E-PRTR Regulation PRTR Protocol Malta’s experience in implementation Rachel Decelis, Environment Officer Malta Environment and Planning Authority
The Maltese scenario Around 20 installations locally 75% covered by IPPC: Waste management, chemicals, large combustion plants, poultry Additionally, shipyards & fishfarms
Contact with operators Information meeting: beginning 2007 Webpage on E-PRTR, links to guidance document Timeframes for reporting in Legal Notice – more time given in the first year, possibility to ask for an extension of up to 3 months Publication of template (fill-in the blanks) Electronic reporting (email) Individual meetings or communication when necessary
Thresholds Only pollutants above threshold to be reported (for non-IPPC sites) If nothing above threshold, operators asked to send declaration Some operators supplied data below threshold voluntarily Others attached rationale behind the numbers
Links with IPPC Annual environmental report by March E-PRTR included as a separate section in AER, recent permits include reporting of pollutants below threshold (for verification) Information gained during IPPC process useful for assessing data
Reporting procedures No exceedance Data E-PRTR report Complete? Plausible? Complete? Resubmission Further verification Final E-PRTR report
Quality assessment Initial completeness check Plausibility check: prior knowledge of installation, comparison with other reports on the same activity Further verification – methods used (are they reliable? which category would they fall under?), which pollutants are above threshold, queries to operator Meetings with operators (where necessary), sources/measurements/calculations verified – in one case certain air emissions had been overestimated x1000
Coordinates Due to mapping facilities at MEPA, coordinates worked out internally (based on planning permits) and sent to operator (for future reporting)
New obligations Releases to land: No known activities carrying out land treatment or deep injection Transfers of waste: No major problems, hazardous waste transfers already regulated, so operators have records; threshold for non-hazardous waste is very high for the local scenario (only 1 report) Accidental releases: One operator reported an accidental release above threshold
Availability of information to public EPER data: link to EC website E-PRTR: Discussions underway, due to small number of installations Link to EC website will be placed as soon as information is uploaded by Commission
Benefits & suggestions (1) Most E-PRTR installations also IPPC –useful when same officer is involved in both However, operators complain that they have to report “twice” Guidance document: excellent, examples very practical, pollutant list useful, calculation methods used by several operators However, sector-specific pollutant list sometimes very wide – operators complain of cost Method for assigning an identification number for the facility not very clear
Benefits & suggestions (2) Yearly reporting beneficial – operators get used to obligation Quality of data when operators use estimates not certain Possibility to revise data in future years after submission? Document outlining differences between PRTR and E-PRTR (e.g. employee thresholds, national register) would be useful
Further information Web: http://www.mepa.org.mt/environment/index.htm?IPPC_new/mainpage.htm&1 (click on EPER & E-PRTR) Email: eprtr@mepa.org.mt