1. E-PRTR Regulation PRTR Protocol
Malta’s experience in implementation
Rachel Decelis, Environment Officer
Malta Environment and Planning Authority

2. The Maltese scenario Around 20 installations locally
75% covered by IPPC: Waste management, chemicals, large combustion plants, poultry
Additionally, shipyards & fishfarms

3. 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 ( )
Individual meetings or communication when necessary

4. 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

5. 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

6. Reporting procedures No exceedance Data E-PRTR report Complete?
Plausible?
Complete?
Resubmission
Further
verification
Final E-PRTR
report

7. 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

8. Coordinates
Due to mapping facilities at MEPA, coordinates worked out internally (based on planning permits) and sent to operator (for future reporting)

9. 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

10. 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

11. 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

12. 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

13. Further information
Web: (click on EPER & E-PRTR)