

Odour emissions from the aquaculture sector;

Data on fish diseases;

Data on fish contamination; and

Data on water quality trends for sea bream / sea bass farms.

EMISSIONS TO AIR AND CLIMATE CHANGE

Emissions to air

47. At a national level, air quality is assessed by measuring the levels of the major

pollutants: sulphur dioxide (SO2), nitrogen oxides (NOx), benzene, and ozone (O3),

as well as suspended particulate matter. In Malta, these pollutants are mainly created

by traffic and electricity generation plants. The aquaculture sector has a negligible

impact on air quality, with a limited contribution from feeding and service vessels.

Therefore, consideration of the existing baseline data on the major pollutants has

been omitted from the Environmental Report.

48. Uneaten baitfish that deposits on the bottom of the sea will start to decompose,

releasing gases such as hydrogen sulphide and ammonia. These gases are insoluble in

seawater and therefore rise through the water column until they reach the surface,

where they produce unpleasant odours, which, depending on the prevailing wind

currents at the time, could be blown onshore. These odorous gases are partly to

blame for the complaints reported sporadically over the past years, especially from

the tuna farms up north (which are more in the path of prevailing winds than the

southern farms, as compared to land). Obviously, moving the farms further offshore,

including the potential creation of a new Aquaculture Zone in the north would help

mitigate somewhat the current problems encountered on land from inshore farms.

The use of pelleted feeds would address this issue, however, at this stage it is difficult

to wean wild caught Blue-fin tuna (bait-fish are only used for such fish) to pelleted

feed. It should be pointed out this is not an issue with closed-cycle species that are

23

reared on pellet feed.

49. Odour emissions from land bases can be generated from storage of feed and from

maintenance on nets and other marine infrastructure.

Climatic Factors

50. Increases in anthropogenic greenhouse gases (GHGs) are the major contributor to

climate change5. The main GHG is carbon dioxide (CO2) that contributed to 88.1% of

emissions in 2010. There has been an increase of emissions of 47.9% from 1990 to

20106.

51. The Greenhouse Gas Inventory for Malta for the period 1990-2010 shows that

aquaculture does not significantly contribute to such emissions7.

52. In 2010, the main contributor of GHG emissions is the energy sector which accounts

for 88.9% of all emissions (71.2% of which are generated by power plants and 30.4%

of which are generated by the transport sector). Following the energy sector there

is the waste sector with a share of 6.7%, the agricultural sector with a share of 2.7%

and other industrial processes with a share of 1.8%8, see Figure 4.1.

53. It is noted that, to date, Malta does not have any quantified mandatory targets for the

limitation or reduction of greenhouse gas emissions under the United Nations

Framework Convention on Climate Change (UNFCCC) / Kyoto Protocol process9.

Malta has however been assigned a GHG emission limitation for non-ETS sectors

under the new Effort Sharing Decision (as part of the climate change-energy package

agreed in December 2008). Malta must limit its emissions by 2020 to 5 per cent

above 2005 levels. In addition, by 2020 Malta must obtain 10 per cent of its energy

requirements from renewable sources.

5 IPCC (Intergovernmental Panel on Climate Change), Climate Change 2007: The physical science Basis:

Summary for Policy-makers, Contribution of Working Group I to the Fourth Assessment Report of the

Intergovernmental Panel on Climate Change, 2007. 6 Malta Resources Authority (2012) National Annual Greenhouse Gas Emissions Report for Malta – Submission

under the United Nations Framework Convention on Climate Change. 7 Ibid. 8 Ibid. 9 Malta became an Annex 1 country following its request in COP-15/MOP-5 in Copenhagen. Nonetheless, it is

not bound by reduction targets of the first Kyoto Protocol commitment period (2008-2012).

24

Figure 4.1: Greenhouse gas emissions by sector: 1990 – 2010

BIODIVERSITY

54. Malta’s natural environment includes habitats such as cliffs, valleys, garrigue and sand

dunes. Natural vegetation covers only 18 per cent of Malta’s surface area.

Nonetheless, the islands have a rich biodiversity, which includes a large number of

native plants and animals10.

55. The local vegetation community is mainly characterised by the so-called sclerophyll

series, comprising evergreen wood, maquis, garrigue and steppe. Other vegetation

communities include coastal cliffs, freshwater and saline wetlands, and sand dunes,

together with a variety of marine habitats such as seagrass meadows and habitats

based on coralline red algae. The current status of selected groups of species is

identified in Table 4.2. Of note is that the status of 36 per cent of the Maltese

species listed in the Habitats Directive is unknown, whereas 44 per cent of species

have an inadequate or bad conservation status11.

10 MEPA, The Environment Report 2008, Sub-report 8: Biodiversity, 2010. 11 MEPA, The Environment Report 2008, Sub-report 8: Biodiversity, 2010.

25

Table 4.2: Current status of marine species

Species group Status

Plants The status for the marine species could not be assigned in view of limited data.

Mammals 12 marine species recorded from the Maltese Islands were assessed. The status of

marine mammals remains unknown. Four cetaceans are considered occasional visitors.

Reptiles The status of the Loggerhead Turtle (Caretta caretta) – a marine reptile – in Maltese

waters, is as yet unknown.

Fish Only two fish species were assessed, the Mediterranean Killifish (Aphanius fasciatus) and

the Allis Shad (Alosa fallax). Whilst the Mediterranean Killifish has an unfavourable /

inadequate conservation status, the status of the Allis Shad is as yet unknown.

Invertebrates Six marine invertebrate species were assessed. The general status of marine species is

unknown.

Source: MEPA, The Environment Report 2008, Sub-report 8: Biodiversity.

56. The main threats to local biodiversity are unsustainable development in rural and

marine areas, the introduction of alien species (including GMOs), the exploitation of

wildlife including illegal collection, hunting and trapping, and climate change12.

Protected areas and species

57. Biodiversity is safeguarded mainly through the protection and management of sites

and areas. Figure 4.2 illustrates the designated and managed areas as of April 2012.

As of the end of 2008, 20.5 per cent of the land area was designated.

58. Currently, there are 32 Nature Reserves, 26 Bird Sanctuaries and 66 Areas of

Ecological and / or Sites of Scientific Importance; some of these designations overlap.

There are also two sites designated as Wetlands of International Importance under

the UN Ramsar Convention (l-Ghadira and is-Simar), and four sites designated as

Specially Protected Areas (SPAs) under the Barcelona Convention. In 2007, all beaches and swimming zones in close proximity to urban areas and roads (including

11 specifically named beaches), were given legal protection against hunting.

59. There are currently 28 Special Areas of Conservation of International Importance

(SACs) under the EU Habitats Directive and 13 SPAs under the EU Birds Directive

(these are automatically designated as Natura 2000 sites, see Figure 4.3). In some

cases, the area of SAC and SPA sites overlap. There are also five marine SACs of

International Importance, see Figure 4.4.

60. The management of such sites helps to ensure that conservation goals are reached.

As of 2007, seven sites were being actively managed in Malta. Management plans for

another four sites are currently being prepared or are under review13.

12 MEPA, 2010. The Environment Report 2008, Sub-report 8: Biodiversity, 2010. 13 Ibid

26

Figure 4.2: Designated areas

Source: EIONET, Common Database of Designated Areas (CDDA) 2012 Retrieved 06 June 2012 from http://cdr.eionet.europa.eu/mt/eea/cdda1/envtus7hw/index_html

http://cdr.eionet.europa.eu/mt/eea/cdda1/envtus7hw/index_html

27

Figure 4.3: Natura 2000 sites



28

Figure 4.4: Marine SACs of International Importance



29

61. In 2005, 183 out of 189 local species of international importance were protected by

national legislation; in 2002 only 115 of these species were protected. Since then,

protection was significantly increased for fish, crustaceans, and higher plants as shown in

Figure 4.5.

62. The National Sustainable Development Strategy (2006) states that the intention of the

Maltese Government in the field of biodiversity is to, amongst others, prepare management plans for the Special Areas of Conservation and to develop a National

Biodiversity Strategy based on the aims of the Convention for Biological Diversity. A

draft National Biodiversity Strategy and Action Plan was presented by the Ministry for

Tourism, Culture and the Environment together with MEPA in February 2012 and was

subsequently approved.

Figure 4.5: Percentage protection of local species of international

importance: 2002-2005

Source: MEPA, State of the Environment Report 2005, Sub-report 9: Biodiversity, 2005

30

Marine biodiversity

63. The waters around the Maltese Islands support important marine habitats including

Posidonia oceanica seagrass meadows, and habitats based on coralline red algae, which

form complex assemblages that support further biota.

64. This section describes marine biodiversity including benthic data. It should be noted,

however, that there are data gaps, and benthic areas that have been studied, were

largely as a result of studies related to projects and development. Only a few specific

studies have been commissioned to study the marine benthos in the Maltese Islands.

These include a study that was commissioned by the Malta Environment and Planning

Authority in 2002 to map Posidonia meadows around the Maltese Islands, and the

Biomaerl project, which was funded by the Fourth Framework Programme (1994-1998)

and which included the University of Malta as one of the partners. New information on

the seabed characteristics is expected to be available later on this year (2013) as a result

of MEPA’s EU project on the Development of Environmental Monitoring Strategy and

Environmental Monitoring Baseline Surveys. This project is expected to aid the mapping

of the seabed, including its physical and geomorphological characteristics and its benthic

habitats.

65. Seagrasses are marine flowering plants that constitute an important habitat to a number

of species. A variety of species are dependent on seagrass meadows because they

provide shelter, breeding grounds, and nursery grounds, and act as a direct and indirect

source of food. Seagrasses are also important in preventing coastal erosion and

contribute to oxygenation of the sea.

66. Five species of seagrasses have been reported around the Maltese Islands, of which two

are presumably extinct14. The most important species are the Neptune grasses Posidonia

oceanica and the Lesser Neptune Grass Cymodocea nodosa.

Status of Posidonia Meadows

67. Posidonia oceanica occupies 3.6 percent of Maltese territorial waters, with a total

coverage of 142.56 km2. Posidonia beds are listed as a priority habitat in Annex I of the

Habitats Directive. Thus, distribution of these meadows will play an important part in

the selection and designation of marine Special Areas of Conservation around the

Maltese Islands.

68. As described in Malta’s State of the Environment Report (2005), and referred to above,

in 2002 MEPA commissioned a study to map Posidonia meadows around the Maltese

Islands and to determine their condition. Figure 4.6 illustrates the distribution of

Posidonia around the Maltese Islands based on the 2002 survey.

14 Biodiversity Sub-report, State of the Environment Report, 2005.

31

69. The survey concluded that Maltese Posidonia oceanica meadows were generally in a good

state of health. Dense coverage was found within the channels between Gozo and

Comino and Comino and Malta. Given its sensitivity, Posidonia oceanica acts as a

bioindicator highlighting problems in the marine environment arising from pollution,

turbidity, waste and chemical discharges, impacts from fishing, dredging, run-off, and

coastal development. This species has been officially adopted by a number of Member

States as a bio-indicator informing the implementation of the Water Framework

Directive15.

70. The fisheries sector exerts the second largest maritime pressure on the Maltese

environment after shipping16. Fish farming, whilst reducing the pressures generated by

traditional fishing, has its own impacts on the marine environment.

71. The impact of fish farming on the marine ecology may arguably vary from negligible to

substantial depending on various factors such as site location and the habitat’s sensitivity,

water depth, as well as the operator’s practices. The most severe impacts were

recorded in the farm sites close to the Posidonia oceanica meadows along the North-

Eastern coast of Malta17. These sites predated the need for environmental impact assessments. Fish farms with adequate site selection processes have had less negative

impacts, which MEPA (2010) has argued is likely to be reversible in the eventuality that

site operation is stopped18.

72. Dimech et al (2000) conducted a study on the effect of the fish farm located at St Paul’s

Bay, which had been operating without any consideration of the carrying capacity of the

site, on Posidonia oceanica meadows. Gilthead Sea Bream has been produced in this area

since 1991 in waters with a 12 – 16m depth. Posidonia oceanica meadows are located

some 10m away.

73. The study revealed an impact on Posidonia oceanica meadows up to 170m away from the

cages. A high epiphyte load, high suspended organic matter and increased

phytoplankton production all contributed to low leaf lengths in Posidonia in the

immediate vicinity of the cages. Between 30 to 170m from the cages, a high epiphyte

load remained although suspended organic matter and phytoplankton production

decreased resulting in an increased leaf length in this zone. At 330m all parameters

were low and a further increase in the leaf length of Posidonia in this area was noted.

Thus, the study showed a trend towards an increasing mean leaf length, adult leaf length,

15 Dimech M, Camilleri M, Borg J.A, Smith P, Sciberras M, Schembri P.J. 2007 The potential of fisheries reserves as a

tool for biodiversity conservation. The case of the 25 Nautical Mile Fisheries Management Zone around Malta. [Poster] 16 MEPA, The Environment Report 2008, Sub-report 6: Coastal and Marine Environment, 2010. 17 Dimech M., Borg J.A. & Schembri P.J. (2000) ‘Structural changes in a Posidonia oceanica meadow exposed to a

pollution gradient from a marine fish-farm in Malta (Central Mediterranean)’ in Biologia Marina Mediterranea 7(2):

361-364. 18 MEPA, The Environment Report 2008, Sub-report 6: Coastal and Marine Environment, 2010.

32

biomass and density with distance from the cages. It is however, noted that the site in

question pre-dates the current MEPA permitting system and no baseline studies were

carried out prior to the installation.

Maerl beds

74. Maerl beds are biogenic assemblages made up of alive and dead unattached coralline

algae forming nodules or rhodoliths. This results in a heterogenous substratum that supports a high biodiversity, including a rich fish fauna. An extensive maerl ground

covering about 20 km2 is located off the northeastern coast of Malta and Gozo at a

depth of 30-100m19; to date over 400 species of macrofauna and macroflora associated

with this maerl bed have been recorded20(see Figure 4.7). However, it should be noted

that other accumulations of rhodoliths or unattached coralline algae have been

discovered from other areas including off the southeastern coast of Malta up to a

maximum depth of 85m21; off the north-eastern coast of Malta at depths of 45-50m, area

characterised by maerl beds (supporting gorgonian Eunicella singularis in places)22 and

associations with rhodoliths; and off the southwestern coast of Malta between Malta and

Filfla.

75. The main rhodolith-forming algae in Maltese maerl beds are Lithothamnion coralloides,

Lithothamnion minervae, and Phymatolithon calcareum.

76. The main threats to maerl beds are from bottom trawling and changes to the

sedimentary regime as a result of coastal development23.

Deep water coral beds

77. Coral assemblages of the Lophelia pertusa, Madrepora oculata, and Desmophyllum dianthus

triad24 have also been recently recorded in the Maltese Islands (see Figure 4.7).

19 Sciberras, M., Rizzo, M., Mifsud, J.R., Camilleri, K, Borg, J.A., Lanfranco, E., Schembri, P.J. 2009. Habitat structure

and biological characterisitics of a maerl bed off the north-eastern coast of the Maltese Islands (Central

Mediterranean). 31. Marine Biodiversity. 20 Dimech M, Camilleri M, Borg J.A, Smith P, Sciberras M, Schembri P.J. 2007 The potential of fisheries reserves as a

tool for biodiversity conservation. The case of the 25 Nautical Mile Fisheries Management Zone around Malta. [Poster] 21 Adi Associates Ltd. 2005. Development of an Aquaculture Zone south-east of Malta off Zonqor Point,

Marsaskala. Environmental Impact Statement. Report prepared for Malta Centre for Fisheries Science. 22 Adi Associates and Scott Wilson. 2008. Detailed investigation and feasibility studies on Land Reclamation at two

indicated search areas, Malta. Technical Report 1; Volume 1. Report prepared for Malta Environment and Planning

Authority. 23 Adi Associates Environmental Consultants Ltd, 2008. Strategic Environmental Assessment on Malta’s Fisheries

Operational Programme 2007-2013. 24 Schembri P.J., Dimech M., Camilleri M., Page R. 2007. Living deep-water Lophelia and Madrepora corals in Maltese

waters (Strait of Sicily, Mediterranean Sea). 48: 77-83. Les Cahiers de Biologie Marine

33

Other species

78. Cetaceans, chelonians and sea birds can be negatively affected through fish farming

activities. Sea birds are particularly affected if farms are found close to nesting sites and

rafting zones25. At present, none of Malta’s fish farms are located in such areas.

25 Adi Associates Environmental Consultants Ltd, 2008. Strategic Environmental Assessment on Malta’s Fisheries

Operational Programme 2007-2013.

34

Figure 4.6: Distribution of Posidonia meadows

35

Figure 4.7: Extent of the maerl bed

36

Fish Stocks

79. Although data are collected for a number of species, many commercial fish stocks in the

Mediterranean Sea are still not monitored. Figures 4.8 and 4.9 illustrate fish stocks in

the Mediterranean by species and for each nation. Table 4.3 illustrates the country

each column number represents. Malta is represented by column 15.

Table 4.3: Key for column numbers listed in Figure 4.9

Code Number Area

1 Northern Alboran

2 Alboran Island Sea

3 Southern Alboran Sea

4 Algeria

5 Balearic Island

6 Northern Spain

7 Gulf of Lions

8 Corsica

9 Ligurian and North Tyrrehenian Sea

10 South and Central Tyrrehenian Sea

11 Sardinia

12 Northern Tunisia

13 Gulf of Hammamet

14 Gulf of Gabes

15 Maltese Islands

16 South of Sicily

17 Northern Adriatic

18 Southern Adriatic

19 Western Ionian Sea

20 Eastern Ionian Sea

21 Libya

22 Aegean Sea

23 Crete

24 South of Turkey

25 Cyprus

26 Egypt

27 Levant

28 Marmara Sea

29 Black Sea

30 Azov Sea

37

Figure 4.8: State of commercial fish stocks in Mediterranean Sea up to 2005

38

Figure 4.9: State of commercial fish stocks in Mediterranean Sea up from 2001 to 2009

39

80. Figure 4.8 illustrates that there is a general trend in the Mediterranean that is also

experienced in Malta, i.e. that Hake, Red Mullet, and Bluefin tuna stocks are under

threat, whilst stocks of anchovy, pilchard, and swordfish are within safe biological limits.

Data is not gathered for 80% of species of commercial importance.

81. An important fish species for Malta, not listed in Figure 4.8 is the dolphin fish

(Coryphaena hippurus). Malta’s State of the Environment Report (2005) reports that dolphin fish stocks are not under pressure from fishing activity. This is related to the

biology of this fish, which has a long spawning season during which time both males and

females spawn regularly. Moreover, sexual maturity is reached at 4-5 months as

opposed to other fish such as the Bluefin tuna, which reaches maturity at about 10-11

years.

82. As reported by the European Environment Agency, the latest assessment by the

International Commission for the Conservation of Atlantic Tunas (ICCAT) reports that

efforts made over recent years have rendered the exploitation of swordfish

sustainable26.

Bluefin Tuna 83. Fishing for Bluefin tuna in the Mediterranean Sea is traditional of the culture of this

marginal sea, commencing as early as 12,000 years ago. It has been a sustainable fishery

for at least the past 2,600 years, and a source of food and income for several coastal

communities.

84. Bluefin tuna spawn throughout the Mediterranean mainly along the Balearic and

Tyrrhenian coasts and in the Central Mediterranean, with spawning occurring in the

Aegean Sea. Historically, the Black Sea was considered to be the most important

spawning area for Mediterranean Bluefin tuna, but they no longer pass through the

Dardanelles and the Sea of Marmara, or the Bosphorus straits to spawn, and the historic

tuna fisheries of the Black Sea and the Bosphorus no longer exist (Dean et al., 200227).

85. For centuries, Bluefin tuna have been caught while migrating along Mediterranean shores

by means of nets or traps, called tonnara [Malt.: tunnara]. The catch was a highly

ritualised affair, especially in Sicily and Sardinia, where it is referred to as “mattanza”

(from the Spanish word “matar” meaning “to kill”) and requires a massive team effort by

many fishermen28. During the mattanza, teams of fishermen drive ten-foot long

sharpened gaffes into the backs of the tuna, which would have been caught in a complex

set up of nets, and haul them into the holds of their boats.

26 http://ims.eionet.europa.eu 27 Dean, J.M., Addis, P., and Cau, A., 2002. Mediterranean Bluefin Tuna: an ancient fishery copes with modern

demands. Accessed at http://www.mareblucamogli.com/mediterranean_bluefin_tuna.htm. 28 For more details see for example the following websites: http://www.bestofsicily.com/mag/art125.htm or

http://www.incanto.biz/html/letters_-_mattanza.html.

http://www.bestofsicily.com/mag/art125.htm

http://www.incanto.biz/html/letters_-_mattanza.html

40

86. Today, tuna are caught by a variety of methods, including trap-nets, gill-nets, long lines,

purse-seines (encircling nets), hand line, fishing rod, and baitboat (see FAO Copemed

webpage29).

87. Like most Mediterranean countries, Malta too has a history of tuna fishing using trap

nets (tunnara). These set nets were situated in five different sites in the north of the

island off Mellieha/Mgarr30. Official Government statistics show that as early as 1920 a substantial amount of tuna were being landed at the Valletta fish market during the tuna

season (May to July). However, the limitations of the market and the lack of facilities to

store tuna for preservation made the whole operation uneconomical. The canning

industry set up by Government31 to transform the tuna fisheries industry had to revert

to importation of tuna from North Africa and Italy to supplement the local catches from

the tunnara. The latter too was wound up in the 1960s and up until the 1980s, tuna

landings, though substantial, were not a result of a targeted tuna fishery, but as by-catch

of the, then, more important swordfish long-lining industry32 (Fenech Farrugia, 200333).

88. Long-line tuna fishing in Malta was introduced in 1953 following recommendations by Mr

T.W. Burdon34 that the long line fishing method would be more suitable for local use as it was less expensive and did not require such a large number of fishermen working

together, as was the case with the tunnara. Nonetheless, it was only in the sixties that

long-lining became widely used as a tuna fishing method (NAC, 2000).

89. Today, tuna is caught by means of drifting surface long-lines (Malt.: konz) that are baited

with Atlantic Mackerel and/or Japanese squid (NAC, 200035). Depending on the size of

the boat, the number of hooks set in a long line could be as many as 2,500.

90. Fishing is undertaken to the west, south, and south east of the Maltese Islands, within an

area of approximately 2,000 square miles (NAC, 2000). At the beginning of the season

the effort is concentrated mainly in the south-western sector, tracking to the east as the

fish migrate.

91. One of the two main streams of Maltese aquaculture is tuna penning, which is based on

29 http://www.faocopemed.org/en/activ/research/tuna/tunidos00/general.htm 30 The Fishery Regulations of 1934 (GN 206 of 1934) identify the following sites as available for the laying of tunny

nets: (i) Mellieha, (ii) Cirkewwa and Id-Delli, and (iii) Ghajn Tuffieha and Gnejna. Other sites would be subject

to approval of the Director of Fisheries. 31 Act 1 of 1950. Tunny Fishery (Shares) Act. An Act to enable the Government of Malta to subscribe part of the capital

of a proposed tunny fishing commercial company and to make other provisions in respect thereof. 20th February 1950.

[Chap. 129] 32 During the 1970s and 1980s, swordfish and lampuki (dolphinfish) were the mainstay of the local fishing industry. 33 Fenech Farrugia, A., 2003. Description of the Maltese longline fishery targeting Bluefin tuna (Thynnus thunnus L.)

in the Mediterranean Sea. Col, Vol. Sci. Pap. ICCAT, 55(3): 1148-1156 (2003). 34 Mr Burdon was the Director of Fisheries in Singapore and was invited to Malta by the British Government. 35 National Aquaculture Centre, 2000. Malta Report 2000, FAO Copemed Project.

41

capturing wild tuna of over 70kg each. The advances in cage technology in the late

1990s led to the creation of the first tuna ranching operation in Malta in 2000 becoming

the main producer in the fish farming sector, see Figure 4.10. Capturing takes place

during the months of May and June and the tuna are fattened for approximately 6

months.

92. Catch limits have been in place for the east Atlantic and Mediterranean since 1998. In 2002 ICCAT set the Total Allowable Catch (TAC) to 32,000t for 2003-2006 and at

29,500t and 28,500t for 2007 and 2008, respectively. TACs for 2009, 2010 and 2011

were 22,000t, 19,950t, and 18,500 t, respectively. However, the 2010 TAC was then

revised to 13,500t and this established a framework to set future (2011 and beyond)

TAC at levels sufficient to rebuild the stock to BMSY36

by 2022 with at least 60%

probability. The 2011 TAC was set at 12,900t. Reported catches in 2005 and 2007

exceeded the TAC, however, given fishing capacity ICCAT considers it highly probably

that there was a considerable degree of under-reporting and that TACs were in fact

exceeded significantly. Implementation of the rebuilding plan (including a reduction in

the period for purse seiner fishing) and better monitoring and enforcement controls has

improved the situation to keep catch at or below TAC (see Figure 4.10), however, the

over capacity remains a concern in the stock rebuilding strategy37.

93. ICCAT’s Standing Committee on Research and Statistics (SCRS) 2010 report on the

Atlantic Bluefin Tuna Stock Assessment Session38 indicates that implementation of the

more recent measures including the changes in TAC are showing an initial indication of

increasing stock biomass. The report expects that continued implementation at these

TAC levels should ensure that targets are reached in terms of increasing stock and

identifies, however, that an increase in the current TAC would not allow targets to be

achieved. The report does identify levels of uncertainty and the fact that adaptation to

the new management measures is still ongoing and therefore more data needs to be

gathered before concrete conclusions can be drawn.

36 BMSY is the biomass (total weight of fish) that can support harvest of the maximum sustainable yield (MSY). MSY

in relation to the stock is the greatest yield that can be achieved over time while maintaining the stock’s

productive capacity, taking into consideration the population dynamics of the stock and any environmental

factors that influence the stock. If biomass is below the BMSY, less fish are available, catch rates and average fish

size are also lower; if biomass is above the BMSY, then catch rates, availability and the average fish size can be

expected to increase, however, the total catch is less (catch is comprised mostly of many large, older fish). 37 ICCAT, SCRS. Executive Summary. Bluefin tuna. 2010-2011. 38 SCRS/2010/018. 2011. Report of the 2010 Atlantic Bluefin Tuna Stock Assessment Session. Collect. Vol. Sci.

Pap. ICCAT, 66(2).

42

Figure 4.10: Reported catch for the East Atlantic and Mediterranean from

Task I data from 1950 to 2010 split by main geographic areas (top panel) and

by gears (bottom panel) together with unreported catch estimated by the

Committee (using fishing capacity and mean catch rates over the last

decade) and TAC levels since 1999.

Source: SCRS (2011)

94. Apart from the risk of stock collapse, other environmental concerns are linked to tuna

penning. There are concerns on the large quantities of wild-caught pelagic fish that is

caught to feed the tuna. In Malta, bait fish is imported from North Africa, Asia, the EU

and other countries. The FAO (2008) reports that Bluefin tuna are largely fed on a diet

of a variety of small pelagic species including sardine (Sardinella aurita), pilchard (Sardina

pilchardus), round sardinella, herring (Clupea harengus), mackerel (Scomber japonicus),

43

bogue (Boops boops), and squid (Illex sp.). The proportion and volume of the feed varies

between countries and from farm to farm, with feed composition also based on the

availability of the species generally used39.

95. The use of this foodstuff and the dumping of by-products can also cause water

pollution40.

96. In addition to the management of this fishery through ICCAT, it should be noted that

from an ecological and conservation point of view, Bluefin tuna is listed in the updated

version of Legal Notice 311 of 2006, specifically under Schedule VIII (Animal and Plant species of

national interest whose taking in the wild and exploitation may be subject to management

measures).

Sea Bream (Sparus aurata) and Sea Bass (Dicentrarchus labrax)

97. Gilthead Sea Bream and European Sea Bass are the first two species to be used in large

scale commercial aquaculture in Malta in 1990. Nowadays these two species account

for a small percentage of the total aquaculture production in Malta particularly Sea Bass.

Production of Sea Bream is on the increase both as seen in Figure 4.11 and 4.12.

98. In light of the concerns over tuna penning and higher efficiency it is likely that gilthead

Sea Bream will remain the main product of the finfish aquaculture. Sea Bass is more

costly to produce and strategies are undertaken to increase the profitability of

producing it.

New species

99. Many fish farm operators are looking into the possibility of producing new species.

Many are already producing meagre (Argyrsomus regius) in small quantities.

100. Amberjack (Seriola dumerili) has been reared in very small quantities since 1995 using

wild-caught juveniles. Research and development is still underway to have a closed-cycle

type of production. The Amberjack Project in 2006 is a Maltese joint venture between

Malta Fishfarming Ltd and the Malta Aquaculture Research Centre (MARC) with the aim

of better understanding the spawning and juvenile rearing methods of the Seriola. The

first five year term ended in 2011 and another five year joint venture has been signed.

2012 has seen a significant increase in amberjack juvenile production which augurs well

for the future of this species in Maltese aquaculture.

101. Other species that can be potential species in the Maltese aquaculture industry include:

groupers; sparids; dolphinfish; and the shi drum as native species, while there is a

39 Capture Based Aquaculture – Global Overview; FAO Fisheries Technical Paper; Rome 2008 40 General Fisheries Commission for the Mediterranean International Commission for the Conservation of Atlantic

Tunas (2005) Third Meeting of the Ad Hoc GFCM/ICCAT Working Group on Sustainable Bl.efin Tuna Farming /

Fattening Practices in the Mediterranean. FAO Fisheries Report No. 779.

44

potential for non-fin fish aquaculture in the common octopus, seaweed and sea urchin

roe.

Figure 4.11: Aquaculture production in Malta, 2001-2009. Figures in

thousands per tonnes

Source: NSO, FAO, MARC

45

Figure 4.12: Annual production of Sea Bream and Sea Bass from Maltese

farms, in thousands of tonnes

Source: MARC, NSO

Fish health

102. Fish in the Mediterranean aquaculture industry can suffer from different diseases. Most

of these can easily be controlled whilst some are the cause of mortality. A number of

health issues emerged from the start of the industry in Malta. Flexibacter, Vibriosis and

Pasteurellosis have had a negative impact on the fish immune system. Myxozoan

parasites, like enteromyxosis and Sphaerospora dicentrarchus have had a particularly

negative economic impact. In the mid-1990s a particularly serious viral disease was the

Viral Nervous Necrosis (VNN).

103. Flexibacter was initially treated by nitrofurans yet this was banned by the EU in the late

1990s and oral antibiotics like oxytetracycline were used instead. The problem of

Flexibacter has been almost eliminated through improvements in hatcheries and the use

of immunostimulants.

104. Pasteurellosis is the most significant infection that affects Sea Bream, Sea Bass and

meagre stocks in Malta. It can be a lethal infection during the nursery phase with

outbreaks killing 5 to 15 per cent of the stock. Antimicrobials like oxytetracycline and

46

flumequine are effective in curing this disease. Apart from this the occurrences have

been reduced through the importation of vaccinated juveniles41.

105. Vibrosis affects the Sea Bass stock and can lead to a loss of between 1 and 10 per cent

of the total stock. All Sea Bass juveniles are vaccinated prior to importation reducing

the chances of outbreaks of this disease42.

106. The Winter Disease Syndrome affects Sea Bream leading to severe swelling of the

abdomen. Improvements in the feed and industry in general have resulted in the disease

becoming practically obsolete43.

107. Juveniles are also vulnerable to protozoan parasites like Ichthyobodo. Another common

condition is Imphocystis which can lead to a mortality of 3 to 5 percent44.

108. The worst health issue faced by the industry was the Viral Nervous Necrosis outbreak

in 1996. The outbreak was the result of the importation of infected juvenile Sea Bass

from Italy. Mortality was significant and reached the 30 - 50 percent of the stock. This

led to producers incurring great financial losses and a shift to the production of Sea

Bream which was unaffected by this viral disease. To date only P2M produces Sea Bass

in Malta. VNN outbreaks still have a significant impact, killing 10 to 40 percent of total

stock due to the fact that there is no treatment or vaccine against such diseases.

109. New emergent diseases following the introduction of amberjack could also be identified.

Crytocaryon irritans was a serious problem in the experimental hatchery yet this problem

was addressed through improved water filtration systems. Another dangerous disease

that can spread rapidly and lead to significant mortalities in the amberjack stock is the

Zeuxapta seriolae. Treatment of the disease should be rapid and Praziquantal can be

used for this scope.

110. Blue fin tuna hatcheries are still in their initial phases; however, until now no health

issues have emerged in this sector. This can be one promising aspect of the

development of a tuna closed cycle production system.

111. Locally, fish health is controlled through the ‘Animal Health Requirement for

Aquaculture Animals and Products thereof, and on the Prevention and Control of

Certain Diseases in Aquatic Animals Rules, 2009’. This act includes the permitting

process for aquaculture production businesses and processing establishments. This

includes compliance to various aspects like inspections and audits. The fish farm

41 An aquaculture strategy for Malta: Preparatory study and recommendations prepared for the Ministry of Resources and

Rural Affairs, Government of Malta – Final draft report: March 2012. 42 Ibid. 43 Ibid. 44 Ibid.

47

operators are obliged to keep extensive records on all the processes (both inputs and

outputs) to ensure traceability of all products. Maintaining hygienic standards is crucial

too. The Fish & Farming Regulation and Control Division (FFRC) of the MRRA is

responsible to see that any imported live fish stock is in a healthy state. At present,

however, there are no routine checks on fish health in the existing aquaculture sites45.

WATER & MARINE SEDIMEMTS

112. Coastal water quality is monitored regularly by MEPA and the Public Health

Department. Water quality is regulated through the Bathing Water Directive, the UN

Barcelona Convention and the Water Framework Directive.

113. Over the years, water quality has improved significantly due to the fact that now all

sewage waste is treated prior to disposal into the sea.

114. In 2008, 99 percent of Malta’s water was compliant with EU standards. The non

compliant bathing sites fell from 5 percent in 2007 to 1 percent in 200846, see Figure

4.13.

115. In 2009, Malta began assessing the water quality of its sites in line with the EU Bathing Water Directive. The classification system of the Directive classifies water quality status

as excellent, good, sufficient and poor quality or temporarily closed. The Barcelona

Convention parameters include very good, good, fair or poor water quality. In 2011,

97.7% of coastal bathing waters qualified as being of excellent quality, 1.1% as good

quality and another 1.1% as sufficient quality, see Figure 4.14. In 2011, all 87 bathing

sites were classified as excellent47.

45 An aquaculture strategy for Malta: Preparatory study and recommendations prepared for the Ministry of Resources and

Rural Affairs, Government of Malta – Final draft report: March 2012. 46 Coastal and Marine Environment Sub-report 6, State of the Environment Report 2008 (2010). 47 The Environment Report Indicators 2010-2011 (2012)

48

Figure 4.13: Classification of bathing water sites according to EU Bathing

Water Quality Directive

Source: Department of Environmental Health

49

Figure 4.14: Bathing water quality from 2005 to 2009

Source: Environmental Health Department, The Environment Report Indicators 2010-2011 (2012)

116. Data related to historical trends of water quality at Sea Bream and Sea Bass fish farms is

not a reliable indicator because of lack of reporting of observed patterns over time.

Effect of Aquaculture Activities

117. Sources of pollution from aquaculture may include organic contaminants left over from

fish feed and fish excreta, which give rise to enhanced nutrient levels in the area,

increased Biological Oxygen Demand (BOD), increased sedimentation rates of organic

particulates, and reduced water transparency (see Figure 4.15).

118. Environmental monitoring for Sea Bass and Sea Bream farms started around 1994 with

the publication of the policy guidance on fish farms. However, monitoring was sporadic

and no data on currents has been collected thus making data availability for these sites

poor (Holmer, 2008).

119. Since all Sea Bass and Sea Bream farms, which have to date not been subject to fixed

carrying capacity levels, are located in an area close to Posidonia oceanica meadows,

monitoring surveys centred on assessing the nature and health of these meadows.

Overall from these surveys it was noted that the seagrass below Sea Bass and Sea Bream

50

cages underwent severe regression or else was completely destroyed. Studies showed

that aquaculture can leave an effect on seagrass up to 200m distance from the cages48.

120. Dimech et al (2002)49 assessed the impact of fish farm cages on decapods, mollusc and

echinoderm fauna associated with Posidonia oceanica meadows. Whilst waste generated

from fish farms can severely alter the structure of Posidonia oceanica meadows in their

vicinity (e.g. through increased turbidity that reduces the amount of light available for photosynthesis or through increased growth of epiphytes on their leaves that further

reduces the surface area available for photosynthesis), nutrient enrichment could

increase productivity in other parts of the same meadow leading to increased

biodiversity.

121. There are three distinct zones that could be identified in the vicinity of the farm.

(i) Zone 1, comprising the area occupied by the cages and an additional

band of 30 m around the farm. The macrofaunal assemblages present

within this zone were characterised by a low species richness and the

dominant trophic groups were grazers and deposit feeders (decapods,

polyplacophorans and gastropods), which exploit the abundant epiphytes

and deposited organic matter present close to the cages.

(ii) Zone 2, comprising the area located at a distance of between 30 m

and 90 m from the farm. This zone supported macrofaunal assemblages

that had the highest species richness and abundance, while the fauna was

dominated by the same trophic groups in Zone 1.

(iii) Zone 3, comprising the area located at distances exceeding 90 m from

the farm. This zone supported macrofaunal assemblages having species

richness and abundance values that were intermediate between those

recorded from Zones 1 and 2, and in which the dominant trophic groups

comprised grazers, deposit feeders, suspension-feeders (mostly bivalves) and predators.

122. Later monitoring carried out at P2M’s farm off Mistra Bay (Ecoserv, 200550) again

recorded an adverse effect from aquaculture activities on the P. oceanica meadows

48 Holmer M., Hansen P. K., Karakassis I., Borg J. A. & Schembri P. J. (2008) “Monitoring of Environmental Impacts

of Marine Aquaculture”. In: Holmer M., Black K., Duarte C., Marba N., & Karakassis I. (editors) Aquaculture in

the Ecosystem; pp. 47-85. Heidelberg, Germany: Springer; 326pp. 49 Dimech M., Borg J., Schembri P.J. 2002. Changes in the Structure of a Posidonia oceanica Meadow and in the

Diversity of Associated Decapod, Mollusc and Echinoderm Assemblages, Resulting from Inputs of Waste from a Marine

Fish Farm (Malta, Central Mediterranean). 71(3) Bulletin of Marine Science. 50 Ecoserv. 2005. Marine Benthic Surveys at Pisciculture Marine de Malte Ltd’s Fish Farm Site Off Mistra Bay, made

in March-May 2005.

51

present in the general area of St Paul’s Bay where the farm is located. The 2005

monitoring report compares the results obtained from monitoring carried out in the

same area in 1995 and notes that the same pattern of distribution of benthic

assemblages was identified and that the observed effects of the aquaculture activities on

the biological and physical features of the seabed in the vicinity of the fish farm were also

similar. However, the results of the 2005 survey indicated that the adverse impact of

the fish farm on the marine benthos of the area had extended further from the farm

since the 1994 survey.

123. Monitoring of tuna farms has been carried out in Malta since 2000. The monitoring data

available from the initial studies carried out on the first tuna penning farms that were

established in Malta generally revealed that whilst there seems to be limited impact on

the water column, a significant impact on the benthos was recorded. Axiak (2002)51

carried out a monitoring exercise between June 2001 and January 2002 at a tuna farm

off the NE coast of Malta. The monitoring results indicated that excessive organic

material was reaching the sediments as a result of oversupply of feed, leading to acute

anoxic conditions thus reducing the quality of the sediments that in turn results in an

alteration of the benthic communities. The monitoring results also revealed that when

the farm was fallow, although the carbon load in the sediments decreased, the reducing

conditions did not improve, i.e. the sediment remained anoxic. These initial results, for

instance in relation to the practice of overfeeding, reflect the fact that tuna penning was

still a relatively new practice at this time and problems with management at this stage

were mainly related to the fact that the industry was young in Malta.

124. Later monitoring at other sites, such as in the tuna penning cages located south-east of

Malta, included indicators such as bio-indicators (e.g. crustaceans and polychaetes),

species richness and abundance in order to assess the environmental impact from the

farm. In 200552, results showed a diminished impact from previous monitoring reports

at the Fish & Fish site following implementation of better farm management practices.

Other results indicate increased nutrient enrichment, probably as a result of the farms;

however, the monitoring reports conclude that this is not to a substantial degree

(Ecoserv, 201053). Although results indicate no appreciable alteration in water quality in

the vicinity of tuna farms off the south-east coast, significant differences in some of the

monitored parameters (e.g. levels of ammonia, Ecoserv, 200754) were detected between

51 Axiak V. 2002. Tuna Penning Farm NE Malta (Off St. Paul’s Bay) Marine Environmental Monitoring Programme.

www.mepa.org.mt. 52 Ecoserv. Fish & Fish Ltd Tuna Penning Project. Benthic Monitoring Programme – 5th monitoring session, 2005. 53 Ecoserv. 2010. Fish & Fish Ltd and Malta Fish Farming Limited Tuna Penning Activities. Report of a Water

Quality Survey at Sites used by Fish & Fish Ltd and Malta Fish Farming Limited for Tuna Penning and Control

Sites off Munxar/Il-Hofriet (southeast Malta). 54 EcoServ. 2007. Water Quality Surveys at Fish & Fish Ltd’s Tuna Penning Site and Control Sites off the Il-

Hofriet/Delimara Coast, South-East Malta (August & September 2007 reports).

52

monitoring stations, which indicated a degree of spatial variation, it was considered

difficult to pinpoint a source for the observed differences.

125. In conclusion, therefore, once changes were made to the management of tuna farms,

following the initial monitoring results, the impact from the tuna farms on the benthos

was diminished as operators became more familiar with the practice and improved their

management practices, which included, for instance, avoiding overfeeding.

126. Sediment parameter changes were subsequently recorded by Borg and Schembri

between 2004 and 200555. In most cases the significant changes in sediment parameters

were detected in samples collected adjacent to the tuna pens. Benthic biodiversity was

also compromised in the vicinity of the cages. Vita & Marin (2007)56 also reported

detectable impact only under cages, although an environmental gradient of stressed

macrofaunal assemblages was identified. The benthic surveys revealed that a high impact

was located within 5m of the cages with a transitional radius of 35m characterised by

opportunistic species. For a further 180 - 220m radius, moderately stressed

assemblages were recorded. Beyond 220m, no impact was observed.

127. The establishment of an Aquaculture Zone, approximately 6km off the south-east coast

of Malta was intended to help in reducing negative environmental impacts in coastal

waters as well as increase the capacity of individual farms and allow for diversification.

Monitoring in this area commenced in June 2006.

128. Overall, monitoring of tuna penning sites located 1km offshore has shown that a main

negative impact is the accumulation of feed fish on the seabed beneath and close to the

cages resulting in changes to the physical and biological characteristics (e.g.

disappearance of certain megafaunal species like Spatangus purpureus and Antedon

mediterranea and the appearance of high population densities of detritus-feeding and

scavenging macroinvertebrates).

129. Once the area is cleared from this accumulation either by decomposition or currents,

the seabed starts to recover slowly as evidenced from the reappearance of megafaunal

species.

55 Adi Associates Environmental Consultants Ltd, 2005. Environmental Impact Statement for PA0087/04

Development of an Aquaculture Zone south-east of Malta off Zonqor Point, Marsaskala. 56 Vita R., Marin A. 2007. Environmental Impact of Capture-Based Bluefin Tuna Aquaculture on Benthic Communities in

the Western Mediterranean. Vol. 38, No. 4. pp331-339. Aquaculture Research.

53

Figure 4.15: Sources and fate of nutrients released from tuna penning

Source: Fernandes, 200357

LANDSCAPE

130. In 2002, MEPA published a Landscape Assessment Study. The Study identifies that the

coastal profile contributes to the scenic qualities of a landscape. The Landscape Study

describes the presence of fish farms as obtrusive, introducing a permanent change to the

Maltese seascape. Moreover, in certain areas, such as Mellieha, land-based support for

fish farms has contributed to dereliction of the land, although this cannot be attributed

to aquaculture per se but to bad management practices by the operators in question.

The Study does identify however, that the visual footprint of these facilities is relatively

limited.

57 Fernandes, M. (2003). Tuna Brief. Southern Bluefin Tuna Aquaculture Subprogram Newsletter. South

Australian Research and Development Institute.

54

CULTURAL HERITAGE

131. It is acknowledged that although Malta’s heritage is varied and rich, it requires immediate

attention and significant investment58. A Draft National Strategy for the Cultural

Heritage was published for consultation in May 2012 and the Tourism Policy for the

Maltese Islands was published in July 2012.

132. Buildings, monuments, and sites (including marine sites) are protected through the

Cultural Heritage Act and the Development Planning Act. The latter allows MEPA to

schedule culturally important buildings and sites. Structure Plan policy MCO 2 states

that as far as possible, designated Marine Conservation Areas will include archaeological

sites and structures within their boundaries and access to these sites and wrecks will be

strictly regulated. The MEPA Scheduling List contains 1,720 sites and monuments, of

which 1,284 are of architectural importance, 263 are of archaeological importance, and

173 are of ecological importance. Of these, 2 sites have been scheduled for their

marine archaeology, namely Salina Bay and a site at Birzebbuga. The Antiquities List

compiled in 1946/47 contains 2,000 sites of historical and antiquarian significance from before the 1900s. In addition, three sites, namely the city of Valletta, Hal Saflieni

Hypogeum, and the megalithic temples59 are UNESCO World Heritage Sites.

HUMAN HEALTH

133. Fish is considered a healthy food since it is a good source of vitamins and has high

quality proteins. Fish are also rich in omega 3 fatty acid, which is beneficial for human

health. In the last years due to the problem created through overfishing, the market has

become dependent on the fish produced in fish farms. Forty per cent of the consumed

fish worldwide comes from aquaculture60.

134. In order to combat different diseases that can affect the caged fish, aquaculture

producers make use of different veterinary drugs and chemicals. Apart from these

‘chemical hazards’ there can also be the problem of ‘post-harvest handling’, which can

lead to microbiological hazards (this risk also applies to wild fish). Other environmental

hazards include the accumulation of polychlorinated biphenyls (PCBs) and dioxins.

These hazards are passed from the feeds and water to the fish and eventually to humans.

Risks from the various substances include the bacteria acquiring resistance to antibiotics

58 Malta Government, 2006, A Sustainable Development Strategy for the Maltese Islands 2006 -2016, Third draft,

National Commission for Sustainable Development. 59 The Megalithic Temples of Malta are not one but five sites: Ggantija in Gozo, and Hagar Qim, Mnajdra, Ta’

Hagrat, and Skorba in Malta. 60 Cole, D.W., Cole, R., Gaydos, S.J., Gray, J. Hyland, G., Jacques, M.L., Powell-Dunford, N., Sawhney, C., Au,

W.W. (2009) ‘Aquaculture: Environmental, toxicological, and health issues’, in International Journal of Hygiene

and Environmental Health, 369-377.

55

and the bioaccumulation of toxins and other dangerous substances 61. Cole et al (2009)

specify that the main sources of contamination are from bioaccumulation from the feeds

and locating fish farms in contaminated areas.

135. Studies on trout, salmon and sea bass have indicated higher levels of omega 3 and omega

6 fatty acids in farmed fish when compared to the conventional ones. These acids are

very important for cardiovascular health and people with high triglyceride levels62. However, farmed fish can have higher concentrations of natural and man-made toxic

substances. One source which has raised concern is the use of antibiotic medication.

Antibiotics can maintain the fish health in the short term but can be carcinogenic and

may also lead to antibiotic resistance in the consumers63.

136. The Hazard Analysis and Critical Control Points (HACCP) program has been

implemented in the US and the EU and aims at ensuring that food products are safe for

consumption by assessing the food production process and placing the responsibility

upon the aquaculture sector. This program would be ideal to implement on a global

level in order to contribute to food safety64.

137. There is currently no local study showing the impact of the consumption of aquaculture

products on human health.

MATERIAL ASSETS AND POPULATION

138. Aquaculture was first introduced in Malta in 1988, following the creation of the National

Aquaculture Centre (NAC65) at Fort San Lucjan, Marsaxlokk. Initially, the aim of the

Centre was to develop fish farming as a new industrial activity in Malta (MRAE, 200566).

The Centre started operations by focusing on the hatching and growing of Tilapia,

Oreochromis spilurus and Oreochromis niloticus x O. mossambicus.

139. In addition to the production of sea bass (Dicentrarchus labrax) and sea bream (Sparus

aurata) at the commercial farms, the NAC also undertook trials on the culture of dolphin fish (Coryphaena hippurus), amberjack (Seriola dumerilii), and eel (Anguilla anguilla).

Production fell post-1998 because of reduced market prices and the introduction of

61 Lupin, H.M. (2009) ‘Human health aspects of drug and chemical use in aquaculture’, in Options Méditerranéennes,

A / no. 86. 62 Cole, D.W., Cole, R., Gaydos, S.J., Gray, J. Hyland, G., Jacques, M.L., Powell-Dunford, N., Sawhney, C., Au,

W.W. (2009) ‘Aquaculture: Environmental, toxicological, and health issues’, in International Journal of Hygiene

and Environmental Health, 369-377. 63 Ibid. 64 Ibid. 65 The NAC was re-founded in 2001 as the Malta Centre for Fisheries Science, with a focus on the wider fisheries

science rather than just aquaculture. 66 Ministry for Rural Affairs and the Environment, 2005. Official website accessed at

http://www.maltafisheries.gov.mt/mcfs_aquaculture_history.htm

56

levies for the export of the produce to EU countries. By 2001 the harvest had dropped

to around 1,300 tonnes (MRAE, 2005).

140. In 1999, interest in tuna penning started to increase and the first farm was established in

2000. Three of the former sea bass/sea bream sites were partly converted for use as

tuna penning sites, in the process moving to deeper waters.

141. Today, there are six active commercial aquaculture operations, which make use of ten

marine production sites (two are located in the Aquaculture Zone). Four of these

companies have ancillary land base facilities. The MARC has its own cage site in

Marsaxlokk Bay, which is currently used by one of the commercial operators as a

nursery and as a trial site for the development of new species. One site approved for

use as a tuna penning farm was never brought into use.

142. The penning and fattening of Bluefin tuna Thunnus thynnus around the Maltese Islands

started in 2000 when AJD Tuna Ltd commenced operations with the production of 330

tonnes (MRAE, 2005). Following this initial success, five other permits were issued

between 2001 and 2002. This increased the total approved annual production of tuna

from the farms to 3,575 tonnes, see Table 4.4 and Figure 4.16.

Table 4.4: Production (volume and value) of main cultured species (Source:

MRAE, 2011)

Species produced

2010

Quantity Produced (tonnes) Value million (EUR)

European Sea Bass

(Dicentrarchus labrax) 102 0.8

Gilthead Sea Bream

(Sparus aurata) 1,755 7.1

Atlantic bluefin tuna

(Thunnus thynnus

thynnus)*

4,955 73.7

* Latest officially released value available for Atlantic bluefin tuna is 2003 production.

57

Figure 4.16: Reported aquaculture production in Malta (from 1950) (Source:

FAO Fishery Statistic)

143. In December 2005, MEPA approved an application by the then Fisheries Conservation

and Control Division of the MRAE for the establishment of an Aquaculture Zone

approximately 6 km to the south-east of Malta (off Zonqor Point, Marsaskala). This

Zone, which started operation in July 2006, has a maximum size of 3km x 1.5km at the

sea surface and can eventually contain a maximum of 6,000 tonnes of tuna biomass,

equivalent to around 70% of the total Mediterranean quota. In 2006, the Zone

contained only two farms; additional farms could be set up in future years as the Zone

develops and the inshore farms are relocated.

144. The Ministry for Resources and Rural Affairs is considering the development of a second

aquaculture zone off the north-east coast of Malta. The proposed area is in the same

depth of water as the south-east aquaculture zone.

145. The aquaculture sector directly employs 197 full-time equivalent jobs (FTE). Another

767 FTE jobs are related and result from the industry’s economic impact, for example

wholesalers, retailers, transport, etc (Applied Economics Consulting Ltd., 2009).

58

Table 4.5 Fish Farming operations in Malta

Operator Location Licensed capacity (tonnes) Notes

Malta Tuna

Trading Ltd &

F&F Ltd

Off Il-Hofra z-

Zghira, Marsaxlokk

1,200 (tuna) [MTT Ltd]

300 (sea bass / sea bream) [F&F]

P2M (Site A): Mistra Bay 1,100

(combined total for three sites)

P2M (Site B) St Paul’s Islands

P2M (Site C) Mellieha Bay

MML

(now AJD

Tuna Ltd)

South Comino

Channel

150 (sea bream) &

350 (tuna)

Not operational

NAC Marsaxlokk Bay 100 Part of site used by MFF

Ltd partly to develop

new species for farming

MFF Ltd &

Melita Tuna

Ltd

Off Munxar Reef

(Marsaskala)

350 (tuna) [MT Ltd]

150 (sea bream) [MFF]

AJD Tuna Ltd Sikka l-Bajda

(St Paul’s Bay)

1,500 (tuna)

Mediterranean

Tuna Ltd

Benghajsa 175 (tuna) Not built

MareBlu Ltd Aquaculture Zone,

SE Malta

1,500 (tuna)

Ta’ Mattew Aquaculture Zone,

SE Malta

1,500 (tuna)

146. To date, there are no commercial marine hatcheries in Malta and sea bass and sea

bream fingerlings are imported from hatcheries in other EU Member States. Laboratory

facilities at the MARC provide a small marine hatchery that is used for applied research

experiments.

59

Table 4.5: Production of sea bass, sea bream and tuna by aquaculture units

(2006)

(Source: MEPA, The Environment Report 2008, Sub-report 6: Coastal and Marine Environment, 2010.)

Note: The relocation of two more fish farms, at is-Sikka l-Bajda off St Paul's Bay and that south of Comino

Channel off Kemmuna, Ghajnsielem is being managed by the Fisheries Department.

Location Fish

species Sea Bass /

Tuna

produced Total Area sq

farmed Sea

Bream

in 2006 produced km

produced

in

(tonnes) (tonnes)

2006

(tonnes)

off St.Paul's sea 639 N/A 639 22,145

Islands bass/bream

Mellieha Bay sea 283 N/A 283 99,520

bass/bream

Mistra sea 14 N/A 14 932

bass/bream

off San Lucjan sea

bass/bream

and

1,047 5,215 6,262 47,520

amberjack

off Sikka l-Bajda, tuna N/A 3,000 3,000 0.19

off St Paul's Bay

Munxar Reef off tuna and sea N/A 1,500 1,500 0.48

Xrobb l-Ghagin, bream

l/o

Marsaxlokk93

South Comino tuna and sea N/A 1,500 1,500 0.05

Channel, off bream

Kemmuna,

Ghajnsielem

Il-Hofra z-

Zghira, tuna and sea 300 1,200 1,500 0.52

Marsaxlokk bass/bream

South East of tuna N/A 3,000 3,000 9.00

Malta 6km away

from shore, off

Xrobb l-Ghagin,

l/o Marsaxlokk

Total 2,283 15,415 17,698 170,128

60

EVOLUTION OF THE BASELINE WITHOUT THE STRATEGY

147. The SEA Regulations require a description of the relevant aspects of the current state of

the environment and the likely evolution thereof without the implementation of the

strategy document with a particular emphasis on the future developments arising from

other relevant plans and programmes.

148. The description of the likely future trends should the Strategy not be implemented is

further constrained by uncertainties including availability of data on future economic

development, technological progress or advancements in regulatory frameworks that

collectively influence future trends. The following assessment, therefore, includes

certain assumptions.

149. This analysis focuses on the main environmental issues that have been identified and

described above. It includes a description of the past and current trends from data

available from existing monitoring systems or through expert judgement (in cases where

data are lacking). It also outlines the likely evolution of these trends, if the Strategy

were not implemented.

150. It is noted that major projects will be required to undergo Environmental Impact

Assessment as legislated by the Environmental Impact Assessment Regulations, 2007

(LN 114 of 2007).

Emissions to air and Climate Change

151. The main emissions to air of concern from the aquaculture industry are odour

emissions. These are largely linked to the poor practices applied in the operation and

management of the various sites and limited enforcement. Given that permit conditions

are in place to require the relocation of tuna farms further offshore to established

aquaculture zones, it is unlikely that the Strategy will influence this aspect to any great

extent other than providing a framework within which data can be gathered holistically

from across all sites.

152. The Strategy will not affect climate change mitigation although it may contribute to

some extent in terms of climate change adaptation; especially if species which are/may

be negatively impacted by an increase in temperature are farmed through closed-cycles.

The Strategy provides a framework and policy direction towards diversification. Due to

spatial constraints, it is unlikely that the market on its own would continue to drive

towards diversification in any case.

Biodiversity

153. Following the current baseline, feeding of tuna will be based on baitfish. Tuna ranching

can therefore result in pressures on baitfish populations and secondary effects resulting

from this. The Strategy promotes the development and testing of alternative tuna feeds,

which would reduce the reliance on baitfish. In the case of capture-based tuna farming,

61

it is very difficult to wean wild caught Bluefin tuna to pelleted feed. The Strategy aims at

diversification and the move to increase production of CCS species that will depend on

pelleted feeds; including future Bluefin tuna that will be hatched through marine

hatcheries. The use of such feeds is expected to substantially reduce the impact of

aquaculture on the environment as well as odours and oils.

154. In terms of impact on the seabed, the Strategy is calling for the relocation of tuna farms to beyond the 1 nautical mile limit; however, legal provisions for this are already in place

and therefore the Strategy itself, although providing a framework, is not the driving

force behind the implementation of such measures. The Strategy does, however,

suggest a number of production scenarios and the selection and implementation of the

preferred option will affect marine biodiversity both in terms of intensity of production

and sites selected. The Strategy is therefore crucial in ensuring a holistic approach in

determining how the industry will grow and the significance of the resultant impacts on

biodiversity.

155. The Strategy recommends that instruments to tackle the impact of escapees, alien

species and GMOs are developed.

Water quality & marine sediments

156. Sources of pollution from aquaculture activities may reduce water transparencies,

enhance nutrient levels in the area, increase BOD, and increase sedimentation rates of

organic particles. The current trend can also result in a nuisance to both locals and

tourists. The Strategy will address this concern through the restriction of feeding of

baitfish to tuna cages during onshore wind conditions in the summer months unless

another alternative is found. The Strategy also recommends a review of tuna offal

disposal as well as the establishment of fixed carrying capacities on each site. In

addition, the Strategy recommends that tuna farms should be located at a minimum

distance of 1nm from the shore and in at least 50m water depth. In addition, the

Strategy proposes to use sites from which tuna are relocated offshore for the

production of CCS and proposes that in order to counteract the negative views of

aquaculture, it is necessary to demonstrate compliance with both statutory operating

conditions and a publicly available COGP; in conjunction with specified improved

monitoring systems, mechanisms for review and refinement of carrying capacity models,

and agreed carrying capacity guidelines.

157. Location of tuna farms at least 1nm from shore and within at least 50m water depth is a

concept that is already considered within existing policy. Over and above these

requirements, the Strategy promotes compliance with statutory conditions,

development of a COGP, improved monitoring systems, adherence to carrying capacity,

etc, which, when implemented and enforced is expected to reduce adverse conditions

resulting from existing and future farms.

62

Landscape

158. A Landscape Assessment Study conducted by MEPA has shown that the visible footprint

of developments related to aquaculture is very limited. The Strategy calls for a hatchery;

its location will require consideration of potential landscape impacts amongst other

potential impacts.

Cultural Heritage

159. The impact of aquaculture on the cultural heritage is not considered to be significant and

in the absence of the Strategy the impact would remain unchanged. Any projects

developed within the framework of the Strategy would be required to consider

potential impacts on cultural heritage, depending on the location of potential sites.

Human Health

160. Currently the keeping of records and monitoring are legal obligations yet there are no

routine checks on fish health in the existing aquaculture sites. Malta’s Aquaculture

sector has been affected by a number of Sea bream and Sea Bass diseases. Fish health is

now controlled through the ‘Animal Health Requirement for Aquaculture Animals and

Products thereof, and on the Prevention and Control of Certain Diseases in Aquatic

Animals Rules, 2009’. However, there are no routine checks on fish health in the

existing aquaculture sites. This factor might keep the industry vulnerable to the

possibility of diseases which can result in the loss of a large percentage of the fish stock;

for example VNN can result in a mortality rate of between 10 and 40% of the stock.

The Strategy aims at limiting this vulnerability even further through Area Management

Agreements (AMAs) between all operators in a zone or area. It is also recommended

that a contingency plan in case of a notifiable or other serious disease is prepared by the

government or the industry. The Strategy also suggested that the establishment of a

better diagnostic capability like the one that used to be provided by NAC, should be

assessed. The Strategy also recommends that a national contingency plan be devised to

address the risk of new, emergent diseases, based on the criteria outlined in current EU-

based legislation. In the absence of the Strategy these issues may take a while to

implement. The Strategy also recommends the preparation of a COGP to enhance

quality through better management.

Material Assets and Population

161. Tuna production levels have gone down from the 2007 levels. The total gross value

added (GVA) for tuna went down from €53m in 2007 to negative GVA in 2008 and

€18m in 2009. Tuna penning is affected by various factors, including storms, pricing,

exchange rates, etc.

162. In the absence of the Strategy it is unlikely that alternative species will increase their

share in total production. The Strategy will result in a 50% amberjack and 50% Sea

Bream (and others) production in the CCS sector. The new local hatchery would also

result in a high production of 10,000 p.a. and a hatchery producing 20 million juveniles

63

p.a. that is a total GVA of €46m supporting 464 direct employees and 442 persons in

indirect / induced employment.

163. The Strategy will also result in high production in the tuna sector, which may total to a

GVA of €73m and support direct employment of 233 persons and indirect / induced

employment of 464 persons.

164. R&D is currently mainly limited to the public and academic sector. The Strategy

recommends the PPP model in order to fund the sector and develop it further. The

Strategy suggests collaboration between the MARC and the University of Malta and

other institutions. The Strategy also provides for the development of human resources

through a consultative forum which will formulate formal vocational training

programmes for Maltese aquaculture.

165. In the absence of the Strategy, there is likely to be little marketing of the sector as a

whole. The Strategy points out the important role that marketing and marketing studies

can play in better understanding the species that should be produced how the industry

should develop in order to maintain competitiveness and realise the best returns.

166. The Strategy also suggests a set of actions (like the setting up of a COGP) to ensure

good management practices in the industry resulting in better competitiveness and a

better image of the industry.

167. Chapter 6 assesses the do nothing option against the Strategy alternatives, see Table

6.2 for a summary.

64

CHAPTER 5: SEA FRAMEWORK

INTRODUCTION

168. This Chapter describes the identification of the objectives against which the Strategy will

be assessed in the SEA process.

169. Although the SEA Directive does not specifically require the use of objectives or

indicators in SEA, they are a recognised way in which environmental effects can be

described, analysed, and compared. SEA objectives encompass the relevant national and

EU environmental priorities that can be inferred from a number of relevant national

documents as outlined below. The programme is assessed in light of the SEA objectives.

The programme’s performance against the SEA objectives is generally measured by

indicators. The SEA objectives are distinctly different from the Strategy objectives,

though the two influence each other and may overlap. To fulfil the requirements of the

SEA Directive and the SEA Regulations, 2005, the SEA objectives must cover

biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors,

material assets, cultural heritage, landscape, and interrelationships between them where

these are relevant to the sector being addressed by the plan or programme. Those

objectives relevant to the Strategy are described in this chapter.

170. In developing appropriate objectives and indicators the following documents have been

consulted:

The GRDP Handbook on SEA for Cohesion Policy 2007- 2013;

The Commission’s “Implementation of Directive 2001/42 on the Assessment of

the Effects of Certain Plans and Programmes on the Environment”;

A Practical Guide to the Implementation of the SEA Directive, ODPM;

The SEA Directive 2001/42/EC;

SEA Regulations, 2005;

The Sustainable Development Strategy for the Maltese Islands, 2006-2013;

Malta’s State of the Environment Report, 2005;

State of the Environment Indicators, 2006; and

Malta’s State of the Environment Report, 2008.

SEA OBJECTIVES & INDICATORS

171. Table 5.1 defines the set of objectives relating to the environmental issues identified in

Chapter 4, in support of which, relevant assessment criteria and possible data sources

65

have also been identified.

172. The SEA indicators are measurements of trends over time. Changes in the indicators

show whether the implementation of the Strategy would be or has been successful in

improving the environment. It is to be noted, however, that changes in the indicators

could be the result of factors outside the influence of the Strategy. Hence, the SEA

process is both uncertain and constrained.

173. The proposed indicators will not all be relevant to all the recommendations. In the

assessment, indicators relevant to particular measures were selected from the list

presented in Table 5.167.

67 Some of the indicators listed in Table 5.1 have been modified from those presented in the Scoping Report

66

Table 5.1: SEA Environmental Objectives & Criteria for Assessing Impacts

Issue SEA Objective

Criteria

Will this measure…

SEA Indicator Data source

Biodiversity,

Flora & Fauna

Maintain biodiversity

(including terrestrial

and marine)

Avoid introduction of

non-indigenous

species into the

natural environment

Populations of fish

species taken from the

wild (including species

used for bait fish) are

within safe biological

limits

Avoid negative effects

on wild fish

populations

Help to maintain or enhance the

conservation of designated areas

(under both the Development

Planning Act, and the

Environment Protection Act)?

Negatively affect protected

species and habitats?

Risk introduction of non-

indigenous species into the

marine environment?

Result in unsustainable

exploitation of wild stocks?

Impact negatively wild fish

populations (e.g. through spread

of disease)?

Monitoring results from impacts

on the sea bed

Number of permitted sites in

protected areas

Records of non-indigenous

species in the natural

environment that may have been

introduced as a result of

aquaculture activities

Number of infringements against

Illegal & Unreported and

Unregulated (IUU) Fishing

Recorded disease outbreaks in

wild populations

Environmental monitoring

through Environmental Impact

Assessment (EIA), Appropriate

Assessment (AA), or other

regulatory requirements as

relevant.

Malta Centre for Fisheries

Science (MCFS)/MARC

Malta Environment and Planning

Authority (MEPA)

Human health Ensure aquaculture

products are within

the legal safety

requirements

(antibiotic resistance,

possible contamination

and bioaccumulation

of chemicals, microbial

agents and toxins) for

human consumption

Ensure bathing water

quality does not

deteriorate as a result

of aquaculture

operations

Ensure safe consumption of

aquaculture products?

Ensure that bathing water

quality does not deteriorate as a

result of aquaculture operations?

Analyses and test results as

required by legislation /

operational permit requirements

Bathing water quality results

Malta Competition and

Consumer Affairs Authority

(MCCAA), Malta Centre for

Fisheries Science/MARC

Water Minimises pollution on Help to minimise discharges to Quality of the marine MEPA, potential permit

requirements (i.e. aquaculture

67

Issue SEA Objective

Criteria



the marine

environment

Avoids contribution to

eutrophication

Sea-floor integrity is

maintained

Avoids generation of

litter

Minimise pollution on

groundwater from

activities directly

arising from the

aquaculture sector

Avoids deterioration

of water bodies

water?

Avoid nutrient concentration

and loading?

Avoid changes to the seabed

that may affect the integrity of

the benthos habitat?

Ensure good management

practices that avoid litter

generation?

Help to maintain and enhance

Malta’s groundwater, inland

surface waters and coastal

waters?

environment including the

benthos under cages and in the

vicinity of aquaculture operations

in accordance with permit

conditions

Nutrient concentration and

loading

Aquaculture originating marine

litter in the water column

Ingested marine litter, originating

from aquaculture activities, by

indicator species (e.g. Caretta

caretta)


litter collected from the seabed

and from beaches during cleaning

originating from aquaculture

activities

Quality of groundwater in the

vicinity of land-based aquaculture

operations

Maintaining ecological status in

accordance with the Water

Framework Directive.

operators) , MTA (beach

cleaning), Department of

Veterinary services (carrying

out post mortems on

Loggerhead Turtles).

Emissions to air Ensure no odour

nuisance from

aquaculture

operations

Cause odour nuisance? Number of confirmed cases of

odour arising from aquaculture

activities

MEPA

Climatic factors

and climate

change

Contributes to climate

change adaptation

Contribute to climate change

adaptation?

Number of CCS in the Maltese

aquaculture sector

MARC

Soil/seabed Avoid

contamination/degrada

Help to maintain and conserve

marine sediments?

Contamination of marine

sediments at specific sites;

Environmental monitoring as

part of permit conditions i.e.

68

Issue SEA Objective

Criteria



tion of marine

sediments

Changes to marine sediments at

specific sites.

from farm operators, MEPA,

Malta Centre of

Fisheries/MARC.

Material assets

and Population

Ensure no conflict

between aquaculture

commercial activities

and other uses (e.g.

with tourism,

recreation, etc)

Sustainable waste

management

Be compatible with other uses

in the area?

Implement sustainable waste

management practices?

Number of confirmed cases of

conflicts related to aquaculture

activities


Environmental data collected

through operational permits

MEPA, aquaculture operators,

MARC

Cultural heritage Maintain the

conservation status of

cultural heritage sites /

areas with known

cultural /

archaeological remains

Help to preserve, enhance and

promote cultural heritage

including archaeological

heritage?

Avoid negative impacts on

cultural heritage

features/archaeology?

Number of operations located

away from cultural heritage sites /

areas or areas with known

cultural / archaeological remains

as a percentage of the total

number of operations

MEPA, Resources Management

Unit

Heritage Malta

Superintendent of Cultural

heritage

Landscape Maintain landscape

quality distinctiveness

Help to maintain landscape

quality distinctiveness?

Environmental Impact

Assessment results on landscape

assessment

MEPA

69

CHAPTER 6: ASSESSMENT OF ALTERNATIVES

174. As described in Chapter 2 the Aquaculture Strategy considers alternative

production capacity scenarios for Tuna and CCS. It also proposes sites for the

zoning of the additional capacity proposed. Figure 6.1 illustrates existing

production sites and proposed search areas as identified in the Strategy.

175. The Strategy identifies eight marine areas for potential use for aquaculture activities,

as shown in Figure 6.1. These are located on the eastern side of the Maltese

Islands. According to the Strategy, the west coast is unsuitable because of water

depth and exposure to prevailing winds.

176. Figure 6.2 illustrates most current uses in the marine environment around the

Maltese Islands. This map was developed as part of the Site Selection Exercise (SSE)

for the North Aquaculture Zone68 and therefore includes information related to the

criteria used during the site selection exercise process. The criteria developed

include technical, environmental, and social aspects that were identified as important

considerations when allocating the area for the Aquaculture Zone.

177. An Alternative Site Assessment and Project Description Statement for the Proposed

Aquaculture Zone, North East Malta have been submitted to MEPA.

178. Figure 6.2 was used to identify possible restrictions at each of the proposed areas

identified in the Strategy. Figure 6.3 shows the location of the proposed new sites

in relation to other potentially conflicting uses / areas, and including the 1nm

boundary and 50m depth. Table 6.1 summarises other uses within the proposed

sites.

Table 6.1: Proposed areas for aquaculture and other known uses within

these areas

Proposed new aquaculture site Characteristics of proposed site

Area 1 – North Aquaculture Zone Refer to paragraphs below

Area 2 – Extension to area east of St Paul’s

Islands Posidonia (matte)

MPA

Maerl bed

Parts within 1km from coastline

Within 500m of bunkering area

Less than 50m deep

Area 3 – Area just outside 1nm limit Rhodolith and maerl beds

Telecommunications cable

Firing practice area

Mostly 50-100m depth

MPA

Area 4 – North of St George’s Point, close to Posidonia (rock)

68 Adi Associates Environmental Consultants (2011) “Proposed Aquaculture Zone North East Malta -

Alternative Site Assessment and Project Description Statement”.

70

Proposed new aquaculture site Characteristics of proposed site

the Maddalena shoals Mostly <50m depth

Firing practice area

MPA

Edge is partly within 1km from coastline

Area 5 – South-east of the sewage treatment

plant at Xghajra Mostly <50m depth

Mostly within 1km of coastline

Within 500m of bunkering area

Posidonia

Area 6 – Off St Thomas Point Within 500m buffer around bunkering area

Area 7 – Area located approximately halfway

between the existing AZ and the coast Partly located within a 1km buffer around the

south-east AZ

Rhodolith association including maerl

Within 500m buffer of bunkering area

50-100m deep

Possible fairway for Malta Freeport Terminals

Area 8 – Inclusion of existing operations in the

south with an extended AZ area Bunkering Area and buffer area

Wreck conservation area

Within 1km from the coastline

Partly within <50m depth

Within 1km of existing aquaculture farm

179. With regards to Area 1, it should be noted that the proposed area for the North

Aquaculture Zone (Area 1 in Figure 6.1) has now been changed as a result of the

Site Selection Exercise and at present (July 2012) Area 1 is no longer under

consideration. The Aquaculture Strategy will be updated to reflect the latest

proposals following the outcome of the Site Selection Exercise (SSE) subject to

feedback from MEPA. Figure 6.4 illustrates the preferred area for the location of

the North AZ, following the SSE.

180. As shown in Figure 6.4, the preferred area for the location of the North AZ lies

east of Comino and Qala Point and just north of the Sikka l-Bajda reef (between 50m

and 100m depth of water). The site also lies within the Marine Protected Area

(MPA) recently designated by MEPA and extending from Reqqa Point off the north

coast of Gozo and St Julians in Malta. It is also noted, however, that all the existing

aquaculture units in the north of Malta already fall within this MPA and hence their

relocation to a more suitable location that would mitigate their current impacts

should be viewed positively. The MPA was mainly designated to afford protection to

the Posidonia oceanica meadows. The newly proposed site for the North AZ is

located outside the areas harbouring this Priority I habitat (as designated under the

Habitats Directive). However, the latest proposal largely overlies part of the maerl

bed located off the northeast coast of the Maltese Islands. The exact location of the

development of this AZ would depend on the findings of detailed benthic studies

aimed at characterising the seabed.

181. The SSE does identify potential conflicts with other uses and other constraints.

Yachting activity between Malta and Gozo takes place mainly to the immediate south.

Navigation by larger vessels is also common as they approach the Grand Harbour or

71

the bunkering zone at Is-Sikka l-Bajda. From an environmental protection point of

view, waters shallower than 50m support the important Posidonia oceanica meadows,

whereas maerl grounds are found in deeper waters mainly to the east of the site.

Seabirds nesting on L-Irdum tal-Madonna in Mellieha and on the east coast of Comino

are known to raft in waters offshore of these areas.

182. The SSE notes that there may be scope to consider areas further to the east, overlapping with the current bunkering zone at Is-Sikka l-Bajda, if this activity is

relocated (or curtailed) from this location, especially in view of the proposed

offshore wind farm at this location. Currently, an EIA is being carried out on the

proposed wind farm at is-Sikka l-Bajda.

183. As noted in Table 6.1, Area 2 is an extension to an existing tuna farm. The area is

also located within an MPA, and extends closer to shore. Since the Aquaculture

Policy recommends a minimum water depth of 50m for tuna penning69, given that the

area is located in shallower waters it is not considered appropriate for the creation

of an AZ for tuna; however it may be considered suitable for CCS.

184. Area 3 is relatively sizeable and the depth is satisfactory for aquaculture cages; it is

located within an MPA and an area where the seabed consists of maerl beds. Area 4

also lies within an MPA and is partially located within a Posidonia area (for which the

MPA was mainly designated). It is also located directly opposite the Armed Forces of

Malta's Pembroke Rifle Ranges; an application for a tuna farm in this location was

turned down in 2000 in view of conflicts with the ranges. Parts of Area 5 include

Posidonia meadows and the entire area is close to the coastline. A detailed site

selection exercise would be required to determine the suitability of such sites or

specific areas within these sites that would, for example, not be located on Posidonia

meadows.

185. Areas, 6, 7 and 8 are located in the vicinity of busy maritime traffic areas and close to

buffer areas for bunkering zones. Area 6 is located within the 1nm zone. Area 8 is

also located within a wreck conservation area, which is also popular for diving. A

detailed site selection exercise would be required to determine the suitability of such

sites or specific areas within these sites.

ALTERNATIVES ASSESSMENT

Assessing significance

186. Significance is assessed in accordance with the criteria listed in Schedule 4 of the SEA

Regulations, 2010. It is already well established in Environmental Impact Assessment

(EIA) literature: significance is a function of impact magnitude and the sensitivity of

69 The 50m minimum depth proposed in the Aquaculture Policy was ground breaking at the time that the Policy

was drawn up but experience over the past 6 years has shown that tuna farms (and possibly other

aquaculture units) can very easily be located in much deeper waters (even up to 100m depth) as long as the

anchoring system is properly designed.

72

receptors. Significance may be determined in a number of ways, including expert

judgements, the use of thresholds, reference to legislation, and consultation with

stakeholders. Although this SEA draws on each of these methods, expert judgement

and consultation predominate.

187. The assessment of significance is based on the probability of the impact occurring, on

the scale of the impact, its duration, reversibility, whether it has transboundary impacts, and the certainty of impact prediction. Table 6.2 describes the assessment

framework and the symbols used to denote the various types of impact.

188. The relevant SEA objectives identified in Chapter 5 are used to assess the

alternatives in accordance with the significance criteria described below.

Table 6.2: Assessment legend

Impact character Symbol Description of Impact

Probability VP Impact very likely to occur

P Impact likely to occur

Scale

++ Large positive impact

+ Positive impact

0 No impact

- Negative impact

-- Large negative impact

Direct / Indirect I Indirect impact

D Direct impact

Frequency / duration LT Long term

ST Short term

Transboundary dimension TR Possible transboundary effect

Uncertainty ? Impact uncertain

189. Three production capacity scenarios70 are presented in the Strategy as alternative

options. The three alternative production capacity scenarios were described in

Chapter 2. Figures 6.5 to 6.7 show the different sites proposed under the

different production capacity scenarios.

190. The assessment below is based on the maximum capacity production scenarios as

presented in the Strategy. When describing the possible scenarios, the Strategy

states:

Taking into account the assessment of sites and carrying capacity, three potential

production capacities are proposed which give guidance as to possible production

capacity assuming different site availability and usage.

191. When describing carrying capacity, this report and the Strategy are referring to

environmental carrying capacity, which, in general refers to the threshold limit of use

70 The Strategy makes a distinction between production capacities and production targets. The SEA will assess

capacities as a worst case scenario.

73

of that system without damaging the system.

192. Table 6.3 presents the alternatives assessment and also includes the consideration

of the "do-nothing" option. The assessment is based on both the production

capacities and the proposed locations for development of aquaculture units as

described in the Strategy.

Do-Nothing option

193. The Do-Nothing option is the option that would evolve in the absence of the

Strategy. It is based on the assumptions that a North AZ is under consideration and

all existing sites are retained. It also assumes that there is no written strategic

direction for the industry that addresses baitfish feeding practices, training, market

development, research and innovation, etc. Currently the south AZ is operational and is used solely for tuna fattening. The more challenging climatic conditions that

can be encountered further offshore in the south AZ have resulted in losses in

periods of bad weather and consequently farms operate from June to December.

Current technology does not provide enough guarantees for this site to be used for

CCS farming.

194. As discussed in Chapter 4, the aquaculture industry has been shown to result in a

number of environmental impacts including on the marine benthos (and sediments),

water quality, impacts from odour, and (in the case of tuna farms) baitfish oil slicks.

All of these impacts have been recorded from a number of farms, with the impacts

on the benthos largely resulting from farms in shallower waters. In the current state of affairs, the development of a south AZ was intended to reduce environmental and

social pressures from the aquaculture industry. Relocation of tuna farms to this

offshore site would have relieved pressures on the G and H sites. However, despite

permit conditions, relocation never happened and impacts remain at Sites G and H,

and have also now been introduced at the Southeast AZ site. It is likely that this

state of affairs would continue in the absence of a Strategy. The impacts of the

Strategy are described in Chapter 7.

195. The do-nothing option also results in negative impacts resulting from those farms

located in the north east area off Malta. As identified above, the sites lie within a

MPA and therefore it is crucial to manage these impacts in light of the conservation objectives for the area. In the do-nothing option, impacts from these sites will

remain.

196. The do-nothing option does not provide a framework within which the aquaculture

industry can operate. Currently, industry players operate in compliance with

individual permit requirements and there is no strategic direction for the sector. In

the absence of such a strategic direction, the industry is likely to develop on an ad

hoc basis.

Production Capacity Scenario 1

197. Scenario 1 proposes the development of new outer sites in Area 8 (see Figure 6.1)

for the production of tuna (this recommendation is included in all 3 scenarios).

74

Introduction of Area 8, which is relatively close to the coast (i.e. within 1km)

intensifies production in the area with all associated impacts. Area 8 is located within

a wreck conservation area and includes important dive sites; therefore there may be

potential negative impacts on tourism, water quality, biodiversity, and cultural

heritage, depending on the exact location for the new cages. These impacts could be

mitigated if the recommendations contained in the Strategy, including those related

to operating within environmental carrying capacity at sites, improved monitoring

methodology and improved enforcement are effectively implemented (see Chapter

7). It is noted that the existing cages in proximity of Area 8 (G1 and H1 in Figure

6.1) were issued with a permit on condition that they relocate to the south AZ once

this is set up. To date, it is understood that this relocation has not yet materialised;

the Strategy does not make reference to this situation. The Strategy proponent

considers that this area remains suitable for aquaculture subject that good practices,

as recommended in the Strategy, and carrying capacity are implemented.

198. Scenario 1 does not make provision for the development of a North AZ. This means

that the current environmental pressures exerted by the farms in the north of Malta

will remain.

199. In summary, production capacity scenario 1 aims to achieve a total 11,500t tuna

capacity by adding 3,000t capacity in Area 8. CCS sites remain unchanged.


200. This scenario is identical to Production Capacity Scenario 1 with respect to tuna. With regards to CCS, it proposes a North AZ (capacity 2,000t) and removal of site

A (to the North AZ) and intensification of Sites G and H.

201. The relocation of site A to the North AZ is expected to result in an overall positive

effect at Comino, since it will remove the site from the list of currently permitted

sites and the site will no longer be used for aquaculture. However, in the creation of

a new site where new impacts will be accrued and the fact that no other relocations

are considered, particularly in terms of the Mistra, and St Paul's Islands, and Mellieha

Bay cages, the extent of the significance of positive impacts is limited.

202. The proposed intensification of production of CCS is likely to increase extant

impacts at the Munxar and Il-Hofra sites, though the extent of this intensification

requires monitoring. These impacts could be mitigated somewhat if the

recommendations contained in the Strategy are effectively implemented (see

Chapter 7).

203. As in the case of production capacity scenario 1, the extension of Area 8 will create

further impacts.


204. With regards to tuna, Production Capacity Scenario 3 retains the 6,000t capacity at

the south AZ and removes tuna capacity at site E (allocating it to CCS). As with

Scenarios 1 and 2, it proposes an additional 3,000t in Area 8; however, it also

75

proposes an additional 3,000t in Area 1 (NAZ), 4,500t in Area 3, and 3,000t in Area

7.

205. With regards to CCS, 6,000t are allocated to existing sites. In addition, 3,000t are

proposed in Area 1 (North AZ), 2,000t in Area 3, 1,000t in Area 4, 1,000t in Area 6,

and 2,000t in Area 7. Area 5 is designated as a nursery.

206. This scenario seeks to open up all the identified proposed areas in Figure 6.1 for

aquaculture and to significantly intensify production capacity at all existing sites. This

implies that to reach this production capacity, none of the existing sites would be

relocated and another 8 new areas would be taken up. The increased production

capacity could result in an intensification of negative effects at the existing sites. This

will depend on the carrying capacity, operational performance, and results of

environmental surveys/monitoring. As identified earlier, potential negative impacts

may be recorded on biodiversity, increased problems from marine litter generated by

the industry, deterioration in water quality, impacts on sediment quality, and conflicts

with tourism and recreation (some of the sites are within 1km from the coastline or

overlap with important diving sites). Similar impacts would be expected in Areas 1 - 8. These impacts could be mitigated somewhat if the recommendations contained in

the Strategy are effectively implemented (see Chapter 7).

207. In addition to site specific impacts at each of the areas, the proximity of Areas 5 - 8

and the south AZ means cumulative negative environmental effects are likely.

Conflicts with other uses are also highly likely, including tourism, recreation,

bunkering, navigation, etc. As stated above, these impacts could be mitigated

somewhat if the recommendations contained in the Strategy are effectively

implemented (see Chapter 7).

Conclusions

208. Table 6.3 summarises the alternatives assessment. All of the proposed scenarios

envisage an increase in tuna production to varying degrees, with Production Capacity

Scenario 3 being the maximum envisaged. Production Capacity Scenario 3 is the

option that presents the largest negative environmental impact.

209. In particular, Production Capacity Scenario 3 describes 8 separate new areas along

the entire eastern coast. Moreover, Production Capacity Scenario 3 supports the

retention of all existing sites in addition to creating 8 new areas. Relocation of

existing farms in G and H is not contemplated.

210. The assessment illustrates that Production Capacity Scenario 3 presents the worst

case scenario in terms of environmental impacts. This is therefore the basis for the

assessment carried out in Chapter 7.

211. In order to achieve a more favourable balance between environmental concerns and

technical capacity, it is recommended that the Strategy consider additional options to

the three presented in the Strategy in line with the considerations presented below.

212. Firstly, the Strategy options do not seem to take into consideration the fairly recent

76

changes to the TAC for tuna (refer to Chapter 4). In 2011, the TAC was 12,900t;

this was revised up to 13,400 for 2013 and 2014. The minimum capacity proposed

under the 3 alternatives presented in the Strategy is 11,500t and the maximum, under

Production Capacity Scenario 3 is 19,500t. It is recommended that the Strategy

should reconsider the capacity required for the production of tuna given the lower

TAC because in the present state of affairs, it is not considered justifiable to create

excessive capacity for tuna farming. During monitoring and the Strategy review

process, the Strategy may be revisited to cater for any changes in the industry, if

required.

213. The alternatives presented include options related to the growth of the CCS sector,

and tuna. It is recommended that, rather than referring to a particular species, a

general Strategy is adopted at this stage (as for CCS). Terminology such as Capture-

Based Species (CBS) is therefore considered more appropriate (in place of direct

reference to tuna) and would thereby allow the Strategy to cater for any changes in

the industry that may arise.

214. The development and designation of Aquaculture Zones for the industry should be clearly defined in the Strategy and promoted as a means to reduce the negative

effects that the industry is currently exerting on the environment rather than solely a

means of increasing production. When referring to an Aquaculture Zone, this is

considered to be an area permitted for the use of aquaculture. Such a zone would be

chosen on the basis of several detailed studies including Environmental Impact

Assessment. Depending on the location of the site an Appropriate Assessment in

line with the Habitats Directive may also be required. To this end, proposals to

relocate all farms from existing, inappropriate sites to a permitted AZ in line with

permit requirements should be given concrete importance and direction within the

Strategy. It is noted that the existing South East Aquaculture Zone is not

appropriate for CCS culture. However, the proposed North AZ being closer to the

coast, may be utilised for CCS culture as well. It is pointed out that during the

development of the SEA, it was clarified by the proponent that the proposed areas

(Areas 1-8) are considered to be ‘search areas’ for the location of such zones,

although this was not made clear in the text of the Strategy itself.

215. The recommendations contained in Chapter 8 of the Strategy need to be tailored

towards a preferred production capacity. The absence of a preferred production

scenario amongst the three summarised in Table 16 of the strategy leaves room for

significant interpretation of the recommendations in Chapter 8 of the SEA. In

identifying a preferred capacity for both CCS and CBS, the extent of growth required

in terms of sites will also be identified. However, at this stage, even in the absence of

a clear target, it should be noted, that also in consideration of section 6.5.2 of the

Strategy, Production Capacity 3 still provides an overcapacity when compared to the

highest production target in Table 16 of the Strategy. In this regard, and with regard

to the previous recommendation related to the designation of aquaculture zones, all

effort should be taken to ensure minimal additional uptake of marine areas is based

on real needs and subject to the necessary studies.

77

216. It is important to note that options presented will need to assume that the

production capacities are within environmental carrying capacities at each

site as stated in the Strategy71.

217. Chapter 8 of the SEA provides recommendations based on the findings from

Chapter 6 and Chapter 7.

71 It should however be noted that there are no hard and fast data to confirm this assumption.

78

Figure 6.1: Existing and proposed aquaculture production sites

79

Figure 6.2: Marine uses around the Maltese Islands

80

Figure 6.3: Proposed aquaculture production sites and marine uses

81

Figure 6.4: Preferred location of the North Aquaculture Zone

82

Figure 6.5: Production capacity scenario 1

83


84


85

Table 6.2: SEA Objectives and tuna’s proposed production scenarios

SEA Objectives Maintain biodiversity

(including terrestrial and

marine);

Avoid introduction of

non-indigenous species

into the natural

environment;

Populations of fish

species taken from the

wild are within safe

biological limits (including

species used for baitfish);

Avoid negative effects on

wild fish populations

Ensure aquaculture products are

within the legal safety requirements

(antibiotic resistance, possible

contamination and bioaccumulation of

chemicals, microbial agents and toxins)

for human consumption;

Ensure bathing water quality does not

deteriorate as a result of aquaculture

Minimises pollution on

the marine environment;


eutrophication;

Sea-floor integrity is

maintained;

Avoids generation of

litter;

Minimise pollution on

groundwater from

activities directly arising

from the aquaculture

sector;

Avoids deterioration of

water bodies

Ensure no

odour nuisance

from

aquaculture

Contributes to

climate change

adaptation

Avoid

contamination of

marine sediments

Ensure no conflict

between aquaculture

and other uses (e.g.

tourism, recreation,

etc);

Sustainable waste

management

Maintain the

conservation status of

cultural heritage sites /

areas with known

cultural / archaeological

remains

Maintain

landscape quality

distinctiveness

Alt

ern

ati

ves

Do-nothing

Option

P

-

D

LT

P

-/0

D

LT

P

-

D

LT

P

-

D

LT

P

+

D

LT

P

-

D

LT

P

-

D

LT

P

-

D

LT

P

-

D

LT

Production

Capacity

Scenario 1

P

-

D

LT

P

-

D

LT

P

-

D

LT

P

-

D

LT

P

+

D

LT

P

-

D

LT

P

-

D

LT

P

-

D

LT

P

-

D

LT

Production

Capacity

Scenario 2

P

+/-

D

LT

P

+/-

D

LT

P

+/-

D

LT

P

+/-

D

LT

P

+

D

LT

P

-

D

LT

P

-

D

LT

P

-

D

LT

P

+/-

D

LT

Production

Capacity

Scenario 3

P

--

D

LT

P

--

D

LT

P

--

D

LT

P

--

D

LT

P

++

D

LT

P

--

D

LT

P

--

D

LT

P

--

D

LT

P

--

D

LT

86

CHAPTER 7: ASSESSMENT OF ENVIRONMENTAL

EFFECTS AND PROPOSED MITIGATION

INTRODUCTION

218. This Chapter describes the assessment process followed in the strategic

environmental assessment, and describes the results of the assessment and mitigation

measures recommended to minimise or negate the impacts.

ASSESSING SIGNIFICANCE

219. Significance is assessed in accordance with the criteria listed in Schedule 2 of the SEA

Regulations, 2010. It is already well established in Environmental Impact Assessment

(EIA) literature whereby significance is a function of impact magnitude and the

sensitivity of receptors. Significance may be determined in a number of ways,

including expert judgements, the use of thresholds, reference to legislation, and

consultation with stakeholders. Although this SEA draws on each of these methods,

expert judgement and consultation predominate.

220. The assessment of significance is based on the probability of the impact occurring, on

the scale of the impact, its duration, reversibility, whether it has transboundary

impacts, and the certainty of impact prediction. Table 7.1 describes the assessment

framework and the symbols used to denote the various types of impact.

221. The relevant SEA objectives identified in Chapter 5 are used to assess the measures

in accordance with the significance criteria described below.

Table 7.1: Assessment legend

Impact character Symbol Description of Impact

Probability VP Impact very likely to occur

P Impact likely to occur

Scale

++ Large positive impact

+ Positive impact

0 No impact

- Negative impact

-- Large negative impact

Direct / Indirect I Indirect impact

D Direct impact

Frequency / duration LT Long term

ST Short term

Transboundary dimension TR Possible transboundary effect

Uncertainty ? Impact uncertain

IMPACT ASSESSMENT

222. Based on the methodology described above each of the measures was assessed

against each SEA objective. The results are presented in Table 7.2.

87

223. As described in Chapter 4, the aquaculture sector is considered to have a negligible

impact on air emissions and therefore assessment against the relevant objective has

been scoped out.

88

Table 7.2: Impact assessment

SEA Objective Indicator Comment Significance

Mitigation Symbols Summary description

Aspect 1: The Tuna Penning Sector

Proposals:

- Tuna farms on near shore sites should be relocated to sites with more than 50m water depth and more than 1nm from shore to limit impacts.

- Consideration should be given to restricting the feeding of bait fish to tuna cages during onshore wind conditions in the summer tourist season if alternative solutions are not found.

- A review of tuna offal disposal should be carried out.

Maintain biodiversity (including

terrestrial and marine)

Avoid introduction of non-

indigenous species into the natural

environment

Populations of fish species taken

from the wild are within safe

biological limits (including species

used for baitfish)

Avoid negative effects on wild fish

populations

Monitoring results from

impacts on the sea bed

Number of permitted sites

in protected areas



environment that may have

been introduced as a result

of aquaculture activities

Number of infringements

against Illegal & Unreported

and Unregulated (IUU)

Fishing

Recorded disease outbreaks

in wild populations

Relocation of tuna farms to more appropriate sites

should result in a positive effect at the vacated sites,

where these are inappropriate to support tuna

penning. This, however, implies impacts related to

aquaculture at new sites and therefore extent of

impacts will be related to how the process of

relocation is managed, the environmental

characteristics of the new site, and the management

of farm operations.

If the original sites continue to be used for

aquaculture, impacts at that site will remain, but are

likely to be less significant in the case of CCS

species that are fed pellets, assuming management

measures proposed in the Strategy are

implemented. In order to reduce any negative

effects, the sites should operate within the

environmental carrying capacity of the site.

P

+

D

LT

A positive impact is expected if the relocation of

farms is to permitted aquaculture zones (that

have undergone the necessary assessments at

project level). Relocation to additional sites for

individual operators takes away from the concept

of managing this industry holistically, restricting

impacts to one area, and avoiding sprawl and

cumulative effects. Therefore, it is

recommended that all tuna penning should be

located and managed within aquaculture zones

and the creation of new sites (for individual

operations) is to be avoided.

If, following relocation of the tuna farms, the freed up

sites are used for CCS species, these must operate

within the environmental carrying capacity of the site in

order to reduce potential continued negative impacts at

these locations. The possibility of cage site rotation to

allow impacted seabed to fallow and recover could also

be considered.

Monitoring of relevant parameters as part of an

environmental management plan, which includes

remedial actions to be taken where necessary should be

a permit requirement for all operations.

In terms of regulation and enforcement, it is

recommended that the operator of aquaculture zones is

separate from the regulator of fisheries operations. This

would allow for more transparent regulation of the

aquaculture zones.

The recommendations within the Strategy to develop

and test alternative tuna feeds as well as a drive towards

research into culturing alternative species are

considered to contribute to attempting to reduce

impacts from the industry.




contamination and bioaccumulation

of chemicals, microbial agents and

toxins) for human consumption

Ensure bathing water quality does

not deteriorate as a result of

aquaculture



operational permit

requirements


Appropriate site selection and operational

management are the important areas that should be

addressed in light of these SEA objectives.

P

+

D

LT

Relocation of tuna farms to more appropriate

sites should result in a positive effect at the

vacated sites, where these are inappropriate to

support tuna penning.


aquaculture, impacts at that site will remain, but

are likely to be less significant in the case of CCS

species that are fed pellets, assuming that no

over-feeding takes place and that any uneaten

pellets would have dissolved before reaching the

seabed. In order to reduce any negative effects,

the sites should operate within the

environmental carrying capacity of the site.

Other sections within the Strategy include

recommendations related to water quality and safety

standards regarding mainly monitoring, implementation

of legislation as well as measures related to fish health

control. The implementation of these measures will

ensure that bathing water quality is not affected.

Minimises pollution on the marine

environment


eutrophication

Sea-floor integrity is maintained

Avoids generation of litter

Quality of the marine


benthos under cages and in

the vicinity of aquaculture

operations


loading

As noted in Chapter 4 and above, tuna penning

has in the past resulted in impacts on the water

column, the seabed sediment and benthic organisms

likely due to bad management practices.

P

+

D

LT

Relocation of tuna farms to more appropriate

sites should result in a positive effect at the

vacated sites, where these are inappropriate to

support tuna penning. This, however, implies

impacts related to aquaculture at new sites and

therefore extent of impacts will be related to

how the process of relocation is managed, the

A positive impact is expected if the relocation of farms

is to permitted aquaculture zones (that have undergone

the necessary assessments at project level). Relocation

to additional sites for individual operators takes away

from the concept of managing this industry holistically,

restricting impacts to one area, and avoiding sprawl and

cumulative effects. Therefore, it is recommended that

89

SEA Objective Indicator Comment Significance Mitigation

Minimise pollution on groundwater

from activities directly arising from

the aquaculture sector

Avoids deterioration of water bodies

Aquaculture originating

marine litter in the water

column

Ingested marine litter,


activities, by indicator

species (e.g. Caretta caretta)

Marine litter collected from

the seabed and from

beaches during cleaning that

originates from aquaculture

activities

Quality of groundwater in

the vicinity of land-based

aquaculture operations

Compliance with the Water

Framework Directive

(WFD).

environmental characteristics of the new site,

and the management of farm operations.


aquaculture, impacts at that site will remain, but

are likely to be less significant in the case of CCS

species that are fed pellets, assuming that no

over-feeding takes place and that any uneaten

pellets would have dissolved before reaching the

seabed. In order to reduce any negative effects,

the sites should operate within the

environmental carrying capacity of the site and

be regularly monitored.

The Strategy does not propose direct measures

to address potential problems with marine litter

that may originate from the industry.

all tuna penning should be located and managed within

aquaculture zones and the creation of new sites (for

individual operations) is to be avoided.

If, following the relocation of tuna farms, the freed up

sites are used for CCS species, these must operate

within the environmental carrying capacity of the site in

order to reduce potential continued negative impacts at

these locations. The possibility of cage site rotation to

allow impacted seabed to fallow and recover could also

be considered.



remedial actions to be taken where necessary should be

a permit requirement for all operations.

The recommendation within the Strategy to develop

and test alternative tuna feeds as well as a drive towards

research into culturing alternative species are

considered to contribute to attempting to reduce

impacts from the industry. The development of a

CoGP (a Strategy recommendation) should include

waste management considerations including measures to

reduce generation of marine litter.





control.

Ensure no odour nuisance from

aquaculture

Number of confirmed cases

of odour arising from


The proposed measures seek to reduce impacts

from odour.

P

+

D

LT

The proposed measures i.e. relocation further

offshore seek to go some way to reducing odour

impacts given the increased distance from

sensitive receptors.

In addition to these proactive measures, a formal

complaint system should be set up in order to allow

monitoring of the situation.

Contributes to climate change

adaptation

Diversification of CCS in

the Maltese aquaculture

sector

This aspect does not address diversification. 0

This Aspect does not address diversification,

which is considered elsewhere within the

Strategy.

N/A

Avoid contamination/degradation of

marine sediments



Changes to marine

sediments at specific sites.

Monitoring of previous aquaculture activities has

indicated that they have led to anoxic sediment

conditions in the past, likely due to bad

management practices. Sediments are the primary

sink for particulate nutrients within the marine

system and therefore higher nutrient inputs will lead

to greater bacterial oxygen demand, which can

cause an equilibrium shift from oxygenation to

reduction processes leading to anoxic conditions.

The proposal to locate tuna pens further offshore is

expected to reduce known impacts from tuna

penning on marine sediments at the current sites

(located in relatively shallow waters, and close to

the coast) due to their limited ability to effectively

mobilise excess feed and feed waste, which make it

P

+/-

D

LT

Relocation of tuna farms further offshore is

expected to result in a positive impact at the

existing sites. This, however, implies impacts

related to aquaculture at new sites and therefore

extent of impacts will be related to how the

process of relocation is managed, the

environmental characteristics of the new site,

and the management of farm operations.


aquaculture, impacts at that site will remain,

which will be negative on the sediments to a

significant degree if the environmental carrying

capacity at these sites is exceeded.

A positive impact is expected if the relocation of farms

is to permitted aquaculture zones (that have undergone

the necessary assessments at project level). Relocation

to additional sites for individual operators takes away

from the concept of managing this industry holistically,

restricting impacts to one area, and avoiding sprawl and

cumulative effects. Therefore, it is recommended that

all tuna penning should be located and managed within

aquaculture zones and the creation of new sites (for

individual operations) is to be avoided.

A more significant positive environmental effect can be

accrued if the sites previously used are freed up. If, on

the other hand, the freed up sites are used for CCS

species, these must operate within the environmental

carrying capacity of the site in order to reduce potential

90


more likely that these collect on the seabed.

continued negative impacts at these locations.



remedial actions to be taken, where necessary, should

be a permit requirement for all operations.

Ensure no conflict between

aquaculture and other uses (e.g.

tourism, recreation, etc)

Sustainable waste management


of conflicts related to



Environmental data

collected through

operational permits

Farm operations, particularly in relation to feeding

and waste disposal have also resulted in conflicts

with bathers and recreational users of the coastal

environment, including divers and yachters. The

proposal to restrict the use of baitfish during

onshore wind conditions during summer is

expected to reduce complaints related to

aquaculture activities. However, the proposal

suggests that alternatives may also be found without

elaborating on what this means.

Relocation further offshore should also reduce

impacts on shore-based recreational areas.

P

-/+

D

LT

In term of conflicts with recreational users, if

relocated and managed appropriately, including in

terms of waste management, there should be a

reduction in conflicts between these users and

the farms.

The Strategy should include proposals to ensure the

Sector adopts responsible waste management

procedures. One recommendation is to ensure that all

farms develop an Environmental Management Plan (as

part of permit and license conditions), which will include

aspects on waste management.

As described in Chapter 4, previous conflicts were

largely related to poor management practices,

Measures presented in the Strategy related to improving

monitoring and enforcement are expected to reduce the

scope for conflict.

Maintain the conservation status of

cultural heritage sites/areas with

known cultural/archaeological

remains

Number of operations

located away from cultural

heritage sites / areas or

areas with known cultural /

archaeological remains as a

percentage of the total


If re-located to an Aquaculture Zone, the EIA

associated with the zone would have addressed the

issue of cultural heritage in relation to that specific

zone.

? If it is found through the EIA that the Zone site

could result in significant cultural heritage

impacts, it is considered that appropriate

mitigation measures would then be proposed at

project level, including the consideration of re-

location.

As identified during project level assessment.

Maintain landscape quality

distinctiveness


Assessment results on

landscape assessment

In terms of landscape impacts on the coast,

relocation of existing cages is expected to result in

a positive impact if the existing sites are freed up. If

sites are maintained for CCS, there will be no

change in terms of visual impact from cages

(although, as identified in Chapter 4, visual impact

from the cages is considered to be limited).

However, adverse impacts from oil slicks resulting

from the use of baitfish to feed the tuna, which

include both visual and odour will no longer be an

issue at the sites in question.

P

+/0

D

LT

In terms of landscape impacts on the coast,

relocation of existing cages is expected to result

in a positive impact if the existing sites are freed

up. If sites are maintained for CCS, there will be

no change.

N/A

Aspect 2: The Sea Bream and Sea Bass Sector

Proposals:

- Sea Bass and Sea Bream will remain important species for the industry for the foreseeable future so account must be made of this in strategic planning.





environment




used for fishbait)


populations




in protected areas









The Strategy places an emphasis on this industry.

As described in Chapter 4, environmental impacts

from these species recorded in the past have

related mainly to overcapacity and poor

management of individual sites.

Nutrient enrichment from sea bass and sea bream

farms in the Mediterranean has been known to

increase primary productivity in farm surroundings

in the oligotrophic Mediterranean Sea, which

subsequently results in stimulating productivity at

higher trophic levels. Thus, as long as carrying

P

-/0/+

D/I

LT

Depending on the production scenario selected

including the consideration of potential sites,

impacts on marine benthos in the cage vicinity

will be either negative (this is particularly a

consideration in the establishment of new sites)

or neutral at existing sites that operate according

to good practice and within carrying capacity.

There may also be a degree of positive impact if

nutrient enrichment results in an increase in

primary productivity.

Chapter 6 identifies potential impacts from each of the

proposed alternatives. Refer to Chapter 6 for proposed

recommendations including where it is recommended

that the Strategy should include measures to restrict

aquaculture to certain zones and avoid individual

operators applying for sites outside of permitted zones.

.

Carrying capacities must be established for all sites and

strict adherence to these capacities should be enforced.

Monitoring at these sites needs to remain an important

91


Fishing


in wild populations

capacity is not exceeded and the water quality does

not deteriorate, this sector could positively affect,

to a degree, species abundance (EU Commission,

2012).

The escape of fish from cages could result in

negative genetic effects on wild populations through

interbreeding, and ecological effects through

predation, competition and potential transfer of

diseases to wild fish. Proper management would

avoid such impacts.

Chapter 6 describes potential impacts from the

alternative production scenarios described in the

Strategy, which seeks to increase the production of

these species and therefore the previous impacts

recorded may potentially be expected in increased

production scenarios and at new sites. Other

Strategy recommendations, however, seek to

minimise such potential impacts including

recommendations to ensure establishment and

adherence to carrying capacity at all sites,

establishing an industry Code of Good Practice

(CoGP), improved monitoring and enforcement,

etc.

part of the permit conditions. In addition, however, the

Strategy should identify alternative approaches or

mitigation measures whenever certain parameters are

consistently exceeded and can be developed for each

operation within an Environmental Management Plan for

the site. Monitoring results must also feed back into the

establishment of carrying capacities. This should be

done in consultation with MEPA, particularly where

intervention, based on the data gathered, is required.

Despite the continued focus on this sector, a

commitment to explore other options, in particular

cultivation of herbivorous species or development of an

appropriate protein alternative within pellets should

continue to be a focus of the Strategy.

Good management practices to reduce wastage from

feed and minimise risk of escape should always also be

implemented. Implementation of good practice should

be inspected on a regular basis by

MARC/MEPA/Department of Fisheries (details to be

established in MOU) and if breaches are consistently

noted, specific and imminent action should be taken.









aquaculture



operational permit

requirements


Management of operations and the regulator should

ensure that correct guidelines and legislation is

abided by within this sector.

The Strategy proposes an increase in the

production of CCS species as assessed in Chapter

6. Increased production and increased sites could

impact bathing water quality. Other Strategy

proposals related to good management should go

some way to mitigating such effects.

P

-/0

I

LT

The Strategy should have regard to the

conclusions laid out in Chapter 6 in considering

potential cumulative impacts from increased

production of these species including in terms of

water quality. Regard to bathing sites is

imperative when considering levels of increased

production and location of new sites. This data

should also inform the establishment of carrying

capacities.





control.


environment


eutrophication











operations


loading



column






the seabed and from


The cultivation of Sea Bass and Sea Bream is carried

out in relatively shallow waters and bays, which are

more vulnerable to excess nutrient loads potentially

leading to eutrophic conditions.

Potentially significant impacts can occur on

sediment parameters as well in case of nutrient

overload. Other Strategy recommendations,

however, seek to minimise such potential impacts

including recommendations to ensure establishment

and adherence to carrying capacity at all sites,



etc.

P

-

D

LT

The introduction of new cages in new areas is

likely to result in impacts in terms of quality of

benthos under the cages, increased nutrient

levels and subsequent increase in oxygen demand

in the water column and sediments, etc.

Implementation of the Strategy

recommendations as outlined previously should

reduce the significance of such impacts.

Management of these sites in line with good practice is

important in order to reduce all potential impacts

including those related to sediment changes.

Remedial measures must be adopted when monitoring

results show consistent exceedances.

The development of a CoGP should include waste

management considerations including measures to

reduce generation of marine litter.

92



activities





Framework Directive

(WFD).


aquaculture




Given that pellets are used to feed these species,

odour has not typically been considered a nuisance

from cultivation of these species.

P

0/-

D

LT

The marine-based operation does not generally

result in a significant odour issue. Land-based

facilities, depending on proposed activities, could

potentially be a source of odour.

In addition to Strategy recommendations, any land-based

proposals, e.g. related to packaging/processing or net

washing / mending must be managed in consideration of

the potential nuisance from odour and all measures to

reduce potential impacts should be implemented. This

would need to be addressed in detail at project level.


adaptation



sector

This measure does not address diversification. 0 This measure does not address diversification. N/A

Avoid contamination/degradation of

marine sediments



Changes to marine


Poor management and overcapacity could

contribute to significant negative effects on the

sediment.

Other Strategy recommendations, however, seek to






etc.

P

-/0

D

LT

The potential for negative effects remain,

although the Strategy provides a number of

recommendations that, if implemented, could

reduce the effects. However, the Strategy also

considers increased production and new sites.

The development of new sites would extend

impacts to these areas.

Good practice and remedial measures should be

implemented to minimise negative effects on the

sediment at existing sites.

Refer to recommendations in Chapter 6. If new sites

are considered, a detailed site selection exercise and

EIA are required. Permit conditions would need to take

into consideration carrying capacity and management of

the operation.


aquaculture commercial activities

and other uses (e.g. tourism,

recreation, etc)






Environmental data

collected through

operational permits

These species are generally reared in cages

relatively close to the shore. Impacts relate to

amenity as well as human perception of impacts. A

negative impact in terms of integration with other

uses related for instance to tourism and recreation

is expected.







etc.

P

-

D

LT

These species are generally reared in cages

relatively close to the shore and therefore issues

related to amenity as well as human perception

of the impact of such activities in the vicinity as

well as actual impacts (as attested by monitoring

results).

Farm management in accordance with good practice will

go some way in mitigating conflict with other uses such

as tourism and recreation.

Marine spatial planning will also take potential conflicts

into consideration and seek to minimise them.




remains








Surveys carried out prior to cage siting will have

informed the placement of cages to ensure they are

not located within archaeologically sensitive sites.

This is generally controlled at a project level.

? Surveys should be carried out at project level to

identify whether there will be any potential

impacts on archaeology. This is assessed at

project level.



distinctiveness




The near shore cages are considered to have a

negative impact on the seascape (see Chapter 4).

P

-

D

LT

The near shore cages are considered to have a

negative impact on the seascape (see Chapter

4).

Carry out landscape assessment at project level for new

applications.

Aspect 3: Alternative species

93


Proposals:

- The main emphasis with regard to development of alternative species should be on amberjack.

- A hatchery and spawning facility for amberjack, bluefin tuna and other species should be established at the earliest opportunity.

- Other species groups such as groupers, sparids, octopus and sea urchins may have potential for production in Malta in the future, and research into such species should be encouraged providing commercial potential can be demonstrated.





environment




used for fishbait)


populations




in protected areas









Fishing


in wild populations

Amberjack is another carnivorous species, and

therefore the sustainability of putting emphasis on

this species should be considered. However,

market considerations, such as consumer demand

for carnivorous species must also be taken into

consideration.

Consideration of herbivorous species and/or low-

trophic level species in particular is considered to

be more sustainable, and such alternatives should be

taken into account when considering research focus

within the Strategy.

Closing of the tuna cycle is expected to reduce

pressure on the wild populations..

P

-/+

D

LT

Depending on the selected species used, impacts

on biodiversity could be negative, particularly if

carnivorous species are the focus and could

result in impacts on bait fish populations that

could have secondary impacts on the food web, if

these are fished using unsustainable methods.

Replacing carnivorous species with herbivorous

ones and lower trophic level species such as

molluscs and sea urchins, recommended for

research under this Strategy aspect, would be

preferable.

N.B. Chapter 6 identifies the need to identify

aquaculture zones. Any introduction of new

sites will result in the impacts already identified,

although these will be managed through the

implementation of the Strategy

recommendations.

When considering alternative species for culture,

consideration should be given to the aquafeeds to be

used for production. As outlined in the IUCN guidance

(2007)72, the sourcing of these raw materials should be

environmentally acceptable, and should not have

negative impacts on the ecosystems from which these

ingredients are harvested.









aquaculture



operational permit

requirements


It should be ensured that any alternatives adopted

remain in compliance with legislation and good

practice. Environmental monitoring of operations

would also be required to ensure water quality

does not deteriorate and carrying capacities must

be established and adhered to.

? It is assumed that all developments will ensure

compliance with legal safety requirements, and

operate to best practice standards, however, at

this stage, this is considered an uncertainty.

Close monitoring of cultivation of alternative species is

required both in terms of environmental and health data

gathering.


environment


eutrophication











operations


loading



column






the seabed and from



activities

The risk from previously identified impacts

associated with aquaculture is expected to remain.

However, implementation of industry standards as

outlined through other Strategy recommendations

may successfully mitigate any negative effects.

In addition, depending on facility operation, there

may be impacts resulting from discharges to the

marine environment.







etc.

P

-/0

D

LT

If operated according to carrying capacities, at

existing sites, there may be no residual negative

impacts.

Monitoring and remedial measures are required to

minimise any negative effects.

Management of the land-based hatchery must be

considered in detail particularly in terms of water inputs

and outputs and the need for filtration systems and

other methods to avoid contamination of the

environment from any discharges.

72 2007. Guide for the Sustainable Development of Mediterranean Aquaculture. Interaction between Aquaculture and the Environment. IUCN, Gland, Switzerland & Malaga, Spain.

94






Framework Directive

(WFD).


aquaculture




Formulated feeds have been developed for

amberjack, reducing problems with odour at the

cages. Odour may be a nuisance from the

proposed land-based facility and therefore its siting

is of particular importance.

P

-/0

D

LT

Formulated feeds have been developed for

amberjack, reducing problems with odour at the

cages. Odour may be a nuisance from the

proposed land-based facility and therefore its

siting is of particular importance.



adaptation



sector

This Aspect is in line with this SEA objective. P

+

D

LT

Reducing the dependence on a handful of species

will improve the industry’s prospects in the long-

term and contribute to climate change

adaptation.

N/A

Avoid contamination of marine

sediments



Changes to marine


The risk from previously identified impacts

associated with aquaculture is expected to remain.

However, implementation of industry standards as

outlined through other Strategy recommendations

may successfully mitigate any negative effects.

P

-/0

D

LT

Current impacts associated with aquaculture are

expected to remain. If operated according to

carrying capacities, at existing sites, there may be

no residual negative impacts.

Implementation of monitoring and remedial measures

are imperative in avoiding or reducing negative effects.




recreation, etc)






Environmental data

collected through

operational permits

Development of a land-based hatchery could result

in conflicting uses. Current policy and the

consultation processes identify industrial areas as

the best place for a land-based facility. In reality,

technical issues associated with the running of such

a facility will also have an input in the site selection

process.

? Impacts are largely confined to and subject to the

location of the facility.

Site selection at project stage should be carried out in

order to minimise potential negative effects from

additional facilities including more cages and a land-

based hatchery.




remains








If existing sites are used, no impacts are expected

on the marine environment. In case of new cages,

potential impacts would depend on the siting of any

new cages and the proposed land-based facility.

? Surveys should be carried out related to any new

proposal to identify any potential impacts on

cultural heritage.



distinctiveness




Depending on where cages are located, if new sites

are proposed, and where a land-based facility is

located the impact on the landscape is likely to be

not significant to negative.

P

-/0

D

LT

Depending on where cages are located, if new

sites are proposed, and where a land-based

facility is located the impact on the landscape is

likely to be not significant to negative.


Aspect 4: Identification of sites and potential production scenarios

REFER TO CHAPTER 6 FOR ALTERNATIVES ASSESSMENT

Aspect 5: Aquaculture Policy

- It is recommended that the 2004 policy document is updated to reflect the findings of this study, making sure that it reflects the needs of the industry and current issues, and taking into account the views of all stakeholders, especially the growers

themselves.

THE ASSESSMENT OF THIS ASPECT HAS BEEN INCORPORATED AS PART OF THE ASSESSMENT ON ASPECT 6 GIVEN THAT ASPECT 5 CALLS FOR AN UPDATE TO THE EXISTING POLICY, SOME

RECOMMENDATIONS OF WHICH ARE PART OF ASPECT 6.

Aspect 6: Regulation

- Whilst the concept of zoning is desirable in principle for existing sites as well as new sites, it should only be pursued providing that operators are not financially or operationally disadvantaged and they are fully consulted.

- It is recommended that the minimum term for concessions is 25 years, or in accordance with normal commercial lease terms in Malta, subject to compliance with operating conditions.

- It is recommended that all tuna farms be located in more than 50m water depth and 1nm from shore, whilst CCS should mostly be in less than 50m water depth at varying distance from the shore.

- The present process by which farms are monitored and enforcement instigated should be reviewed and strengthened.

95


- The introduction of conditions regards methods of feeding baitfish to tuna should be considered.

- The industry should be encouraged to prepare a COGP, if necessary supported by funding from the Government.

- MEPA must be aware of the strategic intentions of the Government regarding the industry through a revised policy document based on the findings of this study.

- It is recommended that an appropriate individual within MEPA is trained as an aquaculture specialist to act as a liaison officer between MEPA and the industry.

- An Aquaculture Working Group made up of representatives from the industry, MEPA and MRRA should be established to address specific issues affecting the industry.





environment




used for fishbait)


populations




in protected areas









Fishing


in wild populations

Recommendations under this Aspect are largely

expected to result in both direct and indirect

impacts on benthos, particularly those that seek to

improve management of operation of the farms.

The first recommendation, however, seems to

contradict the recommendation that all tuna farms

should be relocated further offshore, whereby it

places conditions on relocation, especially seeing

that all tuna farms are in 50m of water or more. In

order to ensure positive impacts, or less significant

negative effects, relocation should be required.

Processes to improve monitoring and enforcement,

conditions regarding feeding baitfish to tuna, and the

preparation of a CoGP are expected to result in

positive effects in that impacts on benthos from

excess feed and subsequent nutrient load should be

reduced.

P

+

D/I

LT

Proposals to improve management of the farms

including proposals related to improved

monitoring and enforcement as well as

development of CoGP should have indirect

positive effects on the benthos. Relocating tuna

farms further offshore should reduce pressures

on the benthos, however, the positive effect will

depend on how these are managed.

The Strategy needs a clear direction to fully support the

use of aquaculture zones and require all relevant farms

both existing and any new proposed, to be located in

such zones.









aquaculture



operational permit

requirements


Proposals to improve management of farm

operations should result in an improvement in

water quality in the vicinity of the farms.

P

+

D/I

LT




development of COGP should have indirect

positive effects on water quality. Relocating tuna

farms further offshore should improve water

circulation, thereby reducing risk of anoxic

conditions; however, the extent of this positive

effect will depend on whether other species will

be reared at the existing sites and how they will

be managed (including whether operation is

carried out within the site's environmental

carrying capacity).


use of aquaculture zones and require all relevant farms,


such zones.


environment


eutrophication











operations


loading



column






the seabed and from



activities



water quality in the vicinity of the farms.

P

+

D/I

LT




development of COGP should have indirect

positive effects on water quality. Relocating tuna

farms further offshore should improve water

circulation, thereby reducing risk of anoxic

conditions, however, the extent of this positive

effect will depend on whether other species will

be reared at the existing sites and how they will

be managed (including whether operation is

carried out within the site's environmental

carrying capacity).




such zones.

96






Framework Directive

(WFD).


aquaculture






odour in the vicinity of the farms.

P

+

D/I

LT




development of CoGP, and in particular

conditions on the use of baitfish should minimise

existing problems regarding odour. Relocating

tuna farms further offshore should also reduce

odour impacts on land.




such zones.


adaptation



sector

This aspect does not directly address this objective. 0 This aspect does not directly address this

objective.

N/A


sediments



Changes to marine



operations, including relocation of tuna farms

should result in reduced impact on sediments.

P

+

D/I

LT




development of CoGP, and in particular

conditions on the use of baitfish should minimise

existing problems regarding sediment

contamination. Relocating tuna farms further

offshore should also reduce impacts on

sediments.




such zones.




recreation, etc)






Environmental data

collected through

operational permits

A CoGP and improved monitoring and enforcement

should ensure sustainable waste management.

Relocation of tuna farms must consider other uses

and potential conflicts at identified new sites.

P

+/?

D/I

LT

A CoGP and improved monitoring and

enforcement should ensure sustainable waste

management.

Consideration of alternative site selection outcome

should be an integral part of the Strategy including

reference to the preferred option.

Relocation of tuna farms to aquaculture zones rather

than a number of separate sites would facilitate

management and reduce any impacts in this regard.




remains








Potential impacts on cultural heritage need to be

identified at project level if relevant.

? Potential impacts on cultural heritage need to be

identified at project level if relevant.



distinctiveness




This aspect is not expected to have a direct bearing

on this objective.

0 This aspect is not expected to have a direct

bearing on this objective.

N/A

Aspect 7: R&D

- A mechanism should be put in place to ensure regular (e.g. annual) reviews of research priorities and funding are carried out involving Government, industry and academic stakeholders.

- Resources should be committed to the development and testing of alternative tuna feeds that reduce reliance on baitfish.

- The PPP model of R&D funding appears to be working well and should be developed further, although it must allow participation by all growers in Malta.

- The development of a new marine hatchery and R&D centre is a high priority under the Aquaculture Strategy and full costings and a finance model, most likely using a PPP, should be developed as soon as a site has been agreed.

- Collaboration between MARC and the University of Malta and other institutions in the Mediterranean, whether to provide access to specialised research equipment or expertise is recommended.

97






environment




used for fishbait)


populations




in protected areas









Fishing


in wild populations

Investment in R&D that, in particular, includes

attempting to develop a pellet feed for tuna could

result in positive impacts in the long-term, in

particular if an alternative source of protein is used

in the development of the pellet to reduce pressure

on baitfish. However, this research is considered to

be in its infancy and no direct benefits are expected

in the near future.

The recommendations hereunder are not expected

to generate significant environmental effects:

- A mechanism should be put in place to ensure

regular (e.g. annual) reviews of research

priorities and funding are carried out

involving Government, industry and academic

stakeholders.

- The PPP model of R&D funding appears to be

working well and should be developed

further, although it must allow participation

by all growers in Malta.

- Collaboration between MARC and the

University of Malta and other institutions in

the Mediterranean, whether to provide

access to specialised research equipment or

expertise is recommended.

0 Investment in R&D that, in particular, includes

attempting to develop a pellet feed for tuna

could result in positive impacts in the long-term,

in particular if an alternative source of protein is

used in the development of the pellet to reduce

pressure on baitfish. However, this research is

considered to be in its infancy and no direct

benefits are expected in the near future.

Although no significant impact is expected at a

national level, the impact of the proposed

hatchery on biodiversity would depend on the

sites selected.

The location of the hatchery would be subject to the

relevant planning and environmental processes.









aquaculture



operational permit

requirements


This aspect does not directly influence this

objective.

0 This aspect does not directly influence this

objective.

N/A


environment


eutrophication











operations


loading



column






the seabed and from



activities



objective.


objective.

N/A

98





Framework Directive

(WFD).


aquaculture




Setting up of a new land-based facility must consider

potential impacts from odour.

P

-/?

D

LT

Negative odour impacts may be accrued

depending on the location of the hatchery.



adaptation



sector

Investment in R&D should help the sector better

adapt to climate change and setting up a local

hatchery reduces dependence from other sources.

P

+

D

LT

Investment in R&D should help the sector better

adapt to climate change.

Ensure R&D includes a horizontal theme of climate

change adaptation.


sediments



Changes to marine



objective.


objective.

N/A




recreation, etc)






Environmental data

collected through

operational permits

There is the potential for the siting of the hatchery

to result in negative impacts on other uses in the

area.

P

-/?

D

LT

A land-based hatchery may have negative effects

on other land uses in the area, depending on the

selected site.

Development of a hatchery must include consideration

of potential land use conflicts such that a thorough site

selection exercise should be carried out to minimise

potential conflicts. The hatchery and its management

will be subject to land use and possibly environment

permits to reduce impacts from waste.




remains








Depending on the chosen site for the hatchery,

potential impacts on cultural heritage may be

identified.

P

-/?

D

LT


on cultural heritage in the area, depending on the

selected site.

Site selection for the hatchery should be integrated into

the costings for project development. Site selection will

avoid or minimise the probability of significant negative

effects on cultural heritage. Where this is not possible,

any cultural heritage features should be designed into

the project as far as possible.


distinctiveness




Depending on the chosen site for the hatchery,

potential impacts on landscape may be identified.

P

-/?

D

LT


on landscape, depending on the selected site.

Site selection for the hatchery should be integrated into

the costings for project development. Site selection will

avoid or minimise the probability of significant negative

effects on landscape. The design phase should seek to

integrate the project into the existing landscape as far as

possible.

Aspect 8: Environmental monitoring

- It is recommended that a review of environmental monitoring methodology is carried out by an independent international authority with relevant expertise and that procedures are brought into line with guidance under development within the GFSM

workshops InDAM and SHoCMed.

- It is recommended that a consultative forum is established to develop formal vocational training programmes for Maltese aquaculture. This should involve industry representatives, training providers (e.g. MCAST and the Malta Qualifications Council.

99






environment




used for bait fish)


populations




in protected areas









Fishing


in wild populations

Although these are soft measures, standardisation

of environmental monitoring is expected to result in

indirect positive effects on biodiversity, assuming

remedial action is carried out imminently as and if

required.

Improvement in the establishment of environmental

carrying capacity at each site is also expected

through improved methodology.

P

+

I

LT

Although these are soft measures,

standardisation of environmental monitoring is

expected to result in indirect positive effects on

biodiversity, assuming remedial action is carried

out imminently as and if required.

As part of the Aquaculture Working Group identified

under Aspect 6, a mechanism should be in place to

ensure effective remedial measures are implemented as

required.

Monitoring results should directly feed into models

created to establish carrying capacity at various sites.









aquaculture



operational permit

requirements




positive effects on water quality and other

parameters, assuming remedial action is carried out

imminently as and if required.

P

+

D

LT



expected to result in positive effects on water

quality and other parameters, assuming remedial

action is carried out imminently as and if

required.




required.


environment


eutrophication











operations


loading



column






the seabed and from



activities





Framework Directive

(WFD).





imminently as and if required.

P

+

D

LT






required.




required.


aquaculture





objective.


objective.

N/A

Contributes to climate change Diversification of CCS in This aspect does not directly influence this 0 This aspect does not directly influence this N/A

100


adaptation the Maltese aquaculture

sector

objective. objective.


sediments



Changes to marine




positive effects on marine sediments and other


imminently as and if required and carrying capacity

is more accurately defined.

P

+

D

LT



expected to result in positive effects on marine

sediments and other parameters, assuming

remedial action is carried out imminently as and

if required and carrying capacity is more

accurately defined.




required.




recreation, etc)






Environmental data

collected through

operational permits





imminently as and if required thus ensuring waste

management practices are sustainable and

associated impacts are minimised. Results should

contribute to the establishment of carrying

capacities at each site.

P

+

D

LT






required thus ensuring waste management

practices are sustainable and associated impacts

are minimised. Results should contribute to the

establishment of carrying capacities at each site.




required.




remains









objective.


objective.

N/A


distinctiveness





objective.


objective.

N/A

Aspect 9: Fish health control

- It is recommended that disease control is strengthened through the development of Area Management Agreements (AMAs) between all operators in a zone or area.

- It is recommended that a contingency plan is prepared by Government and industry to deal with the possibility of a notifiable or other serious disease becoming established in Malta.

- In the event of increased production, the need for and delivery of an improved fish disease diagnostic capability, such as the one that used to be provided by the NAC, should be assessed.





environment




used for fishbait)




in protected areas









Fishing


in wild populations

Improvement in fish health control will minimise

risk of spread of disease to wild populations. The

use of chemicals requires strict management

because of potential impacts on the benthos.

Posidonia meadows are particularly sensitive to

chemical inputs (Commission, 2012)

P

+/-

I

LT

Improvement in fish health control will minimise

risk of spread of disease to wild populations.

However, chemical inputs must be strictly

managed on a site specific basis since certain

habitats are particularly sensitive to synthetic

compounds used in aquaculture.

The proposed R&D Centre should be aware of the

possibility of spreading of diseases between cultured and

wild fish and should establish or be part of a network of

other research centres in the region carrying out

studies/monitoring in this field. A contingency plan in

the case of an outbreak should consider ameliorating

potential negative effects on wild populations too.










operational permit

requirements


Assuming operators manage administration of

relevant products/agents correctly and according to

legislation, there should not be any significant effect

on this aspect.

0 Assuming operators manage administration of

relevant products/agent correctly and according

to legislation, there should not be any significant

effect on this aspect.

Implementation of this aspect must ensure compliance

with all relevant regulations.

Monitoring and auditing will be an important aspect in

reducing potential mismanagement of any chemicals

used.

101



aquaculture


environment


eutrophication











operations


loading



column






the seabed and from



activities





Framework Directive

(WFD).

Potential negative effects on water quality may

occur depending on treatments used.

P

-/?

D

LT

Potential negative effects on water quality may

occur depending on treatments used.

The contingency plan should ensure that any treatment

methods required to be used do not cause negative

environmental effects.

Monitoring and auditing will be an important aspect in

reducing potential mismanagement of any chemicals

used and ensuring negative effects are not accrued or

are minimised as far as possible.


aquaculture





objective.


objective.

N/A


adaptation



sector


objective.


objective.

N/A


sediments



Changes to marine


It is unlikely that this aspect would result in an

impact on sediments, however, depending on

treatments used, the possibility of contamination

should be considered.

? It is unlikely that this aspect would result in an

impact on sediments, however, depending on

treatments used, the possibility of contamination








recreation, etc)






Environmental data

collected through

operational permits

It is unlikely that this aspect would result in an

impact on other uses, however, depending on

treatments used, the possibility of conflict with

other marine uses, particularly recreational uses


? It is unlikely that this aspect would result in an

impact on other uses, however, depending on

treatments used, the possibility of conflict with

other marine uses, particularly recreational uses








remains









objective.


objective.

N/A

102



distinctiveness





objective.


objective.

N/A

Aspect 10: Socio-economic impacts

- A commitment to the development of the aquaculture industry is needed to ensure potential future gains in economic impact are realised. GVA from penned tuna has the potential to reach €21, €47 and €73 million in 2015, 2020 and 2025

respectively; whilst for Closed Cycle Species the equivalent figures could be €17, €26 and €46 million.

The way this Aspect is worded implies that the Strategy considers economic growth with no consideration to environmental sustainability. A similar situation is the first recommendation under Aspect 6, which seems to be

giving more importance to financial considerations than environmental aspects. Other areas of the Strategy consider aspects such as carrying capacity of sites, which is linked to environmental sustainability. The Strategy

should not omit consideration of environmental effects when considering its commitment to the development of the Strategy. Chapter 6 includes the Alternatives Assessment on the three production capacity scenarios

presented in the Strategy.

Aspect 11: Marketing

- Support should be given to companies keen to improve the marketing of their products especially with regard to provenance and certification.

- Market research should be conducted to identify specific opportunities for value-added products from Malta, considering the mix of product, target market and distribution logistics.

- It is recommended that marketing budgets are spent on researching customer needs, identifying competitive advantage and the supporting actions necessary to exploit these.

- With regard to amberjack, it is recommended that a marketing study be carried out to identify the product attributes likely to realise the best returns.

The Aspect deals with soft measures that do not have a direct bearing on the relevant environmental aspects.

Aspect 12: Improving the image of aquaculture

- In order to counteract negative views of aquaculture, compliance with both statutory operating conditions and a publicly available COGP should be demonstrated.

- All means of promoting the positive aspects of aquaculture and educating the public, including farm open days, school visits, and the use of aquaculture facilities as tourist attractions, should be utilised.

The Aspect deals with soft measures that do not have a direct bearing on the relevant environmental aspects.

103

SUMMARY OF THE ASSESSMENT

224. To summarise the assessment presented in Table 7.2, the Strategy presents a

number of recommendations that are expected to result in positive environmental

effects when compared to the Do-Nothing scenario. Such recommendations are

related mainly to the operation of the farms and the management of sites and include

the establishment of a CoGP for the industry, improvement of environmental

monitoring methodology, establishment of appropriate permit conditions related to

the feeding of tuna using baitfish, improved enforcement, establishment and

adherence to carrying capacity, etc. Such recommendations are expected to reduce

the negative effects that have been previously recorded from this industry, some of

which were most likely accrued mainly as a result of inexperience in the sector.

225. In terms of tuna penning, the Strategy requires tuna farms to be relocated to sites

with more than 50m water depth and more than 1nm from shore. This is also

expected to result in positive effects when compared to the baseline, although nearly

all existing tuna farms are already located in water depths of 50m or more. The re-

location to 1nm may mean only a small shift in the farms position of around 800m,

which in marine terms is only a small change. On the other hand, the situation

whereby existing farms are relocated to the south AZ or the proposed new North

AZ, would have a significant positive effect, especially where the inshore sites are

allowed to recover and are not (or not completely) re-used for CCS farming. The

assessment in Table 7.2 and the findings from Chapter 6, however, also highlight

that the Strategy does not clearly commit to the requirement for cages to be located

within established aquaculture zones73. As a result, there exists the possibility for

the creation of a number of new sites to accommodate individual operators. As

opposed to the use of one or two zones, this implies that a number of additional

sites would accrue impacts from the presence of aquaculture operations. 225. The

Strategy also seeks to encourage increased research and development, particularly in

the use of alternative species. Positive impacts could be attained particularly if

research efforts focus on the use of more sustainable species, e.g. molluscs,

herbivorous species, species for which the bait fish or raw materials of the aqua feed

are acquired from sustainable sources. Development of a land-based hatchery

should undergo relevant studies as appropriate including a site selection exercise and

environmental assessments as required by MEPA to ensure the minimisation or

elimination of any potential negative impacts.

226. The focus on environmental monitoring with a view to improving methodology is

expected to result in overall positive effects, and improved monitoring is expected to

improve the establishment and accuracy of proposed carrying capacities for each site.

The Strategy recognises that all farms should operate within the environmental

carrying capacity of the site in order to avoid extensive environmental damage. If

implemented to the extent that farms all operate within their site's environmental

73 During the formulation of the SEA the Strategy Proponent clarified that creation of aquaculture zones was

always the intent.

104

carrying capacity, and thus Environmental Quality Standards and Allowed Zones of

Effects will be determined, this is considered to provide a significant beneficial effect

when compared to historic operational management. In addition, the Strategy

provides a road map for implementation. This is considered to illustrate the

commitment of the Strategy proponent to ensure implementation.

227. At a strategic level, the main issue of concern emerging from this assessment (see

Chapter 6 and Chapter 7) lies with the decision in terms of the existing marine

sites to be taken up by new aquaculture activities. Chapter 6 recommends that the

Strategy should establish and justify in socio-economic and environmental terms

what the production target for the aquaculture industry is. This recommendation

emerges in particular because Production Capacity Scenario 3 includes a number of

sites which cumulatively provide a surplus capacity when compared to the highest

production scenario within the same strategy.

228. Chapter 8 summarises the recommendations, which are considered to contribute

to the mitigation of potential negative effects and improve the Strategy’s

environmental performance.

CUMULATIVE & SYNERGISTIC IMPACTS

229. Cumulative effects are those effects that result from incremental changes caused by

other past, present, or reasonably foreseeable actions together with the proposal.

Cumulative effects can result from individually minor but collectively significant

actions taking place over a period of time.

230. Synergistic effects interact to produce a total effect that is greater than the sum of

the individual effects.

231. Table 7.3 provides a general overview of the key issues identified for each

environmental topic considered within the assessment process.

Table 7.3: Summary of cumulative environmental effects of the Draft

Aquaculture Strategy

Environmental

Receptor Key impacts of the Draft Aquaculture Strategy

Biodiversity, Flora

and Fauna

Impacts on biodiversity, flora and fauna, as discussed in Table 7.2 are closely related to

where a marine aquaculture site is located and how the operation is managed. If the

site is appropriately located and the increased oxygen demand in the area does not

result in anoxic conditions (which then leads to effects on benthos diversity, species

composition, abundance, etc), and operates within its carrying capacity, negative effects

can be minimised. Location of sites is also important in relation to more sensitive

seabed communities such as Posidonia meadows and maerl beds. These areas should be

avoided and in the case of protected areas, conservation objectives and ensuring the

favourable conservation status of key species such as Posidonia is an important

consideration when granting permits for aquaculture zones. Increasing sites that would

be under pressure from aquaculture production could result in cumulative impacts that

could potentially be significant; these would be negative in case of inappropriate

operation such that oxygen depletion causes other effects (as described above).

105

Environmental


Improved site management, monitoring and enforcement of carrying capacities should

reduce the significance of negative effects. Zoning aquaculture in permitted zones

would also be considered beneficial.

Human health

Mismanagement of individual operations may affect human health in terms of the

chemicals administered for the culture of the organisms and in terms of other inputs to

the marine environment that may affect bathing water quality.




Water

As already described, impacts on the water column as a result of inputs and outputs

could result in indirect effects related to impacts on sediment and biodiversity.




Emissions to air

Odour is the main emission to air of concern. Odour issues coupled with aesthetic

impacts related to oil from bait fish as well as waste management problems can result in

cumulative negative effects that affect the population and its perception of the industry.




Climatic factors and

climate change

The ability of the industry to adapt to changes in the marine environment as a result of

climate change is considered to be important.

Aquaculture also has implications in terms of sourcing feed. The level of significance of

the effect from Malta would depend on its share of the market.

Marine sediments

Marine sediments act as a sink for nutrients and the organic inputs increases oxygen

demand, which in inappropriate sites and poor management will result in anoxic

conditions in the sediment; this results in secondary effects on the benthos community.

Additional sites where such impacts are accrued could result in significant negative

effects on the benthos, which could then result in other effects on the ecosystem.




Material assets and

population

Impacts on other users could result in significant negative effects if a number of users,

including users from different sectors are affected and particularly if popular sites are

also affected. This would be especially the case if a number of units are developed close

to each other.



106

Environmental



Cultural heritage

Impacts on cultural heritage are generally project specific. If a number of new sites are

developed, potential impacts on cultural heritage artefacts and possibly areas may be

affected. These would be site specific and dependent on findings from studies such as

EIA. Design can be such that impacts are avoided.

Landscape

Impacts on landscape would be accrued if new sites are introduced especially if these

are close to shore. Land based units could also potentially have landscape impacts

depending on their siting. Visual impacts from cages are considered to be limited.

107

CHAPTER 8: RECOMMENDATIONS

232. When considering the need for mitigation, a hierarchy of mitigation measures was

considered:

Avoiding the implementation of unsustainable actions;

Reducing the extent of unsustainable actions;

Remedying or compensating for any negative impacts by incorporating mitigation

measures into the actions to prevent or minimise the impacts; and

Enhancing positive impacts.

233. Potential mitigation measures for each of the draft Strategy Objectives are listed in

Table 7.2 above. In amending the draft Strategy, these should be considered. These

mitigation measures are discussed below.

Preferred alternative

234. As identified in Chapter 6, the Strategy discusses three production capacity

scenarios for Tuna and CCS. The proposed scenarios, in particular Scenario 3, could

potentially result in what is considered to be a significant negative effect related to

the extent of the proposed increase in sites along the eastern coast of Malta.

Production capacity scenario 3 is also well beyond the maximum targets stipulated in

Table 16 of the Strategy and is therefore not considered favourably in this SEA.

235. It is therefore recommended that the Strategy identifies a preferred growth option for the industry. The targets must be justified from a socio-economic and

environmental point of view. Once the production targets are established, it is

recommended that the Strategy clearly defines how it will allocate marine areas for

production. The SEA also considers that preference should be given to existing or

planned aquaculture zones to accommodate the targets. To date there is one existing

Aquaculture Zone in the south east of Malta with a capacity of 6,000 tonnes and the

Government is studying the setting up of another 6,000 tonne capacity aquaculture

zone in the north of Malta. Based on the maximum targets set out in Table 16 of the

Strategy, this is considered to present sufficient capacity for CBS.

236. Should the Strategy require additional capacity for CCS, it is recommended that farms are located within a designated aquaculture zone. To date there are no CCS

farms within a designated zone. As stated above and in Chapter 6 of the SEA,

consideration of all the areas 1 to 8 for aquaculture zones is likely to give rise to

significant environmental impacts. It is therefore recommended that the Strategy

clearly identifies search areas for the establishment of these zones.

237. The 8 areas described in Chapter 6 and presented in the Strategy can therefore be

considered as search areas for potential aquaculture zones. As stated above, the

industry does not require all 8 areas for production. The SEA therefore

recommends that some zones are given preference for further consideration as a

108

search area should they meet the following requirements:

Posidonia meadows should be avoided;

Maerl beds and other potentially sensitive benthic habitats should be avoided;

The presence of aquaculture should not negatively affect the conservation status

of any other important habitats/species; and

Zones should include existing permitted aquaculture sites.

238. From an environmental point of view, most of the search areas, except search areas

7 and 8, a prima facie present some degree of constraintbased on the criteria

described in Chapter 6. . It is moreover noted that conflicts with other uses may

be an issue for areas 7 and 8. Studies such as Appropriate Assessments, and

Environmental Impact Assessments would need to be carried out to identify best

sites.

239. Search areas, 1, 2, 3, 4 and 5 are all located, to varying extents, over sensitive benthic

habitats including Posidonia and maerl beds and Area 6 is located within 1nm. These

sites are therefore considered only suitable as search areas if the detailed studies for

areas, 7 and 8 show that none of these sites are suitable and the industry still needs

capacity in accordance with targets set in the strategy.

Improve sustainability of the sector

240. The Strategy includes a number of measures that will work towards sector

sustainability including research into the use of alternative feed for tuna, research into

alternative species for aquaculture, improved environmental monitoring,

establishment of EQSs and AZEs, etc. It is recommended that such measures are

given particular priority with the development of detailed action plans (also

recommended within the Strategy). Research should focus on seeking to move

towards alternatives including alternative species at lower trophic levels, species

where aquafeeds are from environmentally acceptable sources, etc.

Improve site specific management

241. The Strategy does seek to improve site management through a number of measures.

It is recommended that Environmental Management Plans (EMPs) would be drawn up

by each operator and implemented on site. These EMPs should be used as tools to

inform monitoring. EMPs should include measures addressing aspects such as waste

management including marine litter.

109

CHAPTER 9: MONITORING REQUIREMENTS

INTRODUCTION

242. Monitoring the environmental performance of the draft Aquaculture Strategy should

make it possible to identify corrective actions and to establish how well the

Aquaculture Strategy conforms to SEA objectives during implementation.

243. The European Commission Guidance suggests that SEA monitoring activities and

reporting can be integrated into the regular planning cycle, or may coincide with the

regular revision of a plan. Other SEA guidance indicates that the existing monitoring

arrangements of the plan and that undertaken for other plans can be used to obtain

the required information.

244. Monitoring significant environmental effects resulting from the implementation of the

Strategy is an important aspect of the SEA process.

245. The SEA objectives and indicators, outlined in Table 5.1 provide the most

appropriate tools for monitoring significant environmental impacts that may arise

from implementation of the Aquaculture Strategy. It is recommended that the

Aquaculture Strategy should include a monitoring framework. SEA monitoring can

be carried out as part of the Aquaculture Strategy's monitoring framework, where

possible. It is likely, however, that SEA monitoring will utilise data collected for the

purposes of monitoring the Aquaculture Strategy, where relevant, to avoid

duplication of effort.

246. Difficulties associated with monitoring include data collection itself.

Monitoring plan

247. Table 9.1 summarises the proposed monitoring plan of potential negative impacts

identified in Table 7.2.

248. Although positive impacts are expected from the Aquaculture Strategy, it is

recommended that these impacts are also monitored. Table 9.1 proposes a

monitoring plan for such impacts as well. Frequency of monitoring would depend on

how regularly data is collected, however, as a minimum should be mid-way through

Strategy implementation and at the end of the Strategy period.

110

Table 9.1: Monitoring plan

SEA Theme Potential cumulative significant

effects

Relevant Indicators (from Table

5.1)

Biodiversity, Flora and Fauna

Impacts on biodiversity, flora and fauna,

as discussed in Table 7.2 are closely

related to where a marine aquaculture

site is located and how the operation is

managed. If the site is appropriately

located and the increased oxygen

demand in the area does not result in

anoxic conditions (which then leads to

effects on benthos diversity, species

composition, abundance, etc), and

operates within its carrying capacity,

negative effects can be minimised.

Location of sites is also important in

relation to more sensitive seabed

communities such as Posidonia

meadows and maerl beds. These areas

should be avoided and in the case of

protected areas, conservation

objectives and ensuring the favourable

conservation status of key species such

as Posidonia is an important

consideration. Increasing sites that

would be under pressure from

aquaculture production could result in

cumulative impacts that could be

significant, these would be negative in

case of inappropriate operation such

that oxygen depletion causes other

effects (as described above). Careful

site selection and operation could

result in increased productivity;

however, given the possibility of

negative effects that could largely

impact communities, it is not

considered a reason to increase sites.

Aquaculture also has implications in

terms of sourcing feed. The level of

significance of the effect from Malta

would depend on its share of the

market.

Monitoring results from impacts

on the sea bed

Number of permitted sites in

protected areas



environment that may have been

introduced as a result of


Recorded disease outbreaks in

wild populations

Human health

Management of individual operations

may affect human health in terms of the

chemicals administered for the culture

of the organisms and in terms of other

inputs to the marine environment that

may affect bathing water quality.



operational permit requirements


Water As already described, impacts on the

water column as a result of inputs and Quality of the marine


111

outputs could result in indirect effects

related to impacts on sediment and

biodiversity.

benthos under cages and in the

vicinity of aquaculture

operations in accordance with

permit conditions


loading


litter in the water column



activities, by indicator species

(e.g. Caretta caretta)


litter collected from the seabed

and from beaches during

cleaning originating from


Quality of groundwater in the

vicinity of land-based


Maintaining ecological status in

accordance with the Water

Framework Directive.

.

Emissions to air

Odour is the main emission to air of

concern. Odour issues coupled with

aesthetic impacts related to oil from

bait fish as well as waste management

problems can result in cumulative

negative effects that affect the

population and its perception of the

industry.

Number of confirmed cases of

odour arising from aquaculture

activities

Climatic factors and climate

change

The ability of the industry to adapt to

changes in the marine environment as a

result of climate change is considered

to be important.

Number of CCS in the Maltese

aquaculture sector

Marine sediments

Marine sediments act as a sink for

nutrients and the organic inputs

increases oxygen demand, which in

inappropriate sites and poor

management will result in anoxic

conditions in the sediment; this results

in secondary effects on the benthos

community. Additional sites where

such impacts are accrued could result

in significant negative effects on the

benthos, which could then result in

other effects on the ecosystem.



Changes to marine sediments at

specific sites.

Material assets and population

Impacts on other users could result in

significant negative effects if a number Number of confirmed cases of

conflicts related to aquaculture

112

of users, including users from different

sectors are affected and particularly if

popular sites are also affected.

activities


Environmental data collected


Cultural heritage

Impacts on cultural heritage are

generally project specific. If a number

of new sites included, potential impacts

on cultural heritage artefacts and

possibly areas may be affected.

Number of operations located

away from cultural heritage sites

/ areas or areas with known

cultural / archaeological remains

as a percentage of the total


Landscape Impacts on landscape would be accrued

if new sites are introduced.


Assessment results on landscape

assessment

Other data sources

249. Besides using the above framework to gather data, other assessments both at project

and at planning level will likely gather monitoring data that can feed into the SEA

monitoring programme for the Aquaculture Strategy.

250. Projects developed through implementation of the Aquaculture Strategy that require

planning permission and possibly, depending on the project, an EIA, such as the

North AZ are likely to be monitored either through the EIA or by MEPA to ensure

permit conditions are being abided by. The information gathered can inform the

Aquaculture Strategy.

251. In order to ensure consistency the indicators identified above offer possible

monitoring criteria for future permits.

CONCLUSIONS & NEXT STEPS

252. Following consultation on the SEA and draft Aquaculture Strategy, changes may be

made to the draft Aquaculture Strategy before it is finally adopted. According to

Regulation 10 of the SEA Regulations, 2010 the responsible authority is required to

prepare a statement summarising how environmental considerations have been

integrated into the plan or programme and how the environmental report and the

opinions expressed by the public have been taken into account and the reasons for

choosing the Strategy as adopted, in the light of the other reasonable alternatives

dealt with.

113

Appendix 1:Scoping Report

Ministry for Resources and Rural Affairs

STRATEGIC ENVIRONMENTAL ASSESSMENT ON MALTA’S AQUACULTURE STRATEGY

SCOPING REPORT

Version 1: July 2012

Report Reference:

Adi Associates Environmental Consultants Ltd, 2012. Strategic Environmental Assessment on Malta’s Aquaculture Strategy. Scoping Report. San Gwann, July 2012; v + 25pp+1 Appendix.

THIS IS A DIGITAL COPY OF THE REPORT.

RESPECT THE ENVIRONMENT – KEEP IT DIGITAL

iii

This document has been prepared in accordance with the scope of Adi Associates’ appointment with its client and is subject to the terms of that appointment. It is addressed to and for the sole and confidential use and reliance of Adi Associates’ client. Adi Associates accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared and provided. Except as provided for by legislation, no person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior written permission of Adi Associates. Any advice, opinions, or recommendations within this document should be read and relied upon only in the context of the document as a whole. The contents of this document do not provide legal or tax advice or opinion. © Adi Associates Environmental Consultants Ltd 2012

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Quality Assurance Strategic Environmental Assessment on Malta’s Aquaculture Strategy Scoping Report July 2012 Report for: Ministry for Resources and Rural Affairs

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CONTENTS Introduction .................................................................................................................................................. 1 Strategic Environmental Assessment ...................................................................................................... 1 Malta’s Aquaculture Strategy .................................................................................................................... 2 The SEA Process ......................................................................................................................................... 5 Relation of the Aquaculture Strategy to Other National Documents & Legislation ................... 6 Baseline Data ................................................................................................................................................ 7 Evaluation of the Current Situation in the Absence of the Aquaculture Strategy ....................... 9 SEA Objectives ............................................................................................................................................ 9 Likely Significant Effects and Constraints ............................................................................................. 14 Cumulative & Synergistic Impacts .......................................................................................................... 17 Alternatives ................................................................................................................................................ 17 Proposed sites ............................................................................................................................................ 17 Proposed production capacities ............................................................................................................ 18 Monitoring .................................................................................................................................................. 24 Assessment Methodology ....................................................................................................................... 24 The Environment Report ........................................................................................................................ 24

FIGURES Figure 1: Existing and proposed new aquaculture sites ................................................................... 23

TABLES Table 1: Strategy recommendations ....................................................................................................... 4 Table 2: Environmental baseline .............................................................................................................. 8 Table 3: SEA Environmental Objectives & Indicators for Assessing Impacts ............................. 11 Table 4: Assessment legend ................................................................................................................... 14 Table 5: Example Strategy Assessment framework and format for environmental report .... 15 Table 6: Potential production capacity under different site availability scenarios ..................... 20 Table 7: Structure of the Environment Report ................................................................................. 25

APPENDICES

Appendix 1: Analysis of Related Plans, Programmes, and Legislation

1

SCOPING REPORT

INTRODUCTION 1. The Malta Aquaculture Research Centre (MARC) within the Ministry for Resources

and Rural Affairs (MRRA) contracted the development of an Aquaculture Strategy for Malta. The overall aim of the strategy was to provide a roadmap for sustainably developing aquaculture in Malta and to identify the aspects that are essential for a profitable and sustainable industry in Malta.

2. Screening of the Strategy determined that it qualifies for a Strategic Environmental Assessment (SEA) in accordance with Legal Notice 497 of 2010, the Strategic Environmental Assessment Regulations, 2010. In this regard, the SEA is being undertaken by Adi Associates Environmental Consultants Ltd. The Team is working closely with MARC and MRRA.

3. This is the Scoping Report for the Strategic Environmental Assessment (SEA) of Malta’s Aquaculture Strategy. The aim of the Report is to set out the framework for the SEA, including setting the context of the SEA, establishing the baseline, setting the SEA objectives and indicators for the assessment, and identifying any potential significant impacts of the aquaculture industry. The Report will also discuss the proposed contents of the Environmental Report and the next stages in the SEA process.

Strategic Environmental Assessment

4. European Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment requires that a SEA of a wide range of plans and programmes is carried out prior to the implementation of the plan or programme. The objective of the "SEA Directive" is to provide a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans with a view to promoting sustainable development. SEA comprises:

• Preparing an Environmental Report on the likely significant effects of the draft Strategy;

• Consulting on the draft Strategy and the accompanying Environmental Report;

• Taking into account the Environmental Report and the results of consultation in decision making; and

• A discussion of how the results of the environmental assessment would be taken into account in the Plan or Programme.

5. The information to be included in the Environmental Report includes:

• A description of the baseline environment;

2

• Links between the Strategy and other relevant policies, plans, programmes, and environmental objectives;

• An identification of existing environmental problems affecting the Strategy;

• The Strategy's likely significant effects on the environment, including issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climate, material assets, cultural heritage, landscape, and the interrelationship between such factors;

• The mitigation measures envisaged;

• A description of the alternatives considered and those discarded in favour of the selected action(s);

• Monitoring measures envisaged; and

• A non-technical summary.

6. The SEA Directive (2001/42/EC) has been transposed into national legislation by the SEA Regulations, 2010 (Legal Notice 497 of 2010).

7. Guidance on SEA for Malta has not yet been published. The Scoping Report therefore draws on other European Guidance namely, the GRDP’s (2006) “Handbook on SEA for Cohesion Policy 2007- 2013”, the Commission’s “Implementation of Directive 2001/42 on the Assessment of the Effects of Certain Plans and Programmes on the Environment” and the UK’s (2005) “A Practical Guide to the Implementation of the SEA Directive”.

Malta’s Aquaculture Strategy

8. “An Aquaculture Strategy for Malta: Preparatory study and recommendations prepared for the Ministry for Resources and Rural Affairs” (March 2012) sets out a strategy for the aquaculture sector in Malta, including the identification of a number of options for implementation. This document will hereafter be referred to as “the Strategy”.

9. Chapter 8 of the Strategy presents four strategic objectives and associated desired outcomes. These are:

• Improved regulation: Streamlined regulatory environment under one MRRA Directorate, with a clear policy on site locations, minimal conflict with other users, and standard conditions for all operators.

• Improved operation: Efficient, profitable farms operating according to the principles of best management practice, complying with their operating consents, causing no nuisance to other coastal users and with a positive public image.

• Improved environmental monitoring: A system that recognises the link between biomass and impacts, specifies limits to what constitutes adverse impact

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(Environmental Quality Standard - EQS), over what area such impacts are acceptable i.e., the Allowable Zone of Effect (AZE), and is proportionate, practical and cost effective.

• Better innovation: Facilities, funding and human resources to allow high quality applied research for the benefit of all industry operators.

10. In order to achieve these objectives, the Strategy suggests a number of recommendations under various aspects and proposes the development of Action Plans where relevant to ensure the realisation of the recommendations. The aspects identified and associated recommendations are summarised in Table 1.

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Table 1: Strategy recommendations Aspect 1: The Tuna Penning Sector Tuna farms on near shore sites should be relocated to sites with more than 50m water depth and more than 1nm from shore to limit impacts. Consideration should be given to restricting the feeding of baitfish to tuna cages during onshore wind conditions in the summer tourist season if alternative solutions are not found. A review of tuna offal disposal should be carried out. Aspect 2: The Sea Bream and Sea Bass Sector Sea Bass and Sea Bream will remain important species for the industry for the foreseeable future so account must be made of this in strategic planning. Aspect 3: Alternative Species The main emphasis with regard to development of alternative species should be on amberjack. A hatchery and spawning facility for amberjack, bluefin tuna and other species should be established at the earliest opportunity. Other species groups such as groupers, sparids, octopus and sea urchins may have potential for production in Malta in the future, and research into such species should be encouraged providing commercial potential can be demonstrated. Aspect 4: Identification of Sites and Potential Production Scenarios Additional marine sites will be needed for future expansion of the industry in both nearshore and offshore areas. Potential sites are proposed together with possible production scenarios in the Strategy. Aspect 5: Aquaculture Policy It is recommended that the 2004 policy document is updated to reflect the findings of this study, making sure that it reflects the needs of the industry and current issues, and taking into account the views of all stakeholders, especially the growers themselves. Aspect 6: Regulation Whilst the concept of zoning is desirable in principle for existing sites as well as new sites, it should only be pursued providing that operators are not financially or operationally disadvantaged and they are fully consulted. It is recommended that the minimum term for concessions is 25 years, or in accordance with normal commercial lease terms in Malta, subject to compliance with operating conditions. It is recommended that all tuna farms be located in more than 50m water depth and 1nm from shore, whilst CCS should mostly be in less than 50m water depth at varying distance from the shore. The present process by which farms are monitored and enforcement instigated should be reviewed and strengthened. The introduction of conditions regarding methods of feeding baitfish to tuna should be considered. The industry should be encouraged to prepare a COGP, if necessary supported by funding from the Government. MEPA must be made aware of the strategic intentions of the Government regarding the industry through a revised policy document based on the findings of this study. It is recommended that an appropriate individual within MEPA is trained as an aquaculture specialist to act as a liaison officer between MEPA and the industry. An Aquaculture Working Group made up of representatives from the industry, MEPA and MRRA should be established to address specific issues affecting the industry. Aspect 7: R&D A mechanism should be put in place to ensure regular (e.g. annual) reviews of research priorities and funding are carried out involving government, industry and academic stakeholders. Resources should be committed to the development and testing of alternative tuna feeds that reduce reliance on baitfish. The PPP model of R&D funding appears to be working well and should be developed further, although it must allow participation by all growers in Malta. The development of a new Marine Hatchery and R&D centre is a high priority under the aquaculture Strategy and full costings and a finance model, most likely using a PPP, should be developed as soon as a site has been agreed.

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Collaboration between MARC and the University of Malta and other institutions in the Mediterranean, whether to provide access to specialised research equipment or expertise is recommended. Aspect 8: Environmental Monitoring It is recommended that a review of environmental monitoring methodology is carried out by an independent international authority with relevant expertise and that procedures are brought into line with guidance under development within the GFCM workshops InDAM and SHoCMed. It is recommended that a consultative forum is established to develop formal vocational training programmes for Maltese aquaculture. This should involve industry representatives, training providers (e.g. MCAST) and the Malta Qualifications Council. Aspect 9: Fish Health Control It is recommended that disease control is strengthened through the establishment of Area Management Agreements (AMAs) between all operators in a zone or area. It is recommended that a contingency plan is prepared by Government and industry to deal with the possibility of a notifiable or other serious disease becoming established in Malta. In the event of increased production, the need for and delivery of an improved fish disease diagnostic capability, such as the one that used to be provided by the NAC, should be assessed. Aspect 10: Socio-economic Impacts A commitment to the development of the aquaculture industry is needed to ensure potential future gains in economic impact are realised. GVA from penned tuna has the potential to reach €21, €47 and €73 million in 2015, 2020 and 2025 respectively; whilst for Closed Cycle Species the equivalent figures could be €17, €26 and €46 million. Aspect 11: Marketing Support should be given to companies keen to improve the marketing of their products especially with regard to provenance and certification. Market research should be conducted to identify specific opportunities for value-added products from Malta, considering the mix of product, target market and distribution logistics. It is recommended that marketing budgets are spent on researching customer needs, identifying competitive advantage and the supporting actions necessary to exploit these. With regard to amberjack, it is recommended that a marketing study be carried out to identify the product attributes likely to realise the best returns. Aspect 12: Improving the image of aquaculture In order to counteract negative views of aquaculture, compliance with both statutory operating conditions and a publicly available COGP should be demonstrated. All means of promoting the positive aspects of aquaculture and educating the public, including farm open days, school visits, and the use of aquaculture facilities as tourist attractions, should be utilised.

THE SEA PROCESS 11. The first stage of the SEA process is scoping. This sets out the context for the

assessment and defines its scope. It is one of the most important stages in the process as it identifies the issues for consideration in the Environmental Report. Although no longer a legal requirement, it is considered good practice to clearly document the scoping process. Consultation on the draft Scoping Report has been undertaken with a number of identified stakeholders including the SEA Focal Point, the Malta Environment and Planning Authority, the Malta Resources Authority, the Department of Agriculture, the Department of Fisheries, and the Environmental Health Directorate. The Scoping Report has been amended to include comments that were received from these stakeholders.

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RELATION OF THE AQUACULTURE STRATEGY TO OTHER NATIONAL DOCUMENTS & LEGISLATION

12. Schedule 2 of the SEA Regulations requires a discussion of the “the degree to which the plan or programme sets a framework for projects and other activities, either with regard to the location, nature, size and operating conditions or by allocating resources” and “the relevance of the plan or programme for the implementation of Community legislation on the environment, such as plans and programmes linked to waste-management or water protection”. Appendix 1 provides a list of the policies, plans, and programmes relevant to the strategy, which have been analysed.

13. The analysis has been subdivided into four main categories:

(i) International Commitments: this category covers the international environment and sustainability policy framework within which Malta must work. It includes a selection of global commitments, such as those arising from the Millennium Development Goals (MDGs), UN Framework Convention on Climate Change (UNFCCC) and Kyoto Protocol.

(ii) EU requirements: Relevant EU communications specifically concerning fisheries and aquaculture have been included. In the case of European Union Directives already transposed into national legislation, the Directives per se will not be discussed; the section on national legislation is described below;

(iii) National Environmental & Planning Documents including the Structure Plan for the Maltese Islands, the draft National Sustainable Development Strategy, and the National Reform Programme. The review provided herein summarises the key issues raised; further information can be obtained from the original documents;

(iv) National Sectoral Policies and Strategies: this section covers highest-level policy and strategy documents published by the Government, such as the National Strategic Plan. Rather than summarise entire documents this review seeks to emphasise the key sustainability objectives and priorities;

(iv) National legislation: no attempt will be made to assess the individual regulations, as is done at the project level EIA (Environmental Impact Assessment). However, the main areas of concern for the Strategy will be highlighted. Given the scale (and evolutionary nature of this field) this review is not exhaustive and represents a current (May 2012) snapshot.

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BASELINE DATA 14. A good understanding of the environment of the areas covered by the SEA is

essential for the performance of a sound assessment. It is therefore necessary to establish the environmental baseline relevant to the plan or programme being proposed. This provides a snapshot of the existing state of the environment and a description of the likely future trends (based on past trends) without the programme being in place.

15. Existing environmental and sustainability data will be collected from a wide range of sources. Table 2 summarises this broad-brush description. The list is not exhaustive, and may be modified in the Environmental Report. It will also depend on the availability of data.

16. The Sustainable Development Strategy 2006 – 2016 identifies Malta's environmental challenges; it arises from a systematic review of official reports including the State of the Environment Report (1998, 2002, and 2005) and Malta's National Report to the World Summit on Sustainable Development (2002), and an extensive consultation process. The later National Environment Policy (2012) identifies Malta’s Environmental Objectives.

17. The following environmental parameters were identified:

• Air quality;

• Climatic factors and climate change;

• Energy-efficiency and renewable energy resources;

• Biodiversity including the marine environment;

• Freshwater;

• Waste;

• Land use;

• Soils;

• Landscape;

• Cultural heritage;

• Population and human health; and

• Material assets.

18. The SEA baseline will focus on the parameters listed under Schedule 1(f) of the SEA Regulations, 2010 - Information to be included in the Environmental Report.

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19. Table 2 shows how the Environment Report will draw together the issues and baseline data. Sources of information included the statistics produced by the National Statistics Office, the State of the Environment Report, 2005 (and subsequent updates) and the documents prepared in connection with the Structure Plan Review process. As the Environmental Report is developed the baseline may be modified to reflect available and other relevant data.

Table 2: Environmental baseline Issue Relevant baseline data Illustrative material Emissions to air and climate change

• GHG inventory (if relevant) • Odour emissions from the

sector • Coastal erosion, sea level rise,

changing weather patterns resulting from climate change

Graphs and figures.

Biodiversity / fauna and flora • Areas protected and managed under international and local legislation;

• Areas known to support priority Annex I habitats under the Habitats Directive

• Protected species; • Areas for which surveys have

been carried out; • Potential new marine

conservation areas

Designated, managed and surveyed areas; where relevant, any data related to areas, habitats and/or species that are not formally protected although they are considered to be of conservation value, will be included

Water • Information on the quality of the marine environment

• Information on groundwaters • Water Framework Directive

targets, objectives, protected areas

Maps / graphs / tables

Soil • Marine sediments

Published data and figures

Landscape • Areas protected for landscape value

Landscape sensitivity areas and protective designations

Cultural heritage • Sites protected for cultural heritage

Maps

Human health • Environmental health data (where available);

• Water users; • Consumers of fish and

aquaculture products • Information on fish health (if

available)

Graphs and tables Published data

Material assets and population • Commercial fishing/aquaculture activities;

Maps / figures

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• Waste management infrastructure;

• Coastal and marine based tourism interests/attractions;

• Sea uses

20. Quantitative data will be presented in the form of maps, tables, and figures, where possible. A brief description of the baseline and any trends will be given, where these are available. Where difficulties in obtaining data are encountered they will be described in the Environment Report.

EVALUATION OF THE CURRENT SITUATION IN THE ABSENCE OF THE AQUACULTURE STRATEGY

21. The SEA Regulations require a description of the relevant aspects of the current state of the environment and the likely evolution thereof without the implementation of the policy document with a particular emphasis on the future developments arising from other relevant plans and programmes.

22. This analysis will focus on the main environmental issues that have been identified in Table 2. It will include a description of the past and current trends from data available from existing monitoring systems or through expert judgements (in cases where data are lacking). It will also outline the likely evolution of these trends, if the Aquaculture Strategy were not implemented.

23. The description of the likely future trends should the Aquaculture Strategy not be implemented is constrained by uncertainties, including availability of data on future economic development, technological progress, or advancements in regulatory frameworks that collectively influence future trends. The assessment will include a list of major uncertainties.

SEA OBJECTIVES 24. The SEA Directive does not specifically require the use of objectives or indicators in

SEA, although they are a recognised way through which environmental effects can be described, analysed, and compared.

25. It is therefore preferable to use indicators to monitor the performance of the policy against the SEA objectives. The SEA objectives are meant to be separate from the policy objectives, and provide a way to assess the potential environmental performance of the policy objectives. Thus, the environmental objectives should influence the policy objectives, and the two may even overlap. To fulfil the requirements of the SEA Directive and the SEA Regulations, 2010, the SEA objectives must cover biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage, landscape, and interrelationships between them.

26. In developing appropriate objectives, the following documents have been consulted:

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• GRDP’s Handbook on SEA for Cohesion Policy 2007- 2011;

• The Commission’s “Implementation of Directive 2001/42 on the Assessment of the Effects of Certain Plans and Programmes on the Environment”;

• A Practical Guide to the Implementation of the SEA Directive, ODPM

• The SEA Directive 2001/42/EC; and

• SEA Regulations, 2010.

27. In developing appropriate indicators the following documents have been consulted:

• National Environment Policy, 2012;

• The Sustainable Development Strategy for the Maltese Islands, 2006-2016; and

• Malta’s State of the Environment Report, 2005 and subsequent updates.

28. Table 3 defines the set of objectives relating to the environmental issues identified in Table 2. Alongside these, relevant criteria for assessment and possible data sources have been identified.

29. The SEA indicators are measurements of trends over time. They will be used as a means of ascertaining the success of implementation of the Aquaculture Strategy against the various SEA Objectives. Where possible the SEA process endeavours to identify how the Aquaculture Strategy would affect these indicators (i.e. the trends); such a process is constrained by the fact that the SEA indicators themselves depend on other factors outside the control of the Aquaculture Strategy.

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Table 3: SEA Environmental Objectives & Indicators for Assessing Impacts Issue SEA Objective

Criteria Will this measure…


Biodiversity, Flora & Fauna

• Maintain biodiversity (including terrestrial and marine)

• Avoid introduction of non-indigenous species into the natural environment

• Populations of fish species taken from the wild (including species used for fish bait) are within safe biological limits

• Avoid negative effects on wild fish populations

• Help to maintain or enhance the conservation of designated areas (under both the Development Planning Act, and the Environment Protection Act)?

• Negatively affect protected species and habitats?

• Risk introduction of non-indigenous species into the marine environment?

• Result in unsustainable exploitation of wild stocks?

• Impact negatively wild fish populations (e.g. through spread of disease)?

• Monitoring results from impacts on the sea bed

• Number of permitted sites in protected areas

• Records of non-indigenous species in the natural environment that may have been introduced as a result of aquaculture activities

• Quotas, in particular those set by ICCAT and whether these are exceeded

• Recorded disease outbreaks in wild populations

Environmental monitoring through Environmental Impact Assessment (EIA), Appropriate Assessment (AA), or other regulatory requirements as relevant. Malta Centre for Fisheries Science (MCFS)/MARC Malta Environment and Planning Authority (MEPA)

Human health • Ensure aquaculture products are within the legal safety requirements (antibiotic resistance, possible contamination and bioaccumulation of chemicals, microbial agents and toxins) for human consumption

• Ensure bathing water quality does not deteriorate as a result of aquaculture

• Ensure safe consumption of aquaculture products?

• Ensure that bathing water quality does not deteriorate as a result of aquaculture?

• Analyses and test results as required by legislation / operational permit requirements

• Bathing water quality results

Malta Competition and Consumer Affairs Authority (MCCAA), Malta Centre for Fisheries Science/MARC, MEPA, MHECC

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Issue SEA Objective



Water • Minimises pollution on the marine environment

• Avoids contribution to eutrophication

• Sea-floor integrity is maintained

• Avoids generation of litter

• Minimise pollution on groundwater from activities directly arising from the aquaculture sector

• Avoids deterioration of water bodies

• Help to minimise discharges to water?

• Avoid nutrient concentration and loading?

• Avoid changes to the seabed that may affect the integrity of the benthos habitat?

• Ensure good management practices that avoid litter generation?

• Help to maintain and enhance Malta’s groundwater, inland surface waters and coastal waters?

• Quality of the marine environment including the benthos under cages and in the vicinity of aquaculture operations

• Nutrient concentration and loading

• Marine litter in the water column • Ingested marine litter identified as

originating from aquaculture activities by indicator species (e.g. Caretta caretta)

• Marine litter collected from the seabed and from beaches during cleaning originating from aquaculture activities

• Quality of groundwater in the vicinity of land-based aquaculture operations

• Compliance with the Water Framework Directive (WFD).

MEPA, potential permit requirements (i.e. aquaculture operators) , MTA (beach cleaning), Department of Veterinary services (carrying out post mortems on Loggerhead Turtles).

Emissions to air • Ensure no odour nuisance from aquaculture

• Cause odour nuisance? • Number of complaints related to odour from aquaculture operations

MEPA, MRRA

Climatic factors and climate change

• Contributes to climate change adaptation

• Contribute to climate change adaptation?

• Diversification of CCS in the Maltese aquaculture sector

MARC

Soil/seabed • Avoid contamination of marine sediments

• Avoid physical changes to marine sediments

• Help to maintain and conserve marine sediments?

• Contamination of marine sediments at specific sites;

• Changes to marine sediments at specific sites.

Environmental monitoring as part of permit conditions i.e. from farm operators, MEPA, Malta Centre of Fisheries/MARC.

Material assets and Population

• Ensure no conflict between aquaculture

• Be compatible with other uses in the area?

• Number of complaints (e.g. from noise and odours) related to

MEPA, aquaculture operators, MARC

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Issue SEA Objective



and other uses (e.g. tourism, recreation, etc)

• Sustainable waste management

• Implement sustainable waste management practices?

aquaculture activities • Bathing water quality results • Environmental data collected


Cultural heritage • Maintain the conservation status of cultural heritage sites / areas with known cultural / archaeological remains

• Help to preserve, enhance and promote cultural heritage including archaeological heritage?

• Avoid negative impacts on cultural heritage features/archaeology?

• Number of operations located away from cultural heritage sites / areas or areas with known cultural / archaeological remains as a percentage of the total number of operations

MEPA, Resources Management Unit Heritage Malta Superintendent of Cultural heritage

Landscape • Maintain landscape quality distinctiveness

• Help to maintain landscape quality distinctiveness?

• Environmental Impact Assessment results on landscape assessment

MEPA

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LIKELY SIGNIFICANT EFFECTS AND CONSTRAINTS 30. Significance will also be assessed in accordance with the criteria listed in Schedule 4

of the SEA Regulations, 2010. Consultation will ensure that all factors are considered. Reference documents will include the National Environment Policy, Sustainable Development Strategy and the State of the Environment Report, 2005 (and subsequent updates). Subsequent sections further describe how impacts will be assessed.

31. The assessment of significance is already well established in Environmental Impact Assessment (EIA) literature. Significance is a function of impact magnitude and the sensitivity of receptors. Various methods can be used to determine significance including expert judgements, the use of thresholds, reference to legislation, and consultation with stakeholders. It is expected that, in the course of the SEA process, all these techniques will be used.

32. The assessment of significance is based on the probability of the impact occurring, on the scale of the impact, its duration, reversibility, whether it has transboundary impacts, and whether the impact is uncertain. Table 4 describes the assessment framework and the symbols used to denote the various types of impact.

33. The relevant SEA objectives identified in Table 3 will then be used to assess the Strategy Aspects and recommendations in accordance with the significance criteria described in Table 4. It is proposed to present the results of the assessment in the format indicated in Table 5.

Table 4: Assessment legend Impact character Symbol Description of Impact Probability VP Impact very likely to occur

P Impact likely to occur Scale ++ Large positive impact

+ Positive impact 0 No impact - Negative impact -- Large negative impact

Direct / Indirect I Indirect impact D Direct impact

Frequency / duration LT Long term ST Short term

Transboundary dimension TR Possible transboundary effect Uncertainty ? Impact uncertain

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Table 5: Example Strategy Assessment framework and format for environmental report Relevant SEA Aspect

SEA Objectives Indicator Comment

Significance Mitigation Symbols Summary description

STRATEGY ASPECT 1: The Tuna penning sector Tuna farms on near shore sites should be relocated to sites with more than 50m water depth and more than 1nm from shore to limit impacts. Consideration should be given to restricting the feeding of baitfish to tuna cages during onshore wind conditions in the summer tourist season if alternative solutions are not found. A review of tuna offal disposal should be carried out.

Biodiversity, Fauna & Flora

• Maintain biodiversity (including terrestrial and marine)

• Avoid introduction of non-indigenous species into the natural environment

• Populations of fish species taken from the wild (i.e. where the production cycle is not a closed one) are within safe biological limits

• Number, % cover, and area of protected areas

• Designated areas that are subject to formal management arrangements

• Records of non-indigenous species in the natural environment that may have been introduced as a result of aquaculture activities

• Quotas, in particular those set by ICCAT and whether these are exceeded

What is the potential impact?

Impact assessment in accordance with the criteria listed in Table 4

Justification of the impact assessment

Description of mitigation measures, if these are necessary

STRATEGY ASPECT 2: The Sea Bream and Sea Bass sector

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Cumulative & Synergistic Impacts 34. This stage of the process involves an assessment of the cumulative and synergistic

effects of all proposed priorities in the Aquaculture Strategy on the relevant environmental issues, objectives, and indicators. Cumulative effects are effects that result from incremental changes caused by other past, present, or reasonably foreseeable actions together with the proposal. Cumulative effects can result from individually minor but collectively significant actions taking place over a period of time.

35. Synergistic effects interact to produce a total effect that is greater than the sum of the individual effects. Synergistic effects often happen as habitats or human communities begin to reach carrying capacity and/or non renewable resources are depleted unsustainably.

36. The cumulative and synergistic impact assessment will be based on the information generated by the preceding assessments (described above) of the individual priorities. Any identified cumulative and synergistic effects will be summarised and used as recommendations for final adjustments to the programming document.

ALTERNATIVES 37. The SEA Directive requires that an assessment must identify the likely significant

effects on the environment of implementing the plan or programme, and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme.

38. The Strategy proposes possible new alternative aquaculture zone sites (see Figure 1) and includes reference to limitations of each alternative. Alternative production capacity scenarios, which are linked to sites in terms of their carrying capacity, are also presented. The Environmental Report will include an assessment of the alternative sites and production scenarios presented in the Strategy.

Proposed sites

39. The alternatives identified in the Strategy are the following:

• North-East coast:

o Area 1: North Aquaculture Zone (AZ) area1;

o Area 2: Extension to area east of St Paul’s Islands;

o Area 3: Area just outside 1nm limit; and

o Area 4: North of St George’s Point, close to the Madalena shoals. 1 It is noted that the Strategy has not yet been updated following a site selection exercise that was carried out for the North Aquaculture Zone.

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• South-East coast:

o Area 5: South-East of the Sewage Treatment Plant at Xghajra;

o Area 6: Off St Thomas Point;

o Area 7: Area located approximately halfway between the existing AZ and the coast; and

o Area 8: Inclusion of existing operations in the south within an extended AZ area.

Proposed production capacities

40. The following three production capacity scenarios2 are presented in the Strategy as alternative options.


41. This option largely reflects the status quo and permit conditions for existing sites, with no new areas allocated except for extension of sites G and H (see Area 8 in Figure 1) to allow tuna to be moved further offshore. In summary, this option considers the following:

• No North AZ;

• All existing sites retained;

• Such sites used for CCS with exception of SE Zone and AJD site E (see Area 2 in Figure 1);

• CCS capacity for sites A, G and H based on original PDG guidelines of 500t/site;

• P2M sites unchanged;

• Nursery production at Marsaxlokk site I;

• New outer site G for tuna 2km from shore, 1,500t (assumes shift in BA 4);

• New outer site H for tuna 2km from shore, 1,500t (assumes shift in BA 4); and

• Other tuna capacity as per current ICCAT permits.


2 The Strategy makes a distinction between production capacities and production targets. The SEA will assess capacities as a worst case scenario.

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43. This option is based on current policy intentions, for instance, to move existing cages away from Comino to a new NE Aquaculture Zone, and move tuna production from sites G and H (see Figure 1). In summary, this option includes the following:

• North AZ approved;

• Assumes Comino site is exchanged for 2,000 production in North AZ;


• Other existing sites used for CCS with exception of South AZ and site E;

• AJD site E remains for tuna (permit not as flexible as for F&F and MFF sites G and H);

• CCS capacity 1,000t/site;

• Tuna capacity as per current ICCAT permits;


• New outer site G for tuna 2km from shore, 1,500t (assumes shift in BA 4); and

• New outer site H for tuna 2km from shore, 1,500t (assumes shift in BA 4).



45. Option 3 considers the retention of all existing sites, development of all potential new sites, and all tuna farms are moved further offshore. In summary:

• All existing sites retained;

• North AZ approved;


• Newly identified sites approved;

• Inshore sites i.e. <1nm from shore/50m depth, used only for CCS;

• Tuna farms at E, G and H moved further offshore;

• Area around site E (E2, see Figure 1) used for 2 x 1,000 CCS sites;

• CCS capacity 1,000t/site;

• Tuna capacity as per current ICCAT permits;

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• New nursery production at Xghajra sites U and V (see Figure 1);

• New outer site G for tuna 2km from shore, 1,500t (assumes shift in BA 4); and

• New outer site H for tuna 2km from shore, 1,500t (assumes shift in BA 4).


47. Table 6 summaries the potential production capacity scenarios under different site availability scenarios.

Table 6: Potential production capacity under different site availability scenarios Capacity 1 Capacity 2 Capacity 3 Site Location Tuna CCS Tuna CCS Tuna CCS Existing Sites A AJD

Comino 500 1,000

B-D P2M 1,000 1,000 1,000 E AJD St

Paul’s Bay 2,500 2,500 2,000

F South AZ 6,000 6,000 6,000 G MFF

Munxar 500 1,000 1,000

H F&F Il-Hofra

500 1,000 1,000

I MARC Total 8,500 2,500 8,500 3,000 6,000 6,000 Potential New Sites G outer MFF

Munxar 1,500 1,500 1,500

H outer F&F Il-Hofra

1,500 1,500 1,500

J outer North AZ-inner

1,000 1,000

K North AZ-inner

1,000 1,000

L North AZ-inner

1,000

M North AZ-inner

1,500

N North AZ-inner

1,500

O E Zone 1,500 P E Zone 1,500 Q E Zone 1,500 R E Zone 1,000 S E Zone 1,000 T Madalena

Shoals 1,000

U Xghajra Nursery

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Capacity 1 Capacity 2 Capacity 3 Site Location Tuna CCS Tuna CCS Tuna CCS V Xghajra Nursery W San Tumas

Point 1,000

X New SE Zone

1,000

Y New SE Zone

1,500

Z New SE Zone

1,000

Z1 New SE Zone

1,500

Total 3,000 0 3,000 2,000 13,500 9,000 Total all sites

11,500 2,500 11,500 5,000 19,500 15,000

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Figure 1: Existing and proposed new aquaculture sites

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MONITORING 48. The Environmental Report will include a section that describes how the success of

the Aquaculture Strategy’s implementation will be measured with respect to the SEA objectives, by measuring (monitoring) the significant effects of the Aquaculture Strategy on the environment.

49. The SEA will assess the monitoring arrangements proposed for the Aquaculture Strategy and may recommend incorporation of new indicators based on the relevant environmental issues, objectives, and indicators for the programming document.

50. Again, it is noted that the correlation between indicators for monitoring and the Aquaculture Strategy objectives may be constrained because indicators may be affected by other initiatives, including private sector initiatives, other plans and programmes, and legislative measures that are outside the scope of the Aquaculture Strategy.

ASSESSMENT METHODOLOGY 51. The SEA on the Aquaculture Strategy for Malta started in May 2012, after Adi

Associates Environmental Consultants Ltd were awarded the tender to carry out this SEA through a competitive tender procedure administered by the Ministry for Resources and Rural Affairs.

52. The SEA involves several key stages:

• The scoping stage aimed to agree the scope and level of detail of information which must be included in the environmental report. A meeting was held with the programme managers on 30th April 2012.

• The collection of baseline data and analysis of relevant plans, programmes, and environmental objectives has already commenced. The Consultants are collecting baseline data from a wide range of sources, including studies of the key growth areas, and analysing a wide range of plans/programmes/objectives using matrices to structure the data collection. Maps of key environmental issues are being prepared.

• Preparation of the Environment Report – this commences once all relevant information is collected and following consultation with the stakeholders, MEPA, and the Programme Manager.

THE ENVIRONMENT REPORT 53. The proposed structure of the Environment Report is as set out in Table 7. It is

noted that as the Report develops the structure may change slightly; however, the following table gives the general framework. It is in accordance with the provisions of Schedule 1 of the SEA Regulations, 2010.

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Table 7: Structure of the Environment Report Section Content Summary and outcomes

Non-technical summary Statement on the difference the process has made Directions on how to comment on the assessment

Introduction Strategic environmental assessment (compliance with the SEA Regulations, 2010) Aim and structure of the report Strategy background

Methodology Approach adopted Stages of SEA process (timings and responsibilities) Limitations Consultation

Baseline The environmental baseline Summary of environmental issues Links to other relevant policies, plans, programmes

SEA framework Objectives and indicators Assessment of significance

Assessment of alternatives Alternatives considered Comparison of alternatives Consideration of environmental issues in development of alternatives Preferred alternative (including reasons for rejection of others)

Detailed Assessment of the Aquaculture Strategy

Assessment of each Strategy Aspect Recommendations Recommended changes to the Aquaculture Strategy Proposed mitigation Uncertainties and risks

Monitoring proposals A description of the monitoring requirements Appendices As necessary

Appendix 1: Analysis of Related Plans, Programmes, and Legislation

Plan, Programme, Legislation

Description Implications for Aquaculture Strategy

1. International Commitments The UN Millennium Declaration and Millennium Development Goals (MDGs)

The United Nations Millennium Declaration arose from the meeting of UN Heads of State in New York, September 2000. The Declaration was aimed at revitalising international efforts to tackle critical development issues, and led to agreement on, and adoption of, the eight Millennium Development Goals (MDG). Of relevance to the SEA is the seventh MDG: ensure environmental sustainability.

This is a national commitment and the Strategy must play a role in its realisation.

UN Framework Convention on Climate Change

The ultimate objective of this Convention, and any related legal instruments that the Conference of the Parties may adopt, is to achieve stabilisation of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system. Such a level should be achieved within a timeframe sufficient to allow ecosystems to adapt naturally to climate change, to ensure that food production is not threatened, and to enable economic development to proceed in a sustainable manner. Malta is not an Annex 1 country, which means that it does not have to meet quantified targets for a reduction in greenhouse emissions. It does, however, support efforts to reduce greenhouse gas emissions and is bound by EU legislation.

The Strategy should be aware of Malta’s efforts to combat and adapt to climate change and encourage efforts to reduce emissions. The SEA proposes indicators related to climate change.

Bern Convention on the Conservation of European Wildlife and Natural Habitats (1979)

Malta is a party to the Bern Convention. The Convention aims to ensure conservation of wild flora and fauna species and their habitats. Special attention is given to endangered and vulnerable species, including endangered and vulnerable migratory species specified in appendices. The Parties to the Convention must undertake to take all appropriate measures to ensure the conservation of the habitats of the wild flora and fauna species. Such measures should be included in the Parties’ planning and development policies and pollution control, with particular attention to the conservation of wild flora and fauna. They should also undertake to promote education and disseminate general information concerning the need to conserve species of wild flora and fauna and their habitats.

The Strategy should be aware of the endangered and vulnerable species of flora and fauna in Malta and ensure that the Strategy is not in conflict with measures for their protection and conservation and those of their habitats. This will be done through the assessment of the Strategy using the SEA objectives on biodiversity.

The United Nations Convention on the Law of

The ability to deploy and utilise installations or structures in the marine environment is essentially one of property rights. The basis of ownership

The Strategy must ensure to integrate and/or consider the relevant requirements contained in this Convention



the Sea, 1982 and property rights within the marine environment emanates from the provisions of the United Nations Convention on the Law of the Sea, 1982 (UNCLOS). UNCLOS came into force on 16th November 1994 and among its provisions, it conveys rights to coastal states3, while imposing certain duties, among which is environmental protection4 and safety to navigation. UNCLOS establishes the legal status of the territorial sea, of the air space over the territorial sea and of its bed and subsoil. It also sets down rules for the passage of ships through the seas and distinguishes between passenger ships, commercial ships and warships. Article 56, Part V establishes the rights, jurisdiction and duties of the coastal State in the exclusive economic zone, stating that:

1. In the exclusive economic zone, the coastal State has:

including those related to waste management, marine pollution and conservation of living resources. This will be assessed in the Environment Report.

3 Article 56

In the exclusive economic zone, the Coastal State has: (a) sovereign rights for the purpose of exploring and exploiting, conserving and managing the natural resources, whether living or non-living, of the waters

superjacent to the seabed and of the seabed and its subsoil, and with regard to other activities for the economic exploitation and exploration of the zone, such as the production of energy from the water, currents and winds;

(b) jurisdiction as provided for in the relevant provisions of this Convention with regard to: (i) the establishment and use of artificial islands, installations and structures; (ii) marine scientific research; (iii) the protection and preservation of the marine environment;

(c) other rights and duties provided for in this Convention. 4 Article 194(1)

States are required to take “…all measures consistent with [the] Convention that are necessary to prevent, reduce and control pollution of the marine environment from any source”.



(a) Sovereign rights for the purpose of exploring and exploiting, conserving and managing the natural resources, whether living or non-living, of the waters superjacent to the seabed and of the seabed and its subsoil, and with regard to other activities for the economic exploitation and exploration of the zone, such as the production of energy from the water, currents and winds;

(b) Jurisdiction as provided for in the relevant provisions of this Convention with regard to: (i) The establishment and use of artificial islands, installations and

structures; (ii) Marine scientific research; (iii) The protection and preservation of the marine environment;

(c) Other rights and duties provided for in this Convention. Within harbour areas, the placing of any sort of installation, even moorings, falls under the jurisdiction of harbour authorities (in Malta’s case, Transport Malta), whose permission is required prior to the placing of any such structures (see National Legislation below). The Convention defines “pollution of the marine environment” as “introduction by man, directly or indirectly, of substances or energy into the marine environment, including estuaries, which results or is likely to result in such deleterious effects as harm to living resources and marine life, hazards to human health, hindrance to marine activities, including fishing and other legitimate uses of the sea, impairment of quality for use of sea water and reduction of amenities”. However, it excludes from its definition of “dumping” the disposal of wastes derived from the normal operations of ….other man-made structures at sea and their equipment. Hence, operational wastes generated by fish farms are likely to be exempted from the provisions of this Convention. This was further elaborated upon by the London Dumping Convention’s 1996 Protocol (see below). Other relevant aspects of the Convention include the provisions on



Conservation and utilisation of living resources (Arts 61 and 62), Highly migratory species (Art 64), Conservation and Management of Living Resources of the High Seas (Section 2 – Arts 116 – 119), Protection and Preservation of the Marine Environment (Part XII Arts 192-196), and EIA (Art. 206). Article 61 focuses on the conservation of living resources and calls on coastal states to determine the allowable catch of the living resources in their EEZ, in the process ensuring (through sound scientific evidence) that they are not endangered through over-exploitation and to restore or maintain populations of harvested species at levels that can produce the maximum sustainable yield. This is further expounded upon in Article 62, which promotes the objective of optimum utilisation of the living resources in the EEZ, including the possibility of a state entering into agreements with other states to harvest the surplus of its allowable catch. Highly migratory fish stocks are the subject of Article 645, which calls for cooperation among states fishing for such resources. The Atlantic Bluefin Tuna (Thunnus thynnus), and swordfish Xiphias gladius are listed in Annex 1 of the Convention. The conservation and management of the living resources of the high seas

5 Article 64:

1. The coastal State and other States whose nationals fish in the region for the highly migratory species listed in Annex I shall cooperate directly or through appropriate international organizations with a view to ensuring conservation and promoting the objective of optimum utilization of such species throughout the region, both within and beyond the exclusive economic zone. In regions for which no appropriate international organization exists, the coastal State and other States whose nationals harvest these species in the region shall cooperate to establish such an organization and participate in its work.

2. The provisions of paragraph 1 apply in addition to the other provisions of this Part.



are dealt with in Section 2 of Part VII. Articles 116 to 119 set out the rights and obligations of fishing on the high seas. Of importance is the fact that the Convention calls for cooperation among states whose nationals engage in fishing on the high seas to cooperate in the conservation of these living resources, including the establishment of regional and sub-regional fisheries organisation (such as ICCAT and GFCM), and to be guided by scientific evidence in establishing allowable catch quotas. The protection of the marine environment is addressed in Part XII of the Convention. States have the obligation to protect and preserve the marine environment. With regards to marine pollution States are to take “all measures consistent with this Convention that are necessary to prevent, reduce and control pollution of the marine environment from any source, using for this purpose the best practicable means at their disposal and in accordance with their capabilities, and they shall endeavor to harmonize their policies in this connection”. The Convention applies to all sources of pollution including the release of toxic, harmful or noxious substances, pollution from vessels, and pollution from installations and devices operating in the marine environment. The measures taken to prevent pollution should include those necessary to protect and preserve rare or fragile ecosystems as well as the habitat of depleted, threatened or endangered species and other forms of marine life. Pollution from vessels in further addressed in Article 211. Like other Conventions, UNCLOS calls for an assessment of environmental impacts for planned activities that may cause substantial pollution of or significant and harmful changes to the marine environment.

The International Convention for the Prevention of Pollution from Ships, 1973

This Convention, known as the MARPOL Convention addresses pollution of the marine environment by ships from operational or accidental causes. The Convention covers prevention of pollution from sewage, garbage and air pollution from ships.

The Strategy should ensure that prevention of pollution is a priority for the aquaculture sector. This will be assessed in the Environment Report.

The London Convention on This Convention, also known as the London Dumping Convention, has the Waste management is an important consideration for the



the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, 1975

most significant set of international regulations guiding ocean dumping. The scope of this Convention was extended in 1982 with the coming into force of UNCLOS, since the latter obliges those States who had not signed the London Dumping Convention to abide by its standards (Pickering, 20006) and requires States to protect the marine environment from all sources of pollution including dumping. The London Dumping Convention aims to comprehensively and uniformly regulate ocean dumping (Macdonald, 19947) and requires all parties to the Convention “to take all practicable steps to prevent the pollution of the sea by the dumping of waste and other matter that is liable to create hazards to human health, harm living resources and marine life, to damage amenities or to interfere with other legitimate uses of the sea” (UNEP, 20048). The Convention includes a three-part classification of substances with regulations governing the disposal of materials in each category. These are: Annex I – the “black list” (substances that are absolutely prohibited and should be released into the oceans only “in emergencies posing unacceptable risk relating to human health and admitting no other feasible solution”); Annex II – the “grey list” (substances that can be dumped with special permits); and Annex III – materials that are allowed to be dumped under a general permit for all other wastes. Under the London Dumping Convention fish waste, or organic materials resulting from industrial fish processing operations are not considered to be industrial waste9 and hence the provisions of the Convention do not

Strategy and will be assessed in the Environment Report. Whether the Strategy has adequately addressed waste management issues will also be considered in the Environment Report.

6 Pickering, H., 2000. Legal Framework Governing Artificial Reefs in the European Union. In: A.C. Jensen et al. (eds.), Artificial Reefs in European Seas, 469 – 487.

Kluwer Academic Publishers, UK. 7 Macdonald, J.M., 1994. Artificial Reef Debate: habitat enhancement or waste disposal? Ocean Development and International Law. 25: 87-118. 8 http://www.unep.ch/seas/main/legal/llondon.html 9 Defined as “waste materials generated by manufacturing or processing operations”.



apply. Hence, fish wastes, blood, and offal generated by aquaculture operations are allowed to be discharged into the marine environment under the provisions of this Convention.

The 1996 Protocol to the London Dumping Convention

Aspects of the London Dumping Convention were superseded by a Protocol approved in 1996. This Protocol, further redefined the concept of dumping, including a further explanation on what is not considered to be dumping. The Protocol also includes three Annexes: Annex I – Wastes or other matter that may be considered for dumping; Annex II – Assessment of wastes or other matter that may be considered for dumping; and Annex III – Arbitral Procedure Annex I outlines the following materials in the list of wastes that may be considered for dumping: .4 fish waste, or material resulting from industrial fish processing operations; and .5 organic material of natural origin;

Waste management is an important consideration for the Strategy and will be assessed in the Environment Report. Whether the Strategy has adequately addressed waste management issues will also be considered in the Environment Report.

The Convention for the Protection of the Marine Environment and the Coastal Region of the Mediterranean, 1976 (the Barcelona Convention)

This Convention, known as the Barcelona Convention, requires the Contracting Parties to “…individually or jointly take all appropriate measures in accordance with the provisions of this Convention and those Protocols in force to which they are party to prevent, abate, combat and to the fullest possible extent eliminate pollution of the Mediterranean Sea Area and to protect and enhance the marine environment in that Area so as to contribute towards its sustainable development” (UNEP, 200410). The Convention, as revised in 1995, strives to “take all appropriate measures to prevent, abate and to the fullest possible extent eliminate pollution of the Mediterranean Sea Area caused by dumping from ships and aircraft or incineration at sea.” This is in line with similar moves in other international

The application of the precautionary and "polluter pays" principles, the obligation on the Parties to carry out and promote impact assessments, protect and preserve biological diversity, and access to information and public participation are of relevance to the Strategy.

10 http://www.unep.ch/seas/main/med/medconvii.html. As accessed in March 2005.



and regional conventions (e.g. the London Dumping Convention, the Oslo Convention11, and the Helsinki Convention12), and is based on the precautionary principle, which has set a new level of priority in emerging international legislation, including EU Directives. These various amendments include the extension of the Convention's geographical field of application to the coast, the application of the precautionary and "polluter pays" principles, the obligation on the Parties to carry out and promote impact assessments, protect and preserve biological diversity as well as combat pollution from cross-border movements of dangerous waste, and access to information and public participation (EU, 200513).

The Protocol of the Barcelona Convention concerning Specially Protected Areas and Biological Diversity in the Mediterranean, 1999

This Protocol, promulgated by the Contracting Parties to the Barcelona Convention in 1999, aims to protect, preserve, and manage in a sustainable and environmentally sound way the areas of particular natural or cultural value of the Mediterranean through the establishment of Specially Protected Areas (SPAs), and to protect, preserve and manage threatened or endangered species of flora and fauna. To date, 4 SPAs have been designated in Malta under this Protocol, namely l-Ghadira, Il-Gzejjer ta’ San Pawl, Filfla & surrounding islets and I-Gebla tal-General.

Its relevance to the Strategy lies in its requirement for EIA for any industrial or other projects that could significantly affect protected areas and species and their habitats (Article 17 of the Protocol). The requirement for EIA will also be highlighted in the Environment Report.

The Convention on Biological Diversity, 1992

The Convention on Biological Diversity, also known as the Rio Convention, was enacted in 1992. Its objective is to “conserve the maximum possible biological diversity for the benefit of present and future generations and for its intrinsic value“. This pact among the vast majority of the world's governments sets out commitments for maintaining the world's ecological underpinnings while maintaining economic development. The Convention establishes three main goals: the conservation of biological diversity, the sustainable use of its components, and the fair and equitable sharing of the benefits from the use of genetic resources. Relevant aspects of the

The sustainable conservation of resources in the marine environment is particularly relevant to the Strategy and will be assessed in the Environment Report.

11 The Convention for the Prevention of Marine Pollution from Ships and Aircraft (1972). 12 The Convention of the Protection of the Marine Environment of the Baltic Sea Area (1974 revised in 1992). 13 Europa website. Accessed on http://europa.eu.int/scadplus/leg/en/lvb/l28084.htm; March 2005.



Convention are the emphasis on the sustainable use of components of biological diversity, the requirement for EIA, and the inclusion of biodiversity issues. A direct result of the Rio Convention was the concept of Agenda 21 – a global partnership for sustainable development. Agenda 21 addresses today’s pressing problems aiming to prepare the world to meet its challenges. It reflects a global consensus and political commitment at the highest level on development and environment cooperation. Its successful implementation is first and foremost the responsibility of Governments but the broadest public participation and the active involvement of the non-governmental organizations and other groups should also be encouraged. National strategies, plans, policies, and processes are crucial in achieving this (UNEP, 200514). Agenda 21 has four sections: Social and economic dimensions; Conservation and management of resources for development; Strengthening the role of major groups; and Means of implementation. Of particular relevance to the OP are Chapter 15 (on Conservation of Biological Diversity) and Chapter 17 (on the Protection of the oceans, all kinds of seas, including enclosed and semi-enclosed seas, and coastal areas and the protection, rational use and development of their living resources). The objectives of Chapter 15 aim to improve the conservation of biological diversity and the sustainable use of biological resources. A number of activities are set out that help to achieve these objectives, including the promotion of environmentally sound and sustainable development, the recovery of threatened species and ecosystems, and the introduction of appropriate environmental impact assessment procedures for proposed projects likely to have a significant effect on biological diversity.

14 UNEP Earthwatch website, 2005. Accessed at http://earthwatch.grid.unep.ch/agenda21/ in March 2005.



Chapter 17 calls for new approaches to marine and coastal area management and development at the national, sub-regional, regional, and global levels; “approaches that are integrated in content and precautionary and anticipatory in ambit” (UNEP, 2005). The Chapter sets out seven programme areas, as follows: Integrated management and sustainable development of coastal areas, including exclusive economic zones; Marine environmental protection; Sustainable use and conservation of marine living resources of the high seas; Sustainable use and conservation of marine living resources under national jurisdiction; Addressing critical uncertainties for the management of the marine environment and climate change; Strengthening international, including regional, cooperation and coordination; and Sustainable development of small islands. Under the “Sustainable use and conservation of marine living resources under national jurisdiction” programme, the development of aquaculture is particularly encouraged, especially where marine living resources are potentially available. However, the Chapter also calls on States to commit themselves to the conservation and sustainable use of marine living resources on the high seas, including developing and increasing the potential of marine living resources to meet human nutritional needs and social and economic development goals, as well as maintaining and restoring populations of marine species at levels that can produce the maximum sustainable yield, and ensuring effective monitoring and enforcement with respect to fishing activities.

The International Convention for the Conservation of Atlantic Tunas, 1966

This Convention was drawn up to specifically manage populations of tuna and tuna-like fishes found in the Atlantic Ocean. Contracting Parties are required to co-operate in maintaining the populations of these fishes at levels which does not exceed the maximum sustainable catch for food and other purposes thus ensuring the conservation of these living resources. The International Commission for the Conservation of Atlantic Tunas was

The Strategy must consider the requirements under this Convention and in particular ensure the promotion of the local implementation of recommendations submitted by the Commission where relevant. This will be assessed in the Environment Report.



established through this Convention and was empowered to adopt rules of procedure and financial regulations as are considered necessary to carry out its functions. The Commission is responsible for the study of the populations of tuna and tuna-like fishes (the Scombriformes with the exception of the families Trichiuridae and Gempylidae and the genus Scomber) and such other species exploited in tuna that are not studied by another international fishery organisation. The Commission submits a number of recommendations, based on scientific evidence to ensure sustainable management of the species covered by the Convention

2. EU requirements Council Regulation (EC) 1198/2006 on the European Fisheries Fund

This Regulation establishes the European Fisheries Fund and defines the framework for Community support for the sustainable development of the fisheries sector, fisheries areas. The objectives of the fund are to: (a) support the common fisheries policy so as to ensure exploitation of living aquatic resources and support aquaculture in order to provide sustainability in economic, environmental, and social terms; (b) promote a sustainable balance between resources and the fishing capacity of the Community fishing fleet; (c) promote sustainable development of inland fishing; (d) strengthen the competitiveness of the operating structures and the development of economically viable enterprises in the fisheries sector; (e) foster the protection and the enhancement of the environment and natural resources where related to the fisheries sector; (f) encourage sustainable development and the improvement of the quality of life in areas with activities in the fisheries sector; (g) promote equality between men and women in the development of the fisheries sector and fisheries areas.

The Strategy should address the first objective of the EFF requirements and the SEA must take into account the requirements of the Regulation especially when considering alternatives.

Council Regulation (EC) 861/2006 establishing Community financial measures for the implementation of the

This Regulation establishes the framework for Community financial measures for the implementation of the common fisheries policy (the CFP) and the Law of the Sea. The Community financial measures will specifically contribute towards the following general objectives:

The National Fisheries OP (2007-2013) was drawn up taking into account the considerations of the Regulation. The National Aquaculture Strategy should also take account of this regulation.



common fisheries policy and in the area of the Law of the Sea

(a) improving the administrative capacity and the means for control and enforcement of CFP rules; (b) improving the collection of data necessary for the CFP; (c) improving the quality of scientific advice for the purposes of the CFP; (d) improving the technical assistance supporting the management of the Community fishing fleet for the purposes of the CFP; (e) improving the involvement of the fisheries sector and other interest groups in the CFP and promoting dialogue and communication between them and the Commission; (f) implementing measures relating to Fisheries Partnership Agreements and other bilateral or multilateral agreements for the purposes of the CFP, and in particular towards ensuring the sustainability of fisheries resources in third country waters and on the high seas; and (g) implementing measures relating to the Law of the Sea.

Council Regulation (EC) 2371/2002 on the conservation and sustainable exploitation of fisheries resources under the Common Fisheries Policy

This Regulation states that the Common Fisheries Policy must cover conservation, management, and exploitation of living aquatic resources, aquaculture, and the processing and marketing of fishery and aquaculture products, where such activities are practised on the territory of Member States or in Community waters or by Community fishing vessels or, without prejudice to the primary responsibility of the flag State, nationals of Member States. Furthermore the Common Fisheries Policy must provide for coherent measures concerning: (a) conservation, management, and exploitation of living aquatic resources, (b) limitation of the environmental impact of fishing, (c) conditions of access to waters and resources, (d) structural policy and the management of the fleet capacity, (e) control and enforcement, (f) aquaculture, (g) common organisation of the markets, and (h) international relations.

The Strategy must take into consideration the requirements under this regulation.



The Common Fisheries Policy shall ensure exploitation of living aquatic resources that provides sustainable economic, environmental, and social conditions. For this purpose, the Community shall apply the precautionary approach in taking measures designed to protect and conserve living aquatic resources, to provide for their sustainable exploitation and to minimise the impact of fishing activities on marine eco-systems. It shall aim at a progressive implementation of an eco-system-based approach to fisheries management. It shall aim to contribute to efficient fishing activities within an economically viable and competitive fisheries and aquaculture industry, providing a fair standard of living for those who depend on fishing activities and taking into account the interests of consumers. The Common Fisheries Policy shall be guided by the following principles of good governance: (a) clear definition of responsibilities at the Community, national, and local levels; (b) a decision-making process based on sound scientific advice which delivers timely results; (c) broad involvement of stakeholders at all stages of the policy from conception to implementation; (d) consistence with other Community policies, in particular with environmental, social, regional, development, health, and consumer protection policies.

Communication (COM/2002/511) from the Commission to the Council and the European Parliament – Strategy for sustainable development of European Aquaculture

The Commission recognised the importance of aquaculture in the frame of the reform of the Common Fisheries Policy and the necessity to develop a strategy for the sustainable development of this sector. This strategy will be coherent with the other Community’s strategies and in particular with the European Strategy for Sustainable Development and the conclusions of the Göteborg European Council of 15/16 June 2001.

The Strategy must be aware of the objectives listed and should seek to be in line with these objectives.

Communication (COM(2009)162) from the Commission to the European Parliament and the

Seven years on from the publication of the European Aquaculture Strategy this Communication document notes that significant progress was made during this time in ensuring the environmental sustainability, safety and quality of EU aquaculture production, however, during the same time

The national Strategy should consider this Communication document including consideration of aquaculture and its impact on the environment. This will also be addressed in the Environment Report.



Council – Building a sustainable future for aquaculture: A new impetus for the Strategy for the Sustainable Development of European Aquaculture

period, overall EU aquaculture production has stagnated, in contrast to the high growth rate in the rest of the world. This Communication aims to identify and address the causes of the stagnation, build on the achievements of the 2002 Strategy and on the new impetus for marine activities provided by the EU Integrated Maritime Policy. In establishing conditions for sustainable growth of aquaculture, the document emphasises the need to ensure compatibility between aquaculture and the environment and states that the Commission will:

• Continue to emphasise the importance of environmentally sustainable development of aquaculture in its policies and actions;

• Continue to monitor developments in terms of escapees and if necessary, assess the added value of possible action at the EU level.

The Communication also considers the importance of ensuring animal health, animal welfare, and consumer health protection and recognising the health benefit of aquatic food.

Communication (COM(2011) 417 final) from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – Reform of the Common Fisheries Policy.

The reform package of the Common Fisheries Policy (CFP) is proposed in light of the indications that the key objectives of the CFP are not being met. The reform seeks to improve sustainability both of fish stocks and the fisheries sector. The objectives include:

• More fish to fish sustainably; • A future for fisheries and aquaculture industry and jobs - the

reform will require Member States to prepare national strategic plans;

• Thriving coastal communities; • Satisfying the real needs of informed consumers; • Better governance through regionalisation; • Smarter financing; • Projecting the principles of the CFP internationally.

The National Strategy should be developed in light of the reform package and the EU strategic guidelines for the development of the national strategies.

Food Safety Regulations including Regulation (EC) No

These Community regulations cover hygiene, feed, additives, product The Strategy needs to be mindful of these requirements.



178/2002, Regulation (EC) No 136/2004, Regulation (EC) No 882/2004, Regulation (EC) 183/2005, Regulation (EC) 2074/2005, Regulation (EC) 1666/2006, Regulation (EC) 2076/2005, Regulation (EC) 853/2004, Regulation (EC) No 854/2004, Regulation 2073/2005, Regulation (EC) No 1662/2006, Regulation (EC) 396/2005, Regulation (EC) 1881/2006, Regulation (EC) 2377/90, Regulation (EC) No 37/2010, Regulation (EC) No 104/2000, Regulation (EC) No 2065/2001, Regulation (EC) 1829/2003, Regulation (EC) No 1830/2003, Regulation (EC) No 1831/2003, Regulation No 1935/2004, Decisions 89/187/EEC, 91/664/EEC, 2002/657/EC, 96/23/EC, 2003/181/EC, 2004/25/EC, 2005/34/EC.

labelling and inspection procedures relevant to aquaculture.

Council Regulation (EC) No 708/2007 concerning use of alien and locally absent species in aquaculture

This Regulation addresses the potential threat to marine habitats from invasive alien species that may be introduced through aquaculture and establishes a framework governing aquaculture practices in relation to alien and locally absent species to assess and minimise the possible impact of these and any associated non-target species on aquatic habitats and in this manner

The Strategy must consider this Regulation where relevant also in the light of impacts on biodiversity.



contribute to the sustainable development of the sector. Concil Regulation EC 166/2006 of the European Parliament and of the Council of 18 January 2006 concerning the establishment of a European Pollutant Release and Transfer Register and amending Council Directives 91/689/EEC and 96/61/EC Text with EEA relevance.

This regulation requires annual reporting by certain aquaculture operators (those for which Annex I (7) applies) for the Pollutant Release and Transfer Register.

This is an operational issue that the Strategy should be aware of.

EU Sustainable Development Strategy

The first EU SDS was launched at the Gothenburg Summit in June 2001. The strategy proposed objectives and policy measures to address key unsustainable trends and also the requirement for every new major policy to be submitted to an Impact Assessment. The SDS was revised and a renewed strategy was adopted in June 2006. Seven key priority challenges were established for a period until 2010:

• Climate change and clean energy; • Sustainable transport; • Sustainable consumption & production; • Conservation and management of natural resources; • Public Health; • Social inclusion, demography and migration; and • Global poverty and sustainable development challenges The policy was reviewed again in July 2009.

Sustainable consumption and conservation and management of natural resources are particularly relevant for the Strategy.

EU’s Biodiversity Action Plan, 2008

This document aims to facilitate and encourage Member States to reach targets set and implement outstanding measures required under a number

The Strategy should directly consider potential impacts on biodiversity. These will be assessed through the SEA.



of environmental Directives with an aim to safeguarding biodiversity including the Habitats Directive and the Water Framework Directive.

Council Regulation (EC) No 302/2009 concerning a multiannual recovery plan for bluefin tuna in the Atlantic and Mediterranean, amending Regulation (EC) No 43/2009 and repealing Regulation (EC) No 1559/2007

This Regulation reflects a new management approach to the conservation of bluefin tuna in the Atlantic and Mediterranean Seas in an attempt to rebuild stocks.

The Strategy should be aware of the reductions in TACs and other management measures.

3. National Environmental & Planning Documents A Draft Sustainable Strategy for the Maltese Islands 2006-2016

The Sustainable Strategy is centred on four main themes: Managing the environment and resources; Promoting sustainable economic development; Fostering sustainable communities; Cross-cutting strategic issues. Within these sectors the following priorities are identified: The Environment 1. Climate Change: take steps to reduce greenhouse gas emissions through transport and energy policies that seek to promote environmental protection, competitiveness, and security of supplies and, as a result, decouple the rate of growth of Green House Gases (GHG) emissions from economic growth. 2. Air Quality: take remedial action to control emissions of air pollutants and achieve compliance with European standards; 3. Nature and Biodiversity: halt loss of biodiversity by 2010, and achieve management of protected areas by 2008; 4. Groundwater: adopt a policy that safeguards the quality of groundwater resources to protect human health, and satisfy the requirements for human use and achieve good quantitative status by 2015;

Sustainable development principles must be integrated as part of the Strategy. These will be assessed through the SEA.



5. Seawater: sustain compliance with the Bathing Water Directive and achieve compliance with the Barcelona Convention standards; 6. Waste: prevent and minimise waste by achieving EU waste-related objectives and targets, reviewing Malta’s Waste Management Strategy by 2007; 7. Land use: protect, maintain, and improve the urban and rural environment and through the planning system protect the open countryside from uses, particularly residences, which can be more appropriately located in urban areas; 8. Transport: reduce car ownership rates to the EU average by 2014. Attain 1995 bus patronage levels by 2014 (40 million passengers); The Economy 9. Economic Growth: adopt policy measures so that the GDP (Gross Domestic Product) per capita in real terms grows at a rate that will enable the Maltese economy to converge towards the EU average. 10. Employment: create employment opportunities to generate income and improve the quality of life of the population, taking into consideration environmental and social impacts, and adopt policy measures so that the ratio of total employment to the working age population in Malta converges with the EU average and reaches at least 57% by 2010; 11. Labour productivity: adopt policy measures to increase average labour productivity at a rate of 1% per annum over the EU average by 2010, while attempting to balance wages, taxation, and productivity, in collaboration with the social partners. Society 12. Poverty reduction: reduce or at least sustain the current level of 15% of the population at risk of poverty and decrease the ratio of population aged over 65 at risk of poverty from 20% to 15%, by 2010; 13. Labour force participation of women: adopt policy measures so that the labour force participation rate of women increases from 33% to 40.7% by 2010;



14. Health: decrease ratio of overweight/obese population in line with the EU average by 2010 by, amongst other actions enhancing the focus on healthy living and prevention, to reduce the need for curative care; 15. Education: continue to adopt measures to decrease the early school-leavers rate to 35% by 2010. Cross Cutting Issues 16. Spatial development plan: by 2010 draw up an integrated spatial development plan to take forward the National Strategy for Sustainable Development, with the participation of major stakeholders; 17. Economic Instruments: gradually adjust the present income tax regime so that the ratio of green taxation to total taxation reaches the EU average by 2010; 18. Enforcement: by 2008, put in place an audit of enforcement arrangements to assess the adequacy of the current enforcement mechanisms and to promote integration of responsibilities and reduction of overlaps. Implementation 19. Institutional setup: by 2008 put in place a permanent structure, appropriately staffed and funded, to revise and implement the National Strategy for Sustainable Development, on an ongoing basis, under the auspices of the National Commission for Sustainable Development, and hold an annual Conference with participation of major stakeholders to critically evaluate progress relating to the strategy; 20. Sustainability indicators: by 2008, establish and fund an entity responsible for compiling and evaluating sustainability indicators. This entity should work closely with the National Commission for Sustainable Development and the National Statistics Office.

Structure Plan for the Maltese Islands, 1990

This is the national planning document that sets out the development framework for the Maltese Islands for the twenty-year period to 2010. Its’ three goals are:

The Strategy must adhere to relevant policies within the Structure Plan.



1. To encourage the further social and economic development of the Maltese islands, and to ensure as far as possible, that sufficient land and support infrastructure are available to accommodate it; 2. To use land and buildings efficiently, and consequently to channel urban development activity into existing and planned development areas, particularly through rehabilitation and upgrading of the existing fabric and infrastructure thus constraining further inroads into undeveloped land, and generally resulting in higher density development than at present; 3. To radically improve the quality of all aspects of the environment of both urban and rural areas.

Strategic Plan for the Environment and Development (SPED), 2012

The new Environment and Development Planning Act (2010) requires the preparation of a Strategic Plan for the Environment and Development (SPED). This document is currently under preparation and the initial consultation document to establish the strategic objectives can be downloaded from the MEPA website. The SPED will replace the current Structure Plan, providing a strategic spatial planning framework up to 2020. The SPED will be based on an integrated planning system that aims to (i) ensure the sustainable management of land and sea resources together with the protection of the environment; and (ii) guides the development and use of land and sea space.

The Strategy must consider the spatial planning objectives relevant to the aquaculture sector. These will be considered in the Environment Report.

National Climate Change Adaptation Strategy (NCCAS), 2012

The National Climate Change Adaptation Strategy presents a series of actions aimed at various sectors that requires integration of such measures as part of the strategic planning in areas such as fisheries, agriculture, water management, etc.

The Strategy should have regard to the relevant actions and policy direction of the NCCAS.

National Strategy for Policy and Abatement Measures Relating to the Reduction of Greenhouse Gas Emissions, 2009

This strategy is based on a number of pillars including securing civil society and citizen participation, establishing an institutional framework for climate change and building the appropriate human capital, integrating the economics of climate change in policy design and the identification of abatement measures. Abatement measures in the following sectors: energy, waste and agriculture, water, and transport.

The Strategy should be mindful of the objectives within the National Strategy for Policy and Abatement Measures relating to the Reduction of GHG emissions.

National Environmental Policy, 2012

The final NEP was launched in February 2012 and covers all end sectors and natural resources, including air, waste, water, land, soil, climate,

This policy outlines the need to manage the coastal and marine areas in an environmentally-sustainable and



biodiversity, coastal and marine area, noise chemicals and mineral resources. The policy covers the period from 2012 to 2020.

integrated manner. The development of the SEA objectives consider the NEP objectives ensuring that the assessment is directly related to the national objectives in relation to the environment

Proposed National Biodiversity Strategy & Action Plan (NBSAP) (2012-2020)

The draft NBSAP was published in February 2012 by the Ministry for Tourism, Culture and Environment and MEPA and provides a vision that reflects the priorities for efficient use of resources and halting biodiversity loss in line with EU requirements and the Convention on Biological Diversity. The NBSAP seeks to ensure cross-sectoral policy integration of biodiversity concerns and also includes a target (Target 7) related to the sustainable management of activities including specifically aquaculture to ensure biodiversity conservation. In relation to aquaculture, the need for management of Invasive Alien Species is also highlighted. Aquaculture is discussed in detail in section 4.2. Whilst the benefits of aquaculture are noted, including the nutritional, social and economic benefits for coastal communities, a number of threats on the environment resulting from these activities are also highlighted. Possible impacts from marine cage aquaculture are described (see Figure 24) and include:

• Odours; • Oil slicks from fish bait (tuna pens); • Ammonia and urea released from fish farms is toxic to aquatic life

at certain concentrations in relation to water temperature, salinity and pH;

• Ammonium exerts a demand on oxygen in water as it is transformed to oxidised forms of nitrogen;

• High densities of farmed fish can also locally deplete dissolved oxygen concentrations through fish respiration;

• Turbidity caused by the input of artificial feeds; • Risk of escapes – Escaped farmed fish may affect wild populations

Targets at sustainable management of aquaculture to ensure the conservation of biodiversity by 2020. The Strategy and the accompanying SEA must consider the potential impacts clearly outlined in the NBSAP and ensure strategic measures to prevent and/or minimise as far as possible any negative effects. Good practice guidance documents referred to in the Strategy should be integrated where relevant.



by genetic dilution through interbreeding, reduced fecundity in wild stocks, and out-competing wild populations for food and breeding area;

• Exchange of diseases and parasites between wild and farmed fish • Discharge of pollutants: disinfectants – hypoxia, mortality; anti-

fouling agents – invertebrate mortality; pesticides – invertebrate mortality; antibiotics – accumulation in sediments and living organisms;

• Discharges of soluble inorganic nutrients (P and N) and organic matter resulting in (i) eutrophication, which leads to algal blooms, decreased light penetration, depletion of oxygen and then fouling; and (ii) bathing quality adversely affected leading to complaints by the public and affected sectors such as tourism.

Secondary effects also identified include the fact that aquaculture is also dependent on wild-caught fish for the production of fishmeal (such as wild mackerel). In the case of tuna pens, tuna are wild caught. In this regard, there is a need to ensure sustainable fisheries when wild fish are caught and used for the aquaculture industry. In consideration of the above, a number of communities are particularly sensitive to impacts from aquaculture activities including seagrass beds and specific benthic communities. Consideration of carrying capacity is required to determine potential impacts and their significance. An additional point to note is that ensuring good water quality, is also important for the aquaculture industry itself. The NBSAP identifies a number of good practice guides that should be adopted in the management of the aquaculture sector.

Coastal Strategy Topic Paper, 2002

The Coastal Strategy Topic Paper was prepared by MEPA to identify issues affecting the coastal zone that required addressing as part of the Structure

The Strategy should seek to incorporate the principles of Integrated Coastal Zone Management.



Plan Review process. The Topic Paper provides a strategic direction towards sustainable development within the Maltese coast, within the broader concept of Coastal Zone Management15. The Topic Paper’s strategy for the marine environment states: “The primary objectives of the coastal strategy for the marine environment are to safeguard the natural and cultural heritage present; to safeguard legitimate marine uses, and to minimise existing and potential conflicts”. It advocates the designation of the MCAs identified in the Structure Plan, with the seaward boundary extending to the –50m depth contour, establishment of new aquaculture units beyond the -50m depth contour, and calls for a precautionary approach to development and for the application of Environmental Impact Assessment procedures. The Paper reviews the status of the coastal environment, assesses the effectiveness of the current policy framework governing coastal resources and uses, and identifies the main issues that need to be addressed in the new Structure Plan. It identifies aquaculture and fisheries among the major coastal uses. The Topic Paper acknowledges that the fisheries industry in Malta is mainly artisanal, since only a small number of fishing vessels operate on the high seas. The planning concerns identfified are: Protection of fishing harbours including protection of shoreline structures such as slipways and quays for use by the fishermen, and protection of mooring points; Consideration to fisheries requirements in proposed developments in St. Paul’s Bay (the most important fishing port in the North of Malta); Provision of facilities for hard standing and maintenance for boats exceeding

15 Coastal Zone Management is the holistic process that aims to promote and maintain the sustainable development of a defined coastal area (MEPA, 2002).



10 meters in length in Marsaxlokk; Upgrading of the fish market in Valletta; and A need for cold stores and ice making machine in Gozo and Marsaxlokk. The Topic Paper deals with aquaculture in a comprehensive manner, outlining its requirements, the development of the industry in Malta, environmental considerations and economic viability of the industry. It states that “aquaculture has often been sectoral in its approach, with very little consideration given to the impacts created by the industry” and that “certain forms and locations of aquaculture have created a climate of negative perceptions”, something that the industry needs to counteract, promoting itself as a responsible activity and an essential component of food security. Species diversification is also dealt with in the Topic Paper. When the paper was being formulated, Malta had only one tuna penning farm and most sea bream farms were converting part of their operation to tuna penning. The Paper highlights this diversification as an opportunity for local farms to compete in both the Mediterranean and global market. The main issue identified by the Topic Paper is that related to location and space requirements, emphasising the need for detailed environmental assessments before farm locations are decided. According to the Topic Paper, aquaculture is perceived to conflict with a number of other legitimate coastal uses, in terms of demand for resources, including water quality, visual/scenic value, and space. Bunkering and tourism are two sectors that conflict with aquaculture, for safety of navigation reasons and amenity value, respectively. The Topic Paper further states that although decisions on the future of the industry are not the remit of the Planning Authority, the decision on where to locate aquaculture units and their associated facilities is. The Paper concludes that “the ecological and geomorphologic characteristics and the presence of other users within such a limited coastline make it practically difficult



for this industry to expand unless the cage units are taken further offshore within sites primarily zoned for this type of activity”.

National Report on the Strategic Action Plan for the Conservation of Maltese Coastal and Marine Biodiversity, 2002

This Report identifies priority actions in the field of marine and coastal biodiversity. These actions include the preparation of species and habitat action plans, declaration of marine and coastal protected areas, data compilation, monitoring proposals, upgrading research equipment, and effective enforcement.

The Strategy should be cognisant of the requirements in the field of biodiversity and ensure integrated measures as relevant. These will be assessed through the SEA.

Draft Action Plan for the Conservation of Dusky Groupers, Epinephelus marginatus (Lowe, 1834) in Malta, 2011

The goals of this Species Action Plan (SAP) are to analyse the grouper populations with the objective of better conservation; and to analyse the sustainability of grouper fishing in Malta and in light of this to formulate a basis for its management in the Maltese waters. Capturing of this species for aquaculture experimentation purposes is identified as a threat to populations in this SAP.

If considered for exploration as a potential candidate for aquaculture, the Strategy should include measures to ensure that any actions are implemented in a sustainable manner. These will be assessed through the SEA.

Draft National Strategy for the Cultural Heritage (2012-2016)

The draft National Strategy for Cultural Heritage 2012 addresses 22 inter-related objectives, that are grouped into four main areas:

• Broadening citizen participation: cultural heritage and the local community;

• Improving governance in the cultural heritage sector: Investment in the administration setup of the local cultural heritage;

• Care and use of the cultural heritage resource: preservation and conservation;

• Sustainable use of heritage resources: sustainable use of cultural heritage.

The Strategy must consider this draft strategy and integrate measures where relevant.

4. Sectoral Plans & Policies National Reform Programme, 2005

The National Reform Programme (NRP) with a governance structure based on a three-year cycle (2005-2008) aims to set out a comprehensive strategy to deliver growth and jobs in line with the refocus of the Lisbon Agenda agreed to in the Spring European Council. Several political, economic, social, technological, and environmental factors affect Malta’s economic growth and international competitiveness and hence, the island’s employment growth potential. These include: maximising new market and funding opportunities in the EU;

The Strategy should be cognisant of these priority actions and should ensure that these principles are integrated within the Strategy.



intensifying international competition as a result of globalisation; increasing oil prices, terrorism, and competition from low cost nations; changing demographics: ageing population, increasing life expectancy, lower fertility rates; leveraging technological developments; and protecting the environment. The NRF identifies 3 environmental priorities for action by the Maltese Government: 1. Halting Biodiversity Loss; 2. Internalisation of Environmental Externalities; 3. Fight against Climate Change

Malta’s National Strategic Plan for Fisheries 2007-2013

The National Strategic Plan (NSP) describes the current situation in the fisheries sector and establishes the overall aims and objectives for the development of the Maltese fisheries sector for the period 2007-2013.

The Strategy operates in line with this overarching Plan.

National Aquaculture Policy, 2004

The National Policy on Aquaculture (NPA) was formulated in 2004 in response to the rapid development of the local aquaculture industry. The Document has two objectives: To formalise Government’s policy with respect to this emerging industry; and To provide a holistic national strategy with respect to aquaculture development in Malta. The NPA gives an overview of the development of aquaculture in Malta, identifies the requirements of the industry and the environmental constraints/impacts, and emphasis the need for the proper conduct of operations. The NPA’s Strategy is based on procedural matters, development, and management of installations. Procedurally, requests for aquaculture development permits will be the responsibility of the department responsible for fisheries. Marine installations will be located in designated areas depending on the species being farmed, namely: Installations for the culture of large fish (hence occupying large areas of sea)

The Strategy is in line with this policy and recommends that the Policy is updated.



shall be located as far out from the coast as the species and the technology will allow; Installations for the culture of small fish that necessitate sheltered waters (and small areas) shall be located so as to minimise visual impacts and to make best use of the available areas; and Installations for filter-feeding organisms, algae, and invertebrates, will be given priority on the use of inshore sites. Land-based installations will be limited to industrial areas and other appropriate sites and will depend on the systems used for managing their effluent.

National Environmental Health Action Plan, 2006 - 2010

The action plan is a policy framework document that sets targets and priority actions for the period 2006-2010. Actions are primarily concerned primarily with the protection of public health through protection of the environment. In relation to agriculture and fisheries, many of the objectives can be applied to aquaculture. The following objectives consider aquaculture more directly:

• To reduce human exposure to risks related to agriculture and animal husbandry without compromising the primary aims of agriculture and aquaculture and related activities, namely the provision of adequate and safe food.

• To widely promulgate and apply simple and understandable rules on the amount and timing of use of pesticides, particularly fish farms, on the wider use of antibiotics in animal husbandry and on the application of agrochemicals on agricultural crops, if necessary through the adoption of legislation, so as to protect both the farmers and consumers as well as the surface and groundwater draining the land.

The Strategy should integrate environmental health considerations. Impacts on human health are considered in the SEA.

Draft Solid Waste Management Strategy for the Maltese Islands, 2009

This strategy presents a number of measures for the treatment and management of solid waste.

The Strategy must ensure that any proposed measures are in line with waste management requirements where relevant. Waste management will be addressed in the SEA.

Space for Waste: the Waste Management Subject Plan

The Waste Management Subject Plan provides strategic long-term direction and context to guide both Government and the private sector in waste management issues. Its policies guide the strategic planning of waste management and the determination of development permit applications for

As above.



developments and land use changes related to waste management facilities. Water Catchment Management Plan, 2011

Malta’s Water Catchment Management Plan (WCMP) addresses all waters and its objectives focus on water resource management and conservation. The Plan is part of the implementation of the Water Framework Directive and takes an integrated approach and provides a single framework for the management of different water categories (surface and groundwater), integration of water policy across sectors, and promotes stakeholder and public participation dialogue.

The Strategy must ensure an integrated approach with regards, in particular to the programme of measures and monitoring programme of the WCMP. The SEA considers impacts of the Strategy in relation to the requirements under the Water Framework Directive and the WCMP including impacts on water quality, and water-related ecology (see Table 4).

4. National Legislation Constitution of Malta

The Constitution of Malta (Section 9) declares that the State shall safeguard the landscape and the historical and artistic patrimony of the Nation. These are the only aspects of the environment referred to in the Constitution, underlining the importance of the landscape and historical heritage.

Landscape and historical heritage must be recognised as important assets in the Strategy where relevant.

Environment and Development Planning Act, 2010

This Act seeks to protect the environment and make provision for the planning and management of development and establishes the Malta and Environment Planning Authority in relation to these requirements. The Act requires everyone together with the government to protect the environment and to assist in the taking of preventative and remedial measures to protect the environment and manage natural resources in a sustainable manner. Various duties that fall to the government are established including: 4(a) to manage the environment in a sustainable manner by integrating and giving due consideration to environmental concerns in decisions on socioeconomic and other policies; 4(b) to take such preventive and remedial measures as may be necessary to address and abate the problem of pollution and any other form of environmental degradation in Malta and beyond, in accordance with the polluter pays principle and the precautionary principle; 4(e) to apply scientific and technical knowledge and resources in determining matters that affect the environment;

Projects resulting from the Strategy must conform to the requirements of this Act.



4(g) to safeguard biological diversity; 4(h) to combat all forms of pollution; 4(i) to consider the environment as the common heritage and common concern of humankind; and 4(j) to provide incentives leading to a higher level of environmental protection.

Fisheries Conservation and Management Act, 2001

The Fisheries Conservation and Management Act, 2001 makes provisions for the regulation, conservation, and management of fisheries and aquaculture in Malta. It defines, among other things, the fishing waters of Malta, and aquaculture, and provides for the: Conservation of naturally occurring fish stocks; Protection of fish stocks from pollution; Assessment of fish stocks and collection of appropriate fisheries statistics (including catches and fishing fleet); Monitoring, control, and surveillance of fishing operations (including aquaculture); Issue and management of permits and licences; and Safeguarding of protected species.

The Strategy takes into account the requirements of the Act through the provisions contained in the various measures.

Veterinary Services Act, 2002 (latest amendment 2009)

This Act establishes and consolidates the requirements in the veterinary field, veterinary medicinal products, feeding stuffs and zootechnical requirements and for the regulation of the veterinary profession. With regard to fish and fish products, the Act considers courses of action in the event of disease outbreaks, including fish diseases.

Specific regulations are of particular relevance to the Strategy and its implementation under this Act.

Marine Pollution (Prevention and Control) Act

This Act should be the main legal source under Maltese law to address marine pollution but despite being amended three times, it has never come into force. The role of the Transport Authority in this respect is without prejudice to the provisions of the Environment Protection Act, which enables the Minister for the Environment, to issue regulations on marine pollution, with MEPA acting as the competent authority. No regulations on marine pollution control from sea-based sources have ever been issued under the Environment Protection Act.

Not relevant yet as it has not come into force.



Territorial Waters and Contiguous Zone Act, 1971

The Territorial Waters and Contiguous Zone Act (Chapter 226) was enacted in 1971 (and subsequently amended in 1975, 1978, 1981, and 2002) “to extend the territorial waters of Malta and to make provision for a contiguous zone”. The Act declares the territorial waters of Malta as being “all parts of the open sea within twelve nautical miles of the coast of Malta measured from low-water mark on the method of straight baselines joining appropriate points”. The Act empowers the Prime Minister to make regulations to control and regulate the passage of ships through the territorial waters and to regulate [Art. 7(1)]: Safety of navigation and marine traffic, The protection of navigational aids, facilities and other installations; The protection of cables and pipelines; The conservation of marine living resources; The prevention of infringement of fishery laws; The preservation of the environment; The prevention, reduction and control of marine pollution; Marine scientific research and hydrographic surveys; The prevention of infringement of customs, fiscal, immigration, or sanitary laws; and The arrest, detention, and seizure of ships to ensure compliance with laws and regulations. Although this Act provides for wide-ranging powers through enactment of regulations, none have been issued under this Act to date.

The Strategy takes into account Malta’s territorial waters.

Ports and Shipping Act, 1991 This Act makes provision for the establishment of ports in Malta, for the registration and licensing of boats and ships and to regulate the use thereof within the territorial waters of Malta and to establish fees and dues and other matters ancillary to shipping.

The Strategy should consider the Act and subsidiary legislation where relevant.

Merchant Shipping Act, 1973 This Act regulates merchant shipping. Of particular relevance to the Strategy is related to requirements related to fishing boats.

Food Safety Act, 2002 This Act makes provision for any matter related to food safety and establishes a Food Safety Commission. The Act introduces new provisions for enforcement in relation to food and repeals the Food, Drugs and Drinking Water Act.

The Strategy should consider the Act and subsidiary legislation where relevant.



Malta Resources Authority Act, 2000

The Malta Resources Authority Act establishes the powers of the Malta Resources Authority whose regulatory functions centre around water, energy, and mineral resources. In relation to water specifically the Authority shall under provision 4(2)(b): (i) secure and regulate the acquisition, production, storage, distribution or

other disposal of waterfor domestic, commercial, industrial or other purposes;

(ii) secure and regulate the conservation, augmentation and operation of water resources and the sources of water supply;

(iii) secure and regulate the treatment, storage, disposal, use or re-use, as appropriate, of sewage, waste water, sludge and storm water run-off;

(iv) secure and regulate the provision of adequate systems of public sewers and to ascertain their cleanliness, safety and efficiency;

(v) ensure the safe discharge, reception, treatment and disposal of trade effluent;

(vi) encourage and regulate the re-use of treated effluent; (vii) ensure the proper and fit disposal of waste water sewage; (viii) maximise the use of storm water run-off;

The Water Policy is under administration of the Malta Resources Authority.

Authority for Transport in Malta Act, 2009

This Act provides for the establishment of the Authority for Transport in Malta, which assumues the functions previously exercised by the Malta Maritime Authority, the Malta Transport Authority and the Director and Directorate of Civil Aviation and for the exercise by or on behalf of that Authority of functions relating to roads, to transport by air, rail, road or sea, within ports and inland waters, and relating to merchant shipping.

The Authority for Transport in Malta is a stakeholder that should be consulted in the development of the Strategy and the SEA.

Aquaculture Regulations, 1990

Legal Notice 73 of 1990 was published as subsidiary legislation to the Prevention of Disease Ordinance (Chapter 36) and covered by the Veterinary Services Act (Chapter 437), and the Animal Welfare Act (Chapter 439). These Regulations establish the licence requirements for any aquaculture operation (including importation of live fish or live fish products for aquaculture purposes) and establishes a minimum distance of 1 km between fish farms.

The provisions of these Regulations apply to the implementation of the Strategy at project level.

Fish Packing and Processing These Regulations transpose the provisions of EU Directive 91/493/EEC (as These Regulations are relevant for aquaculture operations.



Establishments Regulations, 2000

amended by Directive 97/79/EC) and Commission Decision 94/356/EC (See earlier). These Regulations define aquaculture products as “all fishery products born and raised in controlled conditions until placed on the market as foodstuff. Fish caught in their natural environment when juvenile and kept in fattening units until they reach the desired commercial size for human consumption, are also considered aquaculture products. However, they are not considered so if the fish are merely kept alive to be sold at a later date without any attempt being made to increase their size or weight”. The Regulations set out the conditions required for a fish processing plant to be licensed as an approved packing or processing establishment, and also sets out a procedure for self-check under HACCP procedures.

Legal Notice 24 of 2009, Animal Health Requirements for Aquaculture Animals and Products thereof, and on the Prevention and Control of Certain Diseases in Aquatic Animals Rules, 2009

These Regulations define the animal health requirements to be applied for placing on the market, importation and transit of aquaculture animals and products thereof; the minimum preventive measures aimed at increasing awareness and preparedness of the relevant stakeholders for diseases in aquaculture animals; and the minimum control measures to be applied in the event of a suspicion of, or an outbreak of certain diseases in aquatic animals.

The Strategy should ensure that measures are in line with these requirements as relevant., especially with regards to the disposal of tuna offal.

Legal Notice 341 of 2001, Quality Required of Shellfish Waters Regulations, 2002 (as amended by Legal Notice 426 of 2007)

These regulations designate water quality required for farming shellfish. The Strategy should consider these Regulations where relevant.

Legal Notice 105 of 2009, Undesirable Substances in Animal Feeds Rules, 2009 (amended by LN 358 of 2010)

These rules regulate the use of undesirable substances in animal feeds, including feed used for aquaculture.

The Strategy should be mindful of these rules.

Legal Notice 66 of 1997 Marine Vegetation Licence Regulations, 1997

These Regulations were introduced to regulate the cultivation and harvesting of marine plants through the requirement of a licence.

The Strategy should consider these Regulations where relevant.

Legal Notice 146 of 2008 Food Safety (Temperature

These Regulations addresses risk to food safety and appropriate temperature control measures to be adopted.




Control) Regulations, 2008 Legal Notice 130 of 2008, Ship-Source Pollution Regulations, 2008

These Regulations determine penalties for offences related to pollution of the marine environment from ships.

The Strategy should consider these Regulations where relevant and ensure that the aquaculture sector adopts all measures to minimise negative effects on the marine environment.

Legal Notice 138 of 2003 Materials in Contact with Foodstuffs Regulations, 2003

These Regulations address the types of materials and articles are intended to be brought into contact with foodstuffs.


Legal Notice 264 of 2002 Hygiene of Food Regulations, 2002

These Regulations concern food hygiene at all stages following primary production, during preparation, processing, manufacturing, packaging, storing, transportation, distribution, handling or offering for sale or supply to the consumer.


Legal Notice 265 of 2002 Food Safety (Sampling Procedures) Regulations, 2002

These Regulations consider food sampling to determine food safety requirements are not breached.


Legal Notice 162 Maximum Residue Limits in Veterinary Medicinal Products Regulations, 1998

These Regulations establish maximum residue limits i.e. the maximum concentration of residue resulting from the use of a veterinary medicinal product, which may be legally permitted or recognised as acceptable in food and how to determine these limits.


Legal Notice 142 of 1998 Residues in Meat Regulations, 1998

These Regulations provide restrictions to substances that can be used in aquaculture


Legal Notice 19 of 1977 Sale of Fish Regulations, 1977

These Regulations control sale of fish. The Strategy should consider these Regulations where relevant.

Legal Notice 63 of 1967, Prevention of Disease Amongst Animals Regulations, 1967

As their title suggests, these Regulations control prevention of disease in animals.


Legal Notice 114 of 2007, Environmental Impact Assessment Regulations

This Legal Notice requires that an Environmental Impact Assessment is carried out for certain developments that may have an impact on the environment.

Projects resulting from the Strategy must be screened to ensure that an EIA is carried out if required by legislation. This will be assessed in the SEA.

Legal Notice 497 of 2010, The SEA Regulations require that certain plans and programmes are subject The Strategy is undergoing an SEA, therefore conforms to



Strategic Environmental Assessment Regulations

to an environmental assessment prior to their implementation. the requirements of the legislation.

Legal Notice 311 of 2006, Flora, Fauna and Natural Habitats Protection Regulations, 2006 and Government Notices 161 of 2007, 112 of 2007, 1138 of 2005

These Regulations transpose the Habitats Directive and designate Special Areas of Conservation including Marine Protected Areas. The legislation calls for the protection of species and habitats and the setting up of a NATURA 2000 network.

The Strategy must ensure that it does not threaten natural areas and/or wild species, in particular those protected under national and international legislation. This will be assessed in the Environment Report. Consultation with MEPA has identified that the Strategy requires an Appropriate Assessment under these Regulations.

Legal Notice 116 of 2005 Freedom of Access to Information on the Environment Regulations, 2005

This legislation enables the public to have access to information on the environment that is held by public authorities.

The Environmental Report for the SEA on the Strategy will be published for public consultation.

Legal Notice 194 of 2004, Water Policy Framework Regulations, 2004

The Water Framework Directive seeks to establish a structured framework for action in the field of water policy. It aims to establish a framework for the protection of inland surface waters, transitional waters, coastal waters and groundwater that:

- Prevents further deterioration and protects and enhances the status of aquatic ecosystems and, with regard to their water needs, terrestrial ecosystems and wetlands directly depending on the aquatic ecosystems;

- Promotes sustainable water use based on a long-term protection of available water resources;

- Aims at enhanced protection and improvement of the aquatic environment, inter alia, through specific measures for the progressive reduction of discharges, emissions and losses of priority substances and the cessation or phasing-out of discharges, emissions and losses of the priority hazardous substances;

- Ensures the progressive reduction of pollution of groundwater and prevents its further pollution, and

- Contributes to mitigating the effects of floods and droughts and will have a significant role to play in protecting and managing water

It is important that the issues and measures presented in the regulations are considered in the Strategy. This will be assessed in the Environment Report.



resources. These Regulations require that designated surface waters must achieve good ecological and chemical status by 2015 and that this status is to be maintained.

Legal Notice 340 of 2001 Urban Waste Water Treatment Regulations, 2001

This Regulation concerns the collection, treatment, and discharge of urban wastewater and the treatment and discharge of wastewater from certain industrial sectors. The objective of the legislation is to protect the environment from the adverse effects of these wastewater discharges. The regulation also sets acceptable pollutant levels.

The Directive is important as urban wastewater discharged into the marine environment affects the fisheries and aquaculture sector

Legal Notice 380 of 2003, Quality of Bathing Water Regulations, 2003

This regulation sets binding standards for bathing waters. It sets parameters that Malta is legally obliged to meet for water quality standards for coastal bathing water.

It is important that the Strategy is aware of the targets and impact it may have on water quality, especially with regards to siting of aquaculture facilities in nearshore locations. This will be assessed in the Environment Report.

Legal Notice 73 of 2011, Marine Policy Framework Regulations, 2011

These regulations transposes the Marine Strategy Framework Directive (2008/56/EC), which is the first all-encompassing piece of European legislation aimed at protection of the marine environment. The main aim is to achieve Good Environmental Status (GES) in European waters by 2020 through the adoption of an ecosystem-based approach to the management of all human activities that impact the marine environment. The regulation includes implementation of a number of key steps to achieve the overriding aim including an initial assessment of the current environmental status of marine waters as well as the environmental pressures and impacts on the marine environment. The initial assessment must include an economic and social analysis of the use and degradation of the marine environment. The determination of GES must then be carried out based on a number of qualitative descriptors. Environmental targets and associated indicators must then be set in order to guide progress towards the achievement of GES.

The Strategy must ensure integration with the requirements under these Regulations.

Legal Notice 184 of 2011, The Waste Regulations, 2011

These regulations transpose the Waste Framework Directive (2008/98/EC). They provide the general framework of waste management requirements.

These regulations will be particularly relevant at implementation stage.



Draft Framework for Environmental Permitting of Industrial Activities Legislation (MEPA)

Fish farms are amongst the sectors proposed to be regulated by environmental permitting.

The Strategy must consider planned changes in the permitting framework.