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Agricultural Waste Management in the Maltese Islands (2015-2030) DRAFT REPORT PREPARED FOR THE MINISTRY FOR SUSTAINABLE DEVELOPMENT, ENVIRONMENT AND CLIMATE CHANGE MALTA December 2015

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Page 1: Agricultural Waste Management in the Maltese Islands (2015

Agricultural Waste Management in the Maltese Islands

(2015-2030)

DRAFT REPORT PREPARED FOR THE

MINISTRY FOR SUSTAINABLE DEVELOPMENT, ENVIRONMENT AND CLIMATE CHANGE

MALTA

December 2015

Page 2: Agricultural Waste Management in the Maltese Islands (2015

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Table of Contents

List of Acronyms ...................................................................................................................................... 3

Executive Summary ................................................................................................................................. 4

1. Introduction .................................................................................................................................. 16

2. Policy and Legislation governing Agricultural Waste Management ............................................. 18

2.1 Agricultural Waste in the Maltese Islands .................................................................................. 19

2.2 Current waste management policy ............................................................................................. 19

2.3 EU Directives & National Legislation Relevant to Agricultural Waste Management.................. 20

2.4 Current Practice .......................................................................................................................... 25

2.5 Challenges associated with current practice & compliance ....................................................... 26

2.5.1 Cattle .................................................................................................................................... 26

2.5.2 Pigs ........................................................................................................................................... 26

2.6 Discussion and Conclusions ........................................................................................................ 27

2.7 Barriers to the Implementation of Agricultural Waste Management Infrastructure ................. 28

3. Overview of the Agricultural Sector .................................................................................................. 29

3.1 Malta ........................................................................................................................................... 29

3.1.1 Number of Agricultural Holdings ......................................................................................... 30

3.1.2 Employment ......................................................................................................................... 31

3.1.4 Livestock ............................................................................................................................... 34

3.1.5 Pigs ....................................................................................................................................... 38

3.1.7 Poultry .................................................................................................................................. 40

3.1.8 Goats and Sheep .................................................................................................................. 42

3.2 Gozo and Comino ........................................................................................................................ 43

3.2.1 Number of Agricultural Holdings ......................................................................................... 43

3.2.2 Employment ......................................................................................................................... 44

3.2.3 Cattle .................................................................................................................................... 47

3.2.5 Pigs ....................................................................................................................................... 50

3.2.6 Poultry .................................................................................................................................. 51

3.2.7 Goats and Sheep .................................................................................................................. 52

4. Forecast of the Livestock Sector (2016-2030) .................................................................................. 54

4.1 Cattle ........................................................................................................................................... 54

4.2 Pigs ............................................................................................................................................. 59

4.3 Goats ........................................................................................................................................... 63

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4.4 Sheep........................................................................................................................................... 66

4.5 Potential Forecast Scenarios (Heads) ......................................................................................... 69

4.6 Potential Forecast Scenarios (Manure/Slurry) ........................................................................... 70

5. Strategic Options towards Manure and Slurry Management in Malta (2016-2030) ........................ 73

5.1 Scenario Analyses ........................................................................................................................ 75

5.2 Implications of this Analysis for Strategic Options ............................................................... 78

5.3 Discussion on a Potentially Realistic Scenario ............................................................................ 79

6. High-Level Assessment of Treatment Options .................................................................................. 82

6.1 Critical Parameters ...................................................................................................................... 83

6.2 Current Policy and Practice ......................................................................................................... 84

6.3 Technology options ..................................................................................................................... 85

6.3.1 Physical treatment: Mechanical Separation ........................................................................ 86

6.3.2 Aerobic treatment ................................................................................................................ 87

6.3.3 Aerobic treatment of slurries ............................................................................................... 88

6.4 Thermal treatment of solids ....................................................................................................... 91

6.5 Application in the Maltese Islands Context ................................................................................ 92

7. Determination of the Financial Costs of the Technological Alternatives for the Handling and

Treatment of Agricultural Waste .......................................................................................................... 96

7.1 Waste Generation ....................................................................................................................... 97

7.2 Waste Treatment .................................................................................................................. 98

7.3 Waste Disposal .................................................................................................................... 100

7.4 Technical Options available for generation, treatment and disposal ....................................... 106

7.4 Summary of Options ........................................................................................................... 108

8. Agricultural Waste Management Governance System .............................................................. 114

8.1 Stakeholders involved in the Governance System .................................................................... 115

8.2 Strategic Elements of the Governance System ......................................................................... 115

8.3 Functions of the System ............................................................................................................ 116

8.3.1 Administrative Role ............................................................................................................ 116

8.3.2 Strategic Planning .............................................................................................................. 118

8.3.3 Operational Monitoring ..................................................................................................... 118

8.3.4 System Development/Innovation ...................................................................................... 119

8.3.5 Corporate Structure ........................................................................................................... 119

8.3.6 Governance Structure Milestones ..................................................................................... 120

9. CONCLUSION ............................................................................................................................... 123

Page 4: Agricultural Waste Management in the Maltese Islands (2015

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List of Acronyms

ABP – Agricultural By-Products

AWU – Annual Working Unit

COD – Chemical Oxygen Demand

COGAP – Code of Good Agricultural Practices

EC- European Commission

GHG – Greenhouse Gas Emissions

L.N – Legal Notice

MBBR – Moving Bed Reactor

MBR – Membrane bioreactor

MBT – Malta Biological and Treatment Plant

MDP – Malta Dairy Products

MEPA – Malta Environmental and Planning Authority

MS – Member State

MSDEC – Ministry for Sustainable Development, Environmental and Climate Change

NAP – Nitrates Actions Programme

NSO – National Statistics Office

ODZ – Outside Development Zone

PA- Partnership Agreement

PPP – Public Private Partnership

RDF – Refuse Derived Fuel

RDP – Rural Development Programme

SBR – Sequencing Batch Reactor

SEWCU – Sustainable Energy, Water and Conservation Unit

TSS – Total Suspended Solids

UAA – Unutilised Agricultural Area

WMP – Waste Management Plan

WSC – Water Services Corporation

Page 5: Agricultural Waste Management in the Maltese Islands (2015

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Executive Summary

Background on Compliance Issues

Practices involved in the management of cattle manure and pig slurry in Malta require a review for

the country to meet its objectives and obligations with respect to water resource management and

related environmental issues, especially concerning groundwater and the treatment of waste water.

Farm Waste management in Malta is governed by the requirements of a number of EU Directives. Of

particular relevance is the Nitrates Directive as transposed by Legal Notice 343 of 2001 and by the

Protection of Waters against Pollution Caused by Nitrates from Agricultural Sources Regulations, 2003.

These instruments provide for the designation of the entire territory of Malta and Gozo as Nitrate

Vulnerable Zones, the formulation of Code/s of Good Agricultural Practice and the preparation of

Action Programmes in respect of designated vulnerable zones. The Waste Framework Directive

2008/98/EC as transposed by the Waste Regulations 2011 (L.N. 184 of 2011) is also to be complied

with.

Another important legislation pertaining to the management of livestock manure is compliance with

the Water Framework Directive and the Urban Waste Water Directive, whereby lack of compliance is

currently observed on account of the discharge of pig slurry into the sewer system. In a recent

Commission Staff Working Document1 on the implementation of the Water Framework Directive

Programmes of Measures, the Commission states that in its second River Basin Management Plan,

Malta must:

“Submit a plan on resolving the discharge of animal husbandry waste in the sewage collecting system

because the Maltese Waste Water Treatment Plants had a performance problem as regards

compliance with the COD standards. This was linked to farm manure discharges in the collecting

system.”

Objectives and Methodology

This report develops a plan to cater for the management of agricultural waste in Malta. The

background research to the report has considered all elements of waste generated by the sector

including streams which fall under municipal waste, waste which is of a more commercial/industrial

nature (particularly taking the form of packaging waste) as well as that pertaining to carcasses and

streams normally associated with abattoir processes. It however transpires that the main and pressing

challenges with respect to agricultural waste in Malta lies with the management of manure/slurry.

Other waste streams are found to present far less significant challenges as they are already subject to

management systems, wherein the main issues which could emerge in practice relate more to

enforcement rather than system design. The need for effective enforcement of rules in all aspects of

1 European Commission. 2015. Commission Staff Working Document Report on the progress in implementation of the Water Framework Directive Programmes of Measures Accompanying the document Communication from the Commission to the European Parliament and the Council The Water Framework Directive and the Floods Directive: Actions towards the 'good status' of EU water and to reduce flood risks

Page 6: Agricultural Waste Management in the Maltese Islands (2015

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waste management is an obvious consideration and is not treated any further in this report.

Consequently, this report focuses entirely on issues related with the management of the generation,

transport, treatment and disposal of agricultural manure and slurry.

The approach taken in this report considers the need to safeguard the competitiveness of the livestock

sector whereby in spite of restructuring, significant imbalances between number of heads and

resources for manure/slurry management persist. Furthermore, the potential high cost of compliant

manure/slurry management compound other inherent competitiveness factors facing the sector.

This report and the options which are presented in it are developed within the context of a number

of uncertainties and risks which affect the potential solutions that may be considered. Of particular

relevance are uncertainties associated with the future development of critical activity variables

including:

The number of heads of different categories of livestock;

The mass/volume of waste generation, also affected by water added to pig slurry;

The quantity of N which can be applied to land, which may fall significantly in the coming few

years, and possibly stabilise later;

The amount of utilised agricultural land and crop patterns;

The feasibility of potential treatment options which depends on technical, environmental,

financial and economic constraints, and subject to the consideration that while a limited

number of options are apparently technically viable for Malta, others are still to be tested

within the local context;

The future development of cost variables such as inorganic fertiliser, technically feasible

treatment options, and of treatment options which are currently at an experimental or testing

stage.

There are also uncertainties associated with the behaviour and response of operators within the

livestock sector. Additional costs of operation to the cost of restructuring, an intensification of market

competition and the erosion of support schemes over the years are severely restricting their ability to

pay for waste management services as well as financial sustainability in general. There is also

uncertainty associated with the willingness of livestock and crop farmers to change their current

practices and to adapt to new operating requirements.

A snapshot of the livestock sector in Malta and Gozo is presented in Chapter 3 of the report

distinguishing between developments in the bovine, swine, ovine and other livestock sectors. The

analysis also distinguishes between developments in the Island of Gozo and Malta given that solutions

between the two regions may differ. In general, there has been a downward trend in most of the

sectors most notably in the bovine and swine sectors. Bovine farms in Malta which are mainly located

in the south and central part of Malta and Gozo reached a level of about 18,000 heads in 2008 and

then declined to 15,500 in 2013.2 The drop in heads and cattle farms post 2007 was mainly due to

2 NSO, Agriculture and Fisheries.

Page 7: Agricultural Waste Management in the Maltese Islands (2015

6

enforcement by the local authorities in relation to compliance with EU standards, significant increase

in the price of inputs as well as herd improvement programmes.

Similar to the trend in the bovine sector, the swine industry experienced a significant decline in heads

after 2007. In fact, the number of pigs registered in Malta and Gozo declined to about 46,000 heads

in 2011 from 73,000 heads in 2005. Again, this was an effect of the May 2008 deadline for applications

on planning permits to improve the manure storage and management system on-farms. There has

also been a decline in the number of sheep and goats as well as the number of poultry heads3.

The distribution of the farms by size and types of livestock is shown in Figure E.1.

Figure E.1: Geographical distribution of Farms

Future Scenarios for Waste Generation

In order to derive a forecast of the livestock sector and the related generation of manure/slurry up to

2030, a number of different assessments have been undertaken as presented in Chapter 4 of the

report. Forecasts are in part based on past developments which have been extrapolated into the

future taking into account log functions and autoregressive functions. Furthermore, a convergence

approach has also been considered whereby developments in the livestock categories in Malta are

compared to other countries within the EU, particularly Mediterranean countries which are subject to

similar terrain and climatic conditions, such as Cyprus and Greece. The cross country comparison is

3 NSO, Agriculture and Fisheries

Page 8: Agricultural Waste Management in the Maltese Islands (2015

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undertaken on the basis of population as well as land area. Specifically for the bovine sector, the

forecasts also take into account an analysis of the farms which have already engaged in restructuring

and have invested to sustain their operations. An additional forecasting approach has been applied

for the swine sector to consider a scenario of consolidation of activity centred on the on-going viability

of relatively large operators.

Given the prevailing uncertainty in the development of the livestock sector as well as the relatively

long forecast horizon, which is here considered over fifteen years, the forecasts presented in the

report are not based on point estimates but are presented over ranges characterised by minimum

and maximum values. These forecasts are displayed in Table E.1 below.

Table E1: Forecast Scenarios

In terms of the cattle sector, both the minimum and maximum scenarios refer to a decline in the

number of heads which in 2030 may vary from 8,000 heads to 12,800 heads. It is to be noted that in

terms of the minimum scenario, the number of heads would be expected to decline in a persistent

manner over the forecasted horizon. On the other hand, the maximum scenario which considers the

sustainability of farms based on their willingness and ability to invest also features a decline in heads

up to 2020, followed by a stable situation thereafter.

In the case of pigs, the minimum scenario is taken to reflect the convergence approach which refers

to a decline in the number of heads from 42,700 in 2015 to 7,940 by 2030. On the other hand, the

maximum scenario also refers to a declining trend, albeit less pronounced, to 34,500 by 2030.

Two scenarios based on the minimum and maximum values are also presented for the sheep and goat

sector. In this case, the minimum scenario for both the sheep and goats sectors refers to a decline in

the number of heads. On the other hand, the maximum scenario which is based on the convergence

approach refers to a steady increase in the number of heads reaching 5,900 for goats and 15,300 for

sheep.

The forecasts for the volume of manure/slurry generated considers the above results values together

with agronomical values utilised by the Agricultural Directorate and presented in published sources.

More specifically, in the case of the cattle sector, there are a number of relevant literature sources

which feature a significant variability in the estimates of manure production per head. For the

purposes of this study, outcomes for values across these ranges are considered in order to derive

analyses relating to different scenarios.

The even wider range in the production of pig manure is due to the uncertainties owing to wide

variations in waste management practices across the country, particularly in terms of the use of water.

Relevant results are presented in Table E.2.

Min Max Min Max Min Max Min Max

2015

2020 11.8 12.8 24.2 39.8 3.7 5.1 9.4 12.1

2025 9.7 12.8 13.9 37.0 3.1 5.5 8.3 13.6

2030 8.1 12.8 7.1 34.5 2.6 5.9 7.3 15.3

14.1 42.7 4.5 10.6

Scenario Ranges for Numbers of Heads (000s)

SheepGoatsPigsCattle

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Table E.2 Scenario Ranges for Manure and Slurry Production

The manure generated in the cattle sector may vary from a minimum of 67,700m3 in 2020 to a

maximum of 131,800m3 in the same year, with the relative values falling in the project in accordance

with the expected development in the number of cattle heads.

The greatest uncertainty in the volume of manure/slurry lies with the pig sector whereby slurry may

vary from 7,100 m3 in 2020 to a significantly higher volume of 146,000m3 in the same year. Indeed it

is this sector which is considered to pose the greatest challenges in the implementation of the

agricultural waste management plan as current practices associated with the disposal of slurry cannot

be continued. It is however important to note that while this is considered as a significant challenge,

80% of the production of slurry is undertaken by a relatively limited number of farms, totalling

approximately 40, which may reduce the extent of challenges to implement solutions.

Considerations Impinging on the Derivation of Strategic Options

Chapter 5 of the report details the elements involved in the derivation of strategic options with respect

to manure and slurry management in Malta and describes a number of scenarios which can be

envisaged in future. The derivation of effective strategic options towards manure and slurry

management in Malta depends on the following four factors:

1. the characteristics of the underlying manure and slurry generation and sink mechanisms,

intended as the expected development of the livestock industry and the absorptive capacity of the

crop industry in terms of manure and slurry being generated;

2. the constraints governing the system, the principal of which may be categorised into:

a. the need for Malta to meet its obligations as a Nitrates Vulnerable Zone entailing potential

constraints at three levels:

i. a limitation not to exceed an application of N of 170kg/ha/yr on crop land;

ii. a limitation not to exceed the potential uptake by crops, which is estimated at around

110kg/ha/yr as per the Gross Nitrogen Balance (2007) study undertaken by the NSO;

iii. the need to potentially limit the application of N to crop land in a manner whereby crops would

be absorbing N already contained within the soil from over-application in previous years4, to be

as yet determined through specific studies regarding the N content in soil and rendered

4 This has been estimated at 116.9km or kg/ha in the 2007 Gross Nutrient Balance Study, the fourth highest among 19 EU Member States.

Min Max Min Max Min Max Min Max

2015 80.5 145.4 12.5 157.3 1.2 1.4 94.2 304.1

2020 67.7 131.8 7.1 146.7 1.0 1.6 75.7 280.2

2025 55.4 132.0 4.1 136.4 0.8 1.7 60.3 270.1

2030 46.5 132.0 2.1 127.2 0.7 1.9 49.3 261.0

Scenario Ranges for Manure and Slurry Production (m3000s)

Cattle Pigs Goats and Sheep Total

Page 10: Agricultural Waste Management in the Maltese Islands (2015

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effective through Fertiliser Plans at the farm level in conformity with the Code of Good

Agricultural Practice and the Nitrates Action Programme.

b. the need for Malta to eliminate lack of compliance with the requirements of the Water

Framework Directive and the Urban Wastewater Directive in terms of bathing water quality, which

issue is arising principally from the discharge of slurry into sewers.

c. the need for Malta to sustain the economic competitiveness of the livestock farming, as an

integral component of the multi-functionality of agriculture in Malta, which calls for the pursuit of

cost-effective solutions to manure and slurry management;

d. likewise, the need for Malta to sustain the competitiveness of crop agriculture, which entails

the optimum use of fertiliser while meeting the requirements of Nitrate Management Plans, which

influences:

i. the quantity of fertiliser used;

ii. the mix between locally-sourced organic fertiliser and imported non-organic fertiliser

3. the objectives to be optimised within the system which is taken to be the minimisation of the

financial and externality costs of the management system, considering:

a. manure and slurry management practices at the level of the livestock farms;

b. transport activities;

c. fertiliser costs applicable to crop farms;

d. the net costs of treatment to enable disposal in compliance with Nitrates and Water

Quality constraints, factoring revenues where applicable;

e. the costs of final disposal, including potentially, export.

4. the policy levers available, which could potentially include regulatory and financial

instruments influencing:

a. the general development of livestock farming in Malta;

b. the management of manure and slurry on livestock farms, including issues such as:

i. the extent of water which is used and added to the volume of waste,

particularly with regards to pig slurry;

ii. the extent and location of discharges to the public sewers, which although

currently not permitted by legislation in Malta, are in effect taking place and

could in future potentially take place in conformity with the Water Quality

Directive if effective prior treatment is undertaken;

c. the methods of use of fertiliser on crop land, particularly with regards to the mix

between organic and inorganic fertilisers;

d. the potential development of treatment infrastructures to enable the sustainable and

legal disposal of manure and slurry, whether centralised or decentralised, at the local

or farm level;

e. the potential engagement in export of manure and slurry;

Page 11: Agricultural Waste Management in the Maltese Islands (2015

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f. effective governance to cater for the potential establishment of a centralised system

of manure waste management, possibly at the separate regional levels of Malta and

Gozo

There is also an element of dynamism in the agricultural waste management problem emanating from

factors including:

1. the measures adopted may themselves influence the development of livestock, and to a lesser

extent, crop farming in future years;

2. the adopted fertiliser plans which outline the extent to which N can be applied to crop land

may change in future as N content levels in soil are altered as a result of the actions taken.

Solutions must thus cater for risk through sufficient elements of flexibility, and evolve over time to

cater for expected changes in circumstances.

These considerations are presented in detail in Chapter 5 of the report. Possible scenarios focusing on

the management of cattle manure and pig slurry, with the understanding that these two elements

constitute well over 90% of manure and slurry waste streams in terms of volume, weight and mass of

N are presented in the chapter.

This scenario analysis aims to identify, the amount of manure and slurry which would require

treatment for eventual disposal and/or export, measured in terms of both kilograms of N and cubic

metres of material. This subsequently enables a mapping of policy alternatives under different

situations, including the identification of solutions which afford important degrees of flexibility in the

face of uncertainty.

The scenarios take into account the extent of use of inorganic fertiliser, which would thus crowd out

the use of manure as well as the extent to which an uptake of N by crops from soil content is prioritised

over the application of fertiliser.

In each scenario, it is assumed that the application of fertiliser would in no circumstance exceed the

potential uptake by crops during a particular year. It is further assumed that there is no disposal of pig

slurry into the public sewer network.

A discussion on a potentially realistic scenario upon which options are subsequently developed, is also

presented in the chapter based on the following considerations:

only manure is used for the purposes of application to crops;

pig slurry is by default to be subject to treatment so that it is neither applied as fertiliser nor

would it be discharged to public sewers; restrictions on the application of inorganic fertilisers

within the context of the observance of Nitrates Management Plans may not necessarily be

either feasible or totally desirable;

the restrictions on total N application associated with Nitrates Management Plans will have

to be adhered to.

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Based on these considerations 2015 results indicate a likely range of N surplus of up to 40,000m3 per

annum of cattle manure, with an extreme maximum of just over 69,000m3 per annum. By 2020, these

indicators are expected at almost 35,000m3 and 63,000m3. By 2030, the surplus is expected at no more

than 12,000m3 per annum.

With the Malta North plant which will allow for the co-mingling of manure with municipal waste plant

(operated by Wasteserv Malta) having a capacity of 39,000m3 per annum, the implications for the

derivation of high level options therefore focuses on the need to:

manage pig slurry, in a range between 350,000kgs and 425,000kgs of N per annum, or up to

150,000m3, strongly depending on water content;

provide for potential additional capacity of around 60,000 m3 for cattle manure, and around

5,000 tonnes of manure of other animals;

devise a governance and management system for effective operation.

The rest of the report targets these considerations in a detailed manner over Chapter 6, 7 and 8

respectively.

Chapter 6 of the report presents a high level assessment of treatment options based on the

following critical objectives:

the continued banning of the application of slurry or liquids directly to land.

to effectively prevent the discharge of pig slurry to the sewage system which is considered

more important in light of the EC recommendation on the implementation of the Water

Framework.

The options which take into account international experience, consider from a technical perspective:

Mechanical Separation, Aerobic treatment, Aerobic treatment of slurries, Anaerobic Digestion,

Aerobic treatment (biological oxidation) and thermal treatment of solids

The chapter also considers the application of these technologies in the Maltese context, noting that

in the short-term, export of excess manure and slurry may be necessary.

Strategic Options and High Level Cost Estimates

Chapter 7 of the report articulates the options available for the management of cattle manure and pig

slurry, at different points of the future forecast horizon. It also discusses the financial implications of

the options. The analysis distinguishes between the options available at generation, treatment and

disposal stage. It is emphasised that this report is not indicating any one particular solution as being

the preferred one, but rather advocates the need for a mix of solutions which consider specific needs

and requirements of different farms at different points in time.

In terms of pig slurry, a key element of the management of waste rests on generation in the first place.

Emphasis on sustainable and efficient farming practices to minimise the number of heads and waste

is considered particularly important. The over abundant use of water has to be discontinued to enable

the efficient use of treatment and disposal options. At generation level, there is also the option of

diversification of farm land use, towards for example, sustainable rural real estate, or the outright

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buyout of farms by Government to be utilised in consonance with national policy. The number of

heads may through a policy decision decline thus addressing the generation of slurry through the

diversification of farm land use which ties in with the sustainability of rural areas. Livestock farmers

could be presented with the option of diversifying the farm land use themselves or possibly with a pig

farm buy out scheme which can be implemented by the governance structure which is explained in

Chapter 8.

Table E.3: Options for the generation, treatment and disposal of pig slurry

Waste treatment options for pig slurry are not perceived to be available in the immediate short term

and the viability of the options presented in the matrix above from 2020 onwards remains to be

studied in technical detail. In particular, the options of producing fertilisers, thermal treatment and

disposal to sewer following the treatment of the slurry remains to be tried and tested within the local

context. The financially feasibility of these options also needs to be studied in greater detail. While

technically speaking, the digestion plants can treat pig slurry, the viability of these plants greatly

depends on the composition of the slurry in the first place, climatic conditions, and the availability of

inputs in consistent quantities and of consistent quality across different periods of the year.

It is to be noted that in the analysis, export is taken to absorb the residual of the waste volume which

is not treated. Export is thus considered as a stop-gap solution, and an expensive one, to be pursued

until other feasible options are developed in the medium to long term.

The options for the treatment and disposal of cattle and other livestock manure are presented

separately as shown in Table E.4. At generation level, the options are aimed at diversification of farm

land use towards sustainable rural real estate as well as further and enhanced emphasis on sustainable

and efficient practices to minimise the number of heads and volume of manure.

In terms of treatment, the Malta North Biological Treatment Plant is in the short term the only

treatment plant at a centralised level which can cater for part of the cattle and other livestock manure.

In the medium term, treatment of this manure can be further complemented by other digestion plants

or treatment options. It is however to be reiterated that in the case where the minimum scenario of

cattle manure materialises, the scope of having additional centralised plants may be limited.

2016/2018 2020 2030

Digestion Malta North Digestion Malta North

Digestion Other Malta Digestion Other Malta

Digestion Gozo Digestion Gozo

Fertiliser Production Fertiliser Production

Waste treatment to sewer Waste treatment to sewer

Thermal Thermal

Export Export Export

Sewer (after treatment) Sewer (after treatment)

Landfill (after treatment) Landfill (after treatment)

Waste Disposal

Waste Treatment

Pig Slurry

Waste GenerationDiversification of farm land use towards sustainable rural real estate

Emphasis on sustainable and efficient farming practices to minimise number of heads and waste

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Finally disposal of manure must also be taken into consideration particularly following the treatment

of manure through digestion plants. In particular, this relates to the application of manure on crop

land, as well as the export option. The disposal of water which is generated through the treatment of

manure and any other output such as digestate will have to be disposed of in other manners following

treatment.

Table E.4: Options for the generation, treatment and disposal of cattle, and other livestock manure

An estimate of the financial costs of these options is presented in the report distinguishing between

three periods namely 2016, 2020 and 2030.

The total financial costs vary according to the volume of manure/slurry generated which in turn

depends on the number of heads and farming practices. Once again, a distinction is made between

the minimum and maximum scenarios.

A summary of the total annual financial costs for both the minimum and maximum scenarios is

presented in the Table below. Overall, the total costs which take into account the treatment and

disposal of cattle and other livestock manure and pig slurry could vary from €1.9 million to €22.8

million on an annual basis with the latter costs reflecting a greater reliance on the export option

particularly in the short term on account of the fact that the only existing option to cater for excess

cattle manure is the MBT plant. The maximum total costs of about €22.8 million in 2016 represents

31% of the turnover generated by the livestock sector. The imposition of this cost on the sector would

result in competitiveness issues and severely dent the sustainability of the sector. As a result, the

extent to which government can absorb part of these costs within the constraints of State Aid needs

to be studied.

In the 2020 and 2030 scenarios, the costs would be expected to decline reflecting the drop in the

number of heads of both cattle and pigs, though the costs in the maximum scenario remain significant

at an annual value of €17 million by 2030. In the case of the minimum scenario, it is possible for the

system to generate an overall revenue of €1.3 million. This also reflects the drop in livestock heads

but is also marked by the more efficient use of water in the management of agricultural waste. It is

also to be noted that the revenue is characterised by the sale of the cattle manure for application to

land which outweighs the costs of treating the excess of cattle manure and the disposal of pig slurry.

2016/2018 2020 2030

Digestion Malta North Digestion Malta North Digestion Malta North

Digestion Other Malta Digestion Other Malta

Digestion Gozo Digestion Gozo

Fertiliser Production Fertiliser Production

Thermal Thermal

Crop Land Crop Land Crop Land

Export Export Export

Sewer (after treatment) Sewer (after treatment) Sewer (after treatment)

Landfill (after treatment) Landfill (after treatment) Landfill (after treatment)

Waste Treatment

Cattle and Other Livestock Manure

Diversification of farm land use towards sustainable rural real estate

Emphasis on sustainable and efficient farming practices to minimise number of heads and wasteWaste Generation

Waste Disposal

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Table E.5: Summary of Financial Costs

The Need for an Effective Governance Structure

It is evident that in order to ensure the optimal use and treatment of manure in compliance with the

regulatory obligations of the country, a holistic governance structure is required. This is proposed in

Chapter 8 of the report which outlines in detail a proposed governance structure, the overall objective

of which is to continuously update, co-ordinate and implement the agricultural waste management

plan as a matter of national policy with the involvement of all key stakeholders. The proposed holistic

system would cater for the registration/acceptance of waste produced, the oversight of application to

fields consistent with regulatory arrangements, the implementation/oversight of treatment

approaches leading to production of fertilisers, energy and other output as well as the disposal of

residual waste including export of untreated waste.

The governance structure could ensure that the national system enters into long term agreements

with producers and users of manure and providers of treatment/disposal facilities to safeguard the

sustainability of its operations. In the short term, policy makers may consider implementing the

system in a manner to cater for the production, treatment and disposal of slurry which as explained

in the context section of the agricultural waste management plan, is the agricultural waste which is

clouded in most uncertainty and which is posing the greatest challenges for treatment and disposal.

Eventually the structure could be rolled out to cater for manure generated by all livestock including

cattle, goat, sheep, poultry and rabbit.

It is possible for the national system to function through the utilisation of a number of facilities,

possibly operated by both public and private operators under the principle of a Public Private

Partnership (PPP). In terms of funding, it is proposed that the system could fund the cost of its

operations and of its constituent parts, allowing for an element of reasonable profit, where relevant,

and subject to public policy decision making with respect to the agricultural sector. The system could

be financed through a combination of revenue sources, applied in a standard manner across all

operators although the rates would vary by the type of livestock, given that cost of treatment for

manure/slurry varies. The cost would need to take into account and implement the principle of

Pig Slurry Min Max

2016 1,141 14,362

2020 648 13,367

2030 210 11,614

Bovine and Ovine Manure Min Max

2016 728 8,414

2020 326 7,312

2030 1,546- 5,505

Total Min Max

2016 1,869 22,777

2020 975 20,680

2030 1,336- 17,119

Annual Financial Cost (€ 000s)

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recovery which on the one hand will dent the financial sustainability of the livestock sector and yet on

the other hand may be subject to State Aid scrutiny.

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1. Introduction

This report develops a plan to cater for the management of agricultural waste in Malta for the 2015

to 2030 period. The background research to the report has considered all elements of waste generated

by the sector including streams which fall under municipal waste, waste which is of a more

commercial/industrial nature (particularly taking the form of packaging waste) as well as that

pertaining to carcasses and streams normally associated with abattoir processes. It however

transpires that the main and pressing challenges with respect to agricultural waste in Malta lies with

the management of manure/slurry. Other waste streams are found to present far less significant

challenges as they are already subject to management systems, wherein the main issues which could

emerge in practice relate more to enforcement rather than system design. The need for effective

enforcement of rules in all aspects of waste management is an obvious consideration and is not

treated any further in this report. Consequently, this report focuses entirely on issues related with the

management of the generation, transport, treatment and disposal of agricultural manure and slurry.

Practices involved in the management of cattle manure and pig slurry in Malta require a review for

the country to meet its objectives and obligations with respect to water resource management and

related environmental issues, especially concerning groundwater and the treatment of waste water.

Manure treatment has important national implications for waste management and the associated

environmental and regulatory connotations as both Malta and Gozo are regarded as Nitrate

Vulnerable Zones in terms of the EU Nitrates Directive. Compliance and observance of the Nitrates

Directive in Malta became mandatory upon accession in 2004. This implies that as from this date, the

disposal of manure on agricultural land had to be handled in a viable manner with regards to the

environment.

At present, livestock breeders either use a fraction of manure produced on their farms on land which

they own or (as is in most cases) they sell the manure to be used as a fertilizer by land users. The

manure is then applied to land in a way that is not necessarily compatible with the best agricultural

practices. Regulatory procedures have been in place from 2004. Additional measures have been put

in place in 2011, in the new Nitrates Action Programme and LN 321/2011. These introduce practices

which ensure the proper application of manure on fields mainly focusing on application methods, and

balanced fertilizer application whilst taking into consideration storage facilities. Nitrates application

across the entire agricultural territory is in the process of being duly registered, monitored and

managed. Waste, particularly pig slurry, is also being disposed to the sewer system in a way which is

incompatible with requirements for discharge in this regard.

A number of farms, mainly in the cattle sector, have developed infrastructure to store manure during

periods when it cannot be applied to fields. Structures are designed to separate the liquid from the

solid elements, with the aim to enhance environmental management practices. Other sectors have

been less effective in investing in the required agricultural waste management infrastructure.

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This report builds on the previous agricultural waste management plan in Malta and seeks to extend

it further up to 2030. The report contains a context analysis which is structured over three chapters

with the second chapter presenting a review of literature spanning from relevant legislation, statutory

and policy documents, international experiences relevant to the management of agricultural waste.

The context analysis also reviews the current state of affairs in relation to the generation,

management and use of agricultural waste whilst identifying barriers hindering the development of a

sustainable system for the management of agricultural waste. A review and determination of current

agricultural waste quantities and future projections based on existing data and information, as well as

predictions for future changes in waste quantities taking into account sectoral developments is

presented in Chapter 3. Another important element considered in the report is the demand analysis

to determine the waste quantities that can be treated considering inter alia catchment area and

predicted waste generation quantities during the period of the proposed Plan and other factors

involving storage of manure, such as seasonal storage intended for land application. This is presented

in Chapter 4 of the report which provides the basis upon which the policy options are developed.

Chapter 5 details the elements involved in the derivation of strategic options with respect to manure

and slurry management in Malta and describes a number of scenarios which can be envisaged in future

in this regard. On these bases, a number of potential strategic approaches are outlined and a baseline

planning scenario is derived, for further consideration over the forthcoming phases of the assignment.

A more plausible scenario which takes into account the theoretical assumptions but is more

technically complacent with the situation in Malta is presented in Chapter 6 of the report which

provides a high level assessment of the treatment options. The options presented are based on a desk

study whereby the preliminary review of selected literature regarding the options for the

management of, in particular, cattle and pig manures has been undertaken. The desk study focuses

more intently on treatments that include de-nitrification of AD concentrate or raw slurries and for the

treatment of solids. The financial costs of the different options are presented in Chapter 7 which

provides a high level assessment of the costs and the ensuring costs per tonne of manure/slurry.

An important element of this report is the proposed development of a national system for manure

management which will address a number of market failures, including the insufficient availability of

cultivated land where manure can be applied, the vulnerability of the entire territory to Nitrates

contamination and the practical difficulties faced in terms of appropriate manure management by the

typically small and fragmented farm holdings in Malta.

The system will ensure an optimal use and treatment of manure and waste in compliance with the

obligations of the country and legal provisions in this regard. The system shall cater for the acceptance

of manure produced, and oversee its utilization through various options allowing for a combination of

approaches including application on fields, temporary storage, de-nitrification processes and the

production of renewable energy. There is a possibility for the national system to function through the

utilisation of a number of facilities, possibly operated by both public and private sector entities.

This report has been compiled by E-Cubed Consultants Ltd and ADI Associates for the Ministry for

Sustainable Development, Environment and Climate Change. The contents of the report have been

discussed with the Inter-Ministerial Committee on Farm Waste and the stakeholders within the

Committee.

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2. Policy and Legislation governing Agricultural Waste Management

The management of agricultural waste must ensure that existing policy and legal requirements are

respected. This Chapter describes relevant policy and legal instruments that should be taken into

consideration when drawing up an agricultural strategy.

The policy and legislative context will be guided by recent developments in the implementation of the

Nitrates Directive and the Urban Waste Water Directive. The discussions and relevant reports /

presentations being undertaken by an ad-hoc Farm Waste Steering Committee regarding Untreated

Farmyard Waste Discharges into the Sewerage Network are also informing this document.

The context for the discussion on the management of agricultural waste will also be framed within

existing waste management plans and strategies that have been formulated over recent years notably:

- Waste Management Plan for the Maltese Islands 2014-2020

- Agricultural Waste Management Plan for the Maltese Islands, 2008

Important legislation that affects the sector of agricultural waste management includes:

- Council Directive 91/676 of 12 December 1991 concerning the protection of waters against

pollution caused by nitrates from agricultural sources as transposed by Legal Notice 343 of

2001 Protection of Waters against Pollution Caused by Nitrates from Agricultural Sources

Regulations, 2003 and the Nitrates Action Programme (NAP)

- Council Directive 91/271/EEC of 21 May 1991 concerning urban waste-water treatment as

transposed into Legal Notice 340 of 2001 Urban Waste Water Treatment Regulations, 2001

- Council Directive 2000/60/EC of 23 October 2000 establishing a framework for Community

action in the field of water policy transposed into Maltese legislation as Legal Notice 194 of

2004 (Water Policy Framework Regulations, 2004)

- Council Directive 2008/98/EC of 19 November 2008 on waste and repealing certain Directives

as transposed by Legal Notice 184 of 2011 The Waste Regulations, 2011 as amended

- Council Directive 2008/56/EC of 17 June 2008 establishing a framework for community action

in the field of marine environmental policy (Marine Strategy Framework Directive)

- EC Regulation 1069/2009 laying down health rules concerning Animal By-Products and

derived products not intended for human consumption and repealing Regulation (EC)

No 1774/2002 (Animal by-products Regulation)

- Legal Notice 139 of 2002, Sewage Discharge Control Regulations, 2002

- Legal Notice 106 of 2007 Waste Management (Activity Registration) Regulations, 2007

- Legal Notice 321 of 2011 Nitrates Action Programme Regulations, 2011 as amended

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Other documents that will also provide insight into the local issues associated with agricultural waste

management include:

- The Nitrates Action Programme, 2011

- The Code of Good Agricultural Practice (CoGAP)

- The Water Catchment Management Plan for the Maltese Islands, 20115

- Partnership Agreement of Malta 2014-2020

- The Draft Rural Development Programme 2014-2020

- Programming of European Funds for Malta 2014-2020

- A Proposal for a National Energy Policy, 2009

- Rural Policy & Design Guidance, 2014

- Malta’s Biennial Report on Policies and Measures and Projected Greenhouse Gas

Emissions 2009.

2.1 Agricultural Waste in the Maltese Islands

Manure production in Malta is primarily derived from the farming of cattle, pigs, poultry, sheep,

rabbits and goats. Other waste generated on farms is municipal solid waste, packaging waste, and

hazardous waste in the form of containers for pesticides, expired medicines, etc. Animal slaughter

waste from public and private abattoirs is another important waste stream. Waste from tuna penning

/fish farming activities also include carcasses and other fish parts. Waste from agri-industries such as

the dairy, tuna processing, and tomato processing are also generated.

2.2 Current waste management policy

Any policy for the management of agricultural waste must fit within the current / projected national

waste management policies. Of particular relevance is the Waste Management Plan for the Maltese

Islands 2014-2020 (WMP 2014-2020). It is understood that this document brings together the EU

requirements to have a Waste Management Plan as well as a Waste Prevention Plan. The Plan

represents government’s planning document in respect of waste management. It is intended to set

out a holistic strategic direction in which Government envisaged the sector to be taken forward.

Importantly the national policy in the waste management sector is based on four principles:

1. to reduce waste and to prevent waste occurring, with a view to achieving a zero waste society

5 The Second Management Plan is expected to be published by the end of 2015.

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by 2050

2. to manage waste in accordance with the waste hierarchy, whereby it is recognised

that waste should be prevented or reduced, and that what is generated should be

recovered by means of re-use, recycling or other recovery options, in order to

reduce waste going to landfill, and to use the collection system to aid with

achieving these goals

3. to cause the least possible environmental impacts in the management of waste

4. to ensure that the polluter-pays principle is incorporated in all waste management

procedures.

The WMP 2014-2020 does not provide a framework for the management of manure as manure falls

outside the definition of waste as defined in the Waste Framework Directive. Although it identifies

that the Code of Good Agricultural Practice contributes to the better management of manure and it

identifies that Mechanical Biological Treatment Plant at Ghallis for the treatment of animal waste

there is no formal policy on the management of agricultural waste.

One of the options considered in the WMP 2014-2020 is to build capacity of waste collections systems

is the development is the development of an anaerobic digestion plant in Gozo for the digestion of

the organic fraction of MSW, animal manure and sewage sludge generated in Gozo. A civic amenity

site at Ta’ Qali is also planned to cater for the management of waste from the vegetable market

(Pitkalija) and the Marsa Thermal Treatment is planned to be upgraded to cater for the further

treatment of animal tissue waste.

Agricultural waste management is treated holistically in the 2008 Agricultural Waste Management

Plan for the Maltese Islands. This document comprehensively addresses all the waste streams

generated from the agriculture sector and provides recommendations for the management of these

wastes. The main recommendations emerging from the 2008 Plan are the construction of a number

of manure treatment plants in (i) Gozo (possibly also combined with the treatment of municipal solid

waste; (ii) the north of Malta (to treat 30% of manure/slurry generation, recommended to be

combined with treatment of MSW); and (iii) Siggiewi or another suitable location (to treat

approximately 25 - 35% of all the manure/slurry generation). The Plan stipulates a review after 2 years

to re-assess the need for investment in additional infrastructure (such as the possibility of constructing

a manure treatment plant at Sant Antnin, upgrading the Siggiewi plant, constructing a treatment

facility at Malta South or upgrading North Plant to take all of the manure/slurry generation.)

2.3 EU Directives & National Legislation Relevant to Agricultural Waste Management

Waste management legislation in Malta is shaped by the requirements of a number of EU Directives

mainly the Waste Framework Directive 2008/98/EC as transposed by the Waste Regulations, 2011

(L.N. 184 of 2011) as amended. The regulations provide the general requirements of waste

management in the Maltese Islands. They lay down some basic waste management principles such as

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the obligation to handle waste in a way that does not have a negative impact on the environment and

human health by managing waste sustainably in accordance with the waste hierarchy. The end of

waste status, polluter pays principle and extended producer responsibility are all enshrined in the

regulations.

Of particular relevance to the management of agricultural waste is the Nitrates Directive as transposed

by Subsidiary Legislation 504.43 Protection of Waters against Pollution Caused by Nitrates from

Agricultural Sources Regulations as well as Subsidiary legislation 504.108 Nitrates Action Programme

Regulations.

The Nitrates Directive (1991) aims to protect water quality across Europe by preventing nitrates from

agricultural sources polluting ground and surface waters and by promoting the use of good farming

practices. The Directive also requires the designation of Nitrate Vulnerable Zones, the formulation of

code/s of good agricultural practice and the preparation of Action Programmes in respect of

designated vulnerable zones. Monitoring of freshwater is also required and reporting to the

Commission is also an obligation.

The implementation of the Directive in Malta has brought about the designation of the whole Maltese

Islands as a Nitrate Vulnerable Zone, the formulation of a Code of Good Agricultural Practice, and a

Nitrates Action Programme.

Of particular relevance to the management of agricultural waste is the Nitrates Directive as transposed

by Subsidiary Legislation 504.43 Protection of Waters against Pollution Caused by Nitrates from

Agricultural Sources Regulations as well as Subsidiary legislation 504.108 Nitrates Action Programme

Regulations.

In order to implement the requirements of the Nitrates Directive, the Nitrates Action Programme

Regulations (LN321 of 2011) as amended require that:

All holdings greater than 0.5 of a tumolo prepare a fertiliser plan in accordance with the

requirements of the regulations;

Storage facilities for livestock manure must have a capacity of 5 months production of manure

and must be leak proof and connected to a cesspit that must also be leak proof and have a capacity

for 15 days of urine and washings;

Livestock manure can only be spread on fields between 16th March and 14th October if dry

matter is at least 30% in accordance with the requirements of the regulations;

Livestock manure is stored on fields subject to the provisions of the regulations;

Land application of slurry is not permitted;

For holdings greater than 1 hectare of continuous agricultural land a Nutrient Management

Plan must be formulated in accordance with the requirements of the regulations;

Farmers must keep farm records;

Fertiliser users must be registered and trained;

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The drawing up of a National Nitrates Database by the responsible Government entity.

The requirements are also reflected in the Code of Good Agricultural Practice (CoGAP) specifically

through the legislative framework 504.108 which consists upon the Implementation by , the Maltese

Government are improving provisions concerning the protection of waters against pollution caused

by nitrates from agricultural sources, wherein it is being ascertained that the provisions are in place

to implement the Nitrates Action Programme Regulations.

The fact that pig slurry is being disposed of in the sewerage system is leading to various non-full

compliance concerns. Of particular relevance are Council Directive 91/271/EEC of 21 May 1991

concerning urban waste-water treatment as transposed into Legal Notice 340 of 2001 Urban Waste

Water Treatment Regulations, 2001 and the Sewage Discharge Control Regulations, 2002 (Legal Notice

139 of 2002).

The location of farms (mainly swine and bovine) with respect to water features including water

courses and springs can also be subject to non-compliance issues. In order to address the risks that

farms operations pose to the quality of these surface waters, the Agriculture Directorate has

performed an assessment to determine those farms that pose the highest risk to these water bodies.

Through this study, there is now a system in place to identify the farms that are located closest to the

water bodies and therefore that pose the greatest risk. The risk weighting assists the competent

authority during monitoring controls. It is noted that MEPA’s Rural Policy and Design Guidance 2014

new and relocated cow and pig farms are to be located 300 metres from public groundwater

abstraction sources, poultry, goat, sheep and rabbit farms are to be located 200 metres from public

groundwater abstraction sources and small farms 100 metres away from such sources.

In terms of the application of manure to land, another study is currently being conducted by the

MSDEC in order to determine crop yields. In this preliminary study a comparative study of different

yields based on different inputs is being investigated with the aim to inform the preparation of

fertiliser plans by the farmer. Of particular relevance are the estimates for farmers to consider fewer

inputs.

The Sewage Discharge Control Regulations do not allow for discharge of farm waste into the public

sewerage system. Trade effluent can only be discharged to the public sewerage system if a permit is

in place. The practice of discharging livestock slurry into the sewage system through a designated

point in the system or through the drainage network is therefore illegal, albeit common practice

locally.

The quality of effluent in the sewerage system also has an impact on the urban wastewater treatment

plants that are designed to treat domestic effluent. The latter is typically lower in Chemical Oxygen

Demand (COD) Total Suspended Solids (TSS), and Total Nitrogen6 figures than effluent containing

animal waste. This has an impact on the operation of the treatment plants; only recently (February

2015) did the Ta’ Barkat Treatment Facility stop operating because of the clogging of system from

animal waste (http://www.timesofmalta.com/articles/view/20150226/local/farm-waste-clogs-plant-

80-of-sewage-going-in-sea.557717). The implications on the urban wastewater Directive are also

6 Farmyard Waste Steering Action Committee (2014) Inception Report – Untreated Farmyard Waste Discharges into the Sewerage Network

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important because when the treatment plants discharge raw sewage into the sea there is an

infringement of the Directive.

Schedule 1 of the Waste Management (Activity Registration) Regulations, 2007 (L.N. 106 of 2007)

provides a list of permitted waste disposal activities. The Legal Notice allows for on-site waste

treatment for farms that hold livestock. It includes a number of provisions such as reference to the

Code of Good Agricultural Practice, conditions for the construction of the manure clamp and cesspit,

ensuring that no manure is spread in the closed season, farms having an authorized slaughtering unit

should have a grease trap outside the slaughtering unit, connecting to the cesspit via a settling tank,

dead or fallen animals and slaughterhouse wastes are to be transported to the Thermal Waste

Treatment Facilities operated by Wasteserv Malta (WSM) for incineration, the operator of the

establishment is requested to keep records of the amount and volume of solid and liquid waste as

well as information on where such wastes are directed to, a registered waste carrier should transport

any waste generated by the establishment, consignment notes should accompany waste transfers

where applicable and a Waste Management Plan must be prepared.

Another important component of agricultural waste is animal by-products (APBs). They are regulated

due to the fact that they pose a potential risk to public and animal health and the environment. In

response to various crises affecting the safety of public and animal health and the environment in

2002, the European Commission introduced very strict rules for the collection, traceability, transport,

processing and safe disposal of ABPs (EC Reg.1774/2002). Following revisions, the new legislation (EC)

1069/2009 laying down health rules concerning Animal By-Products and derived products not

intended for human consumption, as well as its accompanying implementing Regulation 142/2011

were approved by the European Parliament and the Council of the European Union and have been in

force since the 4th March 2011. The provisions include issues that are relevant to the livestock and

farming community, the collection and disposal industry, incinerator operators, sea fish and shellfish

industries, the pharmaceutical industry, the catering industry, food establishments, retailers,

supermarkets, butcheries, the Government and non-Governmental Organisations, and the

enforcement Authorities – Veterinary Services amongst others.

Animal By-Products have been divided into three categories, each representing a different level of risk

associated with the waste material:

Category 1 Material which is the highest risk, and consists principally of material that is considered a

TSE risk, such as Specified Risk Material. Pet animals, wild animals, zoo and circus animals and

experimental animals are also classified as Category 1 material. Catering waste from all forms of

international transport (i.e. which has come from outside the EU) is also Category 1.

Category 2 Material is also high risk material and includes fallen stock, manure and digestive content.

Category 2 is also the default status of any animal by-product not defined in Regulation (EC) 1069/2009

as either Category 1 or Category 3 material. Category 2 material includes manure, non-mineralised

guano and digestive tract content, ABPs collected during the treatment of waste water, ABPs

containing residues of authorised substances or contaminants exceeding the permitted levels as

referred to in Directive 96/23/EC, products of animal origin which have been declared unfit for human

consumption due to the presence of foreign bodies in those products, products of animal origin - other

than Category 1 material - that are imported or introduced from a third country or dispatched to

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another Member State and fail to comply with Community veterinary legislation, animals and parts of

animals that died other than being slaughtered, foetuses, oocytes, embryos and semen which are not

destined for breeding purposes and dead-in-shell poultry.

Category 3 Material consists of low risk materials including parts of animals that have been passed fit

for human consumption in a slaughterhouse but which are not intended for consumption, either

because they are not parts of animals that we normally eat or for commercial reasons. They also

include former foodstuffs and domestic kitchen waste (within the scope of the Regulations).Different

waste streams must be handled accordingly and have different uses, depending on which category

they fall under.

In addition to regulations (EC) 1069/2009 and (EC) 142/2011, disposal of ABPs and derived products

should take place also in accordance with:

- Directive 2010/75/EU of 24 November 2010 on industrial emissions (integrated pollution

prevention and control)

- Council Directive 1999/31 on the landfill of waste as amended; and

- Regulation 1013/2006 of 14 June 2006 on shipments of waste as amended.

o In view of the current challenges related to agricultural waste management (see

section below), Directives that govern the marine environment are also of particular

relevance.

The Marine Strategy Framework Directive calls for the achievement of Good Environmental Status of

EU marine waters by 2020. This status is defined by 11 descriptors. Descriptor 5 seeks to ensure that

eutrophication is minimised. The release of raw sewage or sub-standard effluent (due to the waste

treatment facilities not operating according to design requirements) is likely to result in potentially

significant nutrient load to the marine environment at the outfalls. Similarly, the Water Framework

Directive requires that Good Status is achieved in all waters by 2015. This is determined both in terms

of ecological and chemical quality. It is noted, however, that in Malta’s Water Management

Catchment Plan 20117 three water bodies have been identified as having potentially less than-good

ecological status as required by the WFD and in all instances exemptions have been requested to

extend the deadline for the achievement of good status from 2015 to 2021.

In a recent Commission Staff Working Document8 on the implementation of the Water Framework

Directive Programmes of Measures, the Commission states that in its second River Basin Management

Plan Malta must:

Submit a plan on resolving the discharge of animal husbandry waste in the sewage collecting system

7 MEPA. 2011. The Water Catchment Management Plan for the Maltese Islands 8 European Commission. 2015. Commission Staff Working Document Report on the progress in implementation of the Water Framework Directive Programmes of Measures Accompanying the document Communication from the Commission to the European Parliament and the Council The Water Framework Directive and the Floods Directive: Actions towards the 'good status' of EU water and to reduce flood risks

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because the Maltese WWTPs had a performance problem as regards compliance with the COD

standards. This was linked to farm manure discharges in the collecting system.

In terms of emissions, the Agriculture sector accounts for a very small share of national Greenhouse

Gas (GHG) emissions, namely 2.7%.9 Methane is the main greenhouse gas emitted by the agricultural

sector, from enteric fermentation and manure management. Very small amounts of N2O are also

emitted from manure management and fertiliser use10.

2.4 Current Practice

In its Agricultural Waste Management Plan for the Maltese Islands, 2008, Sustech Consulting carried

out a thorough study to identify tonnage and volumes of dry and wet manure generated by livestock,

including cattle, pig, poultry (broilers and layers), and rabbits. The study identified that cattle is the

source of half of the dry manure, approximately a third of wet manure as well as half the nitrogen.

Whereas, whilst pig slurry represents over half the wet volume, dry pig manure only represents around

13% and contributes approximately 22% of nitrogen. Poultry dry matter represents around a third of

the total whereas wet matter constitutes just approximately 7%. Manure from rabbits represent very

little of the total (around 2% of total dry weight and less than 1% of wet).

- Manure and slurry from cattle and swine farms is stored on site in either cesspits or manure

clamps with bedding or separators in the case of cattle; swine farms do not currently use

separators (Envico Consultancy, 2013).11 Dry manure (from cattle) is then spread on fields

during the open season provided there is a demand for it.

- Pig slurry is in the main disposed of in the public sewer for want of alternative management

approaches which are in line with legal requirements in this regard.

- Poultry (broilers and layers) typically collect waste on a layer of bedding (broilers only) which

is then collected and used as manure in the open season. A manure clamp should also be

present on these farms.

- Sheep and goat operate a deep litter system.

A Mechanical Biological Treatment Plant is currently being constructed at Ghallis; this plant is designed

to treat 39,000 tonnes of manure mainly cattle and poultry. The quality of the output (compost) and

its use as a fertiliser on agricultural land is being discussed by the regulatory authorities. There was a

planning application for the relocation of dairy farms and the construction of a treatment facility in

Siggiewi. The state of the process is on hold. There was also interest in building a Mechanical Biological

Treatment Plant on Gozo but the call for studies issued was not awarded. In terms of animal by-

products, these are currently incinerated at the Marsa Thermal Treatment Facility. An autoclave will

9 Malta NIR 1990-2013. 10 MEPA. 2009. Malta’s Biennial Report on Policies and Measures and Projected Greenhouse Gas Emissions 11 EnviCo Consultancy. 2013. Report on Volume Excretion Figures (per animal type) for three main animal categories (sows, heifers & calves). Directorate of Agriculture, Ministry of Resources and Rural Affairs.

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be operational by 2016 and will be able to treat category 1, 2 and 3 of animal by-products.

2.5 Challenges associated with current practice & compliance

2.5.1 Cattle

Various reports on the management of agricultural waste (Sustech Consulting, 2008 and EnviCo

Consultancy, 2013) describe how most cattle farms, through support of the 2007-2013 Rural

Development Programme, underwent restructuring with the aim of ensuring compliance with respect

to reception and waste storage structures. Of these, a number of dairy farms opted for: a) a solid floor

system where solid manure is than stored in an approved manure clamp and any effluent is deposited

in cesspits; and b) slatted floor system with a manure separator. However, as reported by the ad-hoc

Farm Waste Steering Committee (2014), in practice operational costs associated with running the

separator resulted in certain farmers choosing either to not install or operate it and subsequently

storing the manure on site for the entire closed season, or disposing of it to the sewerage system

without separation.

At this stage, in the remaining cases where existing farms have not restructured their onsite waste

storage infrastructure, either they agree to relocate to form a cluster and install common

infrastructure or be subject to necessary action to be undertaken by the Authorities.

2.5.2 Pigs

As identified above, LN 139/02 does not allow for the disposal of animal liquid manure either directly

to the sewerage system or indirectly by bowser. Trade effluent disposal is only allowed where the

WSC has issued a public sewer discharge permit. However, in practice, the lack of any adequate farm

waste-water treatment plants or off-site biogas facilities has meant that the WSC has allowed for the

disposal of this waste fraction into the public sewer at three designated sites, namely, Mtarfa (site in

Gherreqin Road l/o Military Cemetery); Mqabba (site in the road to Mqabba); and Zejtun (site in

Zabbar Road); and Mgarr Road, l/o Xemxija, Gozo. However, due to the cost of transport and for

convenience sake, farmers use other, generally, inappropriate discharge points along the sewerage

network. The waste is generally not processed through a solids separator prior to disposal and this

can result in blockages of the sewage collection network, also affecting the wastewater treatment

plant operation. As a result the treatment operation has been compromised and recently (as reported

above) the Ta’ Barkat facility has closed for maintenance resulting in the discharge of raw sewage to

the marine environment. Overflows and infiltration of effluent are also known to occur. The current

system, therefore, of discharging into the sewerage network cannot continue. The revision of the

Malta Water Catchment Management Plan must include a commitment to address this issue.

From a data collection point of view, one of the challenges is the lack of a uniform collection of

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agricultural waste data. While MEPA collects data on agricultural waste, the remit lies solely with the

reporting of data at waste management facilities and not at source. Given this challenge, the actual

quantity of manure by type of livestock tends to vary particularly in the case of the pig sector whereby

the differing use of water to liquefy the manure into slurry results in varying published levels of waste.

Through the various discussions with stakeholders, it has also been observed that there is

fragmentation in the authorities’ roles and responsibilities associated with agricultural waste

management.

2.6 Discussion and Conclusions

The current scenario with regards to waste management in the Maltese Islands as described above is

clearly unsustainable and has resulted in increased public costs and environmental pollution. There

are three major aspects that need to be addressed in order to improve the situation. Firstly, the

strategic framework for agricultural waste management is absent. The Solid Waste Management Plan

2014-2020 only addresses municipal and industrial waste; it does not address the complete spectrum

of agricultural waste streams but only those which may be accepted in existing or planned waste

management facilities. Moreover, the 2008 Agricultural Waste Management Plan for the Maltese

Islands has not been officially adopted, and would in any case need to be updated following

developments in waste management over recent years. The establishment of an Agricultural Waste

Management Policy for the Maltese Islands is therefore crucial.

Secondly, the necessary infrastructure to manage agricultural waste is inadequate. MEPA has

approved permits for a Mechanical Biological Treatment Plant at Ghallis with a capacity to process

39,000 tonnes of manure per annum. A plan for the construction of 12 farms, a dairy waste digester

and waste conversion facility in Siggiewi is still subject to planning scrutiny.12 However, the planned

infrastructure does not deal with pig slurry. This large waste stream remains unaddressed.

Poor management practices, means that pig waste management uses large volumes of water, which

explains the seemingly significantly higher amount of waste generated. This is an aspect that needs to

be tackled at farm level and precede any disposal and treatment options.

Enforcement is crucially important to ensure that the current scenario, already operating not in

accordance with good practice, at least respects the interim agreed operational conditions.

The provision of adequate infrastructure is addressed in the strategic direction given in Malta’s

Partnership Agreement (2014-2020). Thematic Objective 4c of the Partnership Agreement (PA)

specifically addresses the treatment of animal waste through improved management practices and

the development of common infrastructure. The PA recognises that animal husbandry creates large

volumes of solid or liquid residues and waste products. The PA states that investment in additional

common infrastructure for the management of animal waste which cannot be handled by the

Mechanical and Biological Treatment (MBT) plant (for example pig waste) will be carried out. Such

12 PA 07823/06

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initiatives continue to be of significant importance given that the improved handling of animal waste

at source reduces the leakage of nitrates in the water system and reduces the need to remove nitrates

from the water system. Efforts will be directed to ensure continuous improvement through, though not

limited to increased education, support and technology.

It is understood that manure management will also be funded through the Rural Development

Programme 2014-2020 under investments in physical assessment (Article 17) and Co-operation

(Article 35). However, given that to date there are no planned facilities for agricultural waste

management and noting that such facilities would require planning permission and possibly an

Environmental Impact Assessment, the timing of funding these facilities in the 2014-2020

programming period is a key issue.

2.7 Barriers to the Implementation of Agricultural Waste Management Infrastructure

While it is clear that effort has been put into bringing the bovine sector in line with the requirements

emanating from the Nitrates Directive, there is still resistance to implement the necessary changes.

This resistance is likely to come from:

- The perception from the farmers that there is over-regulation and that too many conditions

are being imposed on them when they are facing increased competition from abroad;

- A cultural resistance to change;

- Costs of removal, storage, and treatment of manure also considering the double insularity

faced by Gozo;

- The inefficient capture, use and management of water that leads to wastes that have a high

water content;

- The lack of an agricultural waste management strategy means that there are no planned

facilities to address waste management from the sector with the consequent risk of losing

funding from the 2014-2020 period;

- Lengthy permitting procedures for waste management facilities especially for facilities that

require an IPPC permit; and

- Co-treatment of manure with MSW could result in compost that is not adequate from

spreading on agricultural land.

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3. Overview of the Agricultural Sector

The Maltese agricultural sector is a diversified sector, comprised of various activities which can be

grouped under different categories including horticulture, fruit and citrus growing, mixed and general

field cropping, different crops and livestock, ruminants including sheep and goats and animals. In

2014, the agricultural sector represented 1.3% of the total Gross Value Added13 generated by the

Maltese economy and accounted for 1.5% of all persons employed. Even though the sector’s

contribution to economic activity is low, agriculture through its multifunctionality plays an important

role in rural landscaping, cultural heritage and the maintenance and preservation of the environment

in Malta.

The sector is confronted by various structural constraints which impose an additional burden on its

competitiveness. Given that land is scarce due to the small size of the island, the sector faces

urbanization pressures. The economic rental value of land results in significant constraints related to

the opportunity cost of land. In addition, the sector faces problems related to water scarcity whereby

most of the water supply originates from costly desalinization.

The Maltese Islands also depend on import costs and high and fluctuating cereal prices together with

the increase of other input prices which are making the situation in the agricultural sector

unsustainable. As is explained further below, the sector is fragmented and characterised by small

holdings whose costs tend to be high given their lack of ability to exploit economies of scale. This issue

has become increasingly evident in the case of investment required for agricultural waste

management as lack of restructuring has seen a number of farms close down over the last few years

shrinking further the agricultural sector.

This section examines the main components of the agricultural sector in Malta. This analysis, on the

structure and characteristics of the Maltese Islands’ agriculture, serves as the basis to form the right

policies for waste and manure management. Malta and Gozo including Comino are analysed

separately given the difference in the specialisation of the livestock sector in the Islands.

3.1 Malta

This section of the report focuses explicitly on the number of farms and the respective livestock

distribution of farms located in Malta. The subsequent section focuses explicitly on the number and

type of farms present in Gozo. It is also to be noted that for the purpose of presenting the trend in

the development of the sector, latest data published by the National Statistics Office is utilised. More

recent data provided by the Agriculture Directorate is utilised to provide a snapshot of the sector as

at March 2015.

13 NSO (046/2015), Gross Domestic Product for2014.

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3.1.1 Number of Agricultural Holdings

On average, 73% of all holdings in Malta are relatively small and consist of less than 1ha of UAA.

Holdings with an area ranging between 1ha and 2ha of UAA represent 16% of the total hectares while

only 11% consist of an area greater than 2ha. It is to be noted that while the number of holdings in

Malta is relatively high, the holdings are small and fragmented thus severely limiting the potential for

these holdings to reap economies of scale.

Figure 3.1: Number of Agricultural Holdings by Size

Source: NSO, Agriculture and Fisheries (2013)

Figure 3.2: Utilized Agricultural Area (UAA) by Type

Source: NSO, Agriculture and Fisheries (2013)

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The Utilised Agricultural Area (UAA) is the total area taken up by arable land, permanent grassland,

permanent crops and kitchen gardens used by the holding, regardless of the type of tenure or whether

it is used as part of common land. Figure 3.2 shows that the total UAA in Malta which increased

marginally from 2007 to 2013. Land in Malta is mainly cultivated for forage production. In fact, forage

on average represents 41% of land use, followed by market gardening (17%), Kitchen gardens (10%),

other areas including fallow land (10%), potatoes (8%), vineyards (7%) and permanent land (5%).

3.1.2 Employment

Total employment within the agricultural sector in 2013 amounted to 14,995 representing 7% of the

total employment in Malta (including part-timers). The employment growth rate in agriculture

increased by an average rate of 5% annually between 2007 and 2013 fuelled by an increase in part

time employment. As can be seen from Figure 3.3 the number of males working in the agricultural

sector is predominantly much higher than the level of women working in the sector.

Figure 3.3: Total Employment in Agriculture by Sex

Source: NSO, Agriculture and Fisheries (2013)

The majority of workers in this sector, that is over 90%, are classified as part-time workers, clearly

indicating that agriculture is not the main source of income for most of the people representing the

farming community. Full-time employment amounted to 1,100 in 2013, that is 7% of all workers

engaged in agricultural activity. Between 2007 and 2013, full time employment declined by 24% while

part-timer employment increased by 12%.

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Data presented in Figures 3.5 and 3.6 is based on the Census of Agriculture carried out in 2010. Full-

time persons engaged in agricultural activity aged less than forty-five amount to 34% of all full-timers

while part-timers within the same age-grop amount to just 24% of all part-timers. Persons within the

farming community aged between 45 and 54 amount to 54% of the total employed while those

exceeding 64 years of age amount to 21% of all people employed within the agricultural sector.

Figure 3.4: Employment in Agriculture by Type

Source: NSO, Agriculture and Fisheries (2013)

This clearly highlights the fact that the sector is characterised by an ageing population where

employment is dwindling. The employment distribution between part-time employmnt and full-time

employment as well as the age distribution reflects the fragility of the sector in terms of its future

potential development. Indeed it can be argued that based on the presentation of employment data,

unlesee workers are enticed to seek employment in the sector, the downsizing in the sector is most

likely expected to continue.

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Figure 3.5: Full-time Agricultural Employment by Age Group

Source: NSO, Census of Agriculture (2010)

Figure 3.6: Part-time Agricultural Employment by Age Group

Source: NSO, Census of Agriculture (2010)

Figure 3.7 illustrates the employment stucture by Annual Work Units (AWUs). On average, 75% of all

workers enaged in agricultural activity work less than 25% of 1 AWU and 23% work between 25% and

100% of 1 AWU.

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Figure 3.7: Total employment (number of persons) in agriculture by Annual Work Unit (AWU)

Source: NSO, Agriculture and Fisheries (2013)

3.1.4 Livestock

The livestock sector in Malta includes cattle (primarily dairy together with some specialized beef

production), swine, poultry (both layer and broiler), goat, sheep and rabbits. Cattle farms reached a

peak of 336 holdings in 2007 and then declined to 242 farms in 2013. The drop in cattle farms post

2007 is mainly due to enforcements by the local authorities in relation to compliance with EU

standards and also due to the fact that cereal prices have increased significantly.

Figure 3.8 indictates that from all cattle farms, dairy farms in Malta represent about 33% for of

holdings. Other farms rearing cattle reached a peak of 231 holdings in 2007 and fell to 154 farms by

2013. Despite the fact that there are more farms catering for beef, the total number of heads is

predominantly much higher for dairy farms.

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Figure 3.8: Cattle Farms by Type of cattle in Malta

Source: NSO, Cattle Survey (2008-2014)

The decline in the number of farms is also reflected in a drop in the number of cattle heads. For the

period 2007-2014, the number of cattle heads in Malta was subject to a decreasing trend (Figure 3.9).

In fact, cattle heads declined by almost 3,164 heads or 24%, exceeding the 20% medium to long- term

decline predicted in the 2008 Agricultural Waste Management Plan. The decline was clearly significant

throughout the period post 2007, that is, just before the May 2008 planning permit application

deadline for investment in infrastructure with regards to the improvement of manure storage and

management. In addition, throughout the same period under review, dairy cattle were affected by a

disease outbreak which contributed to the decline in the dairy cattle population.

Figure 3.9: Development of the Number of Cattle in Malta, 2007-2014

Source: NSO – Agriculture and Fisheries (2011-2014)

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Dairy cows in Malta are the most important component of the cattle industry. Indeed, as previously

indicated, dairy farms hold a significantly high proportion of all cattle heads, dominating the cattle

industry. Figure 3.10 shows that on average, 85% of all cattle heads are reared within dairy farms. The

bulk of the cattle stock is found on farms holding dairy cows, which farms are considered relatively

average in size for the Maltese scenario and their owners are mostly full-time farmers. This data also

indicates that dairy production remains the primary source of income for the local herdsmen.

Figure 3.10: Distribution of Cattle by Farm Type in Malta

Source: NSO, Cattle Survey

A further breakdown of the type of cattle held on farms in Malta as at March 2015 is presented in

theTables below.

In terms of dairy farms, over 60% of farms in Malta hold less than 100 heads while 38% hold between

100 and 400 heads. The majority of these are males which are within the younger age group while

females are predominantly over 2 years old.

Table 3.1: Population in Dairy Farms by age

Source: Agriculture Directorate

M0-6m M6m-1y M1y-2y M2+ F0-6m F6m-1y F1y-2y F2+ Total

Malta 409 405 388 78 650 703 1,367 4,393 8,393

Gozo 328 218 266 31 400 433 773 2,379 4,828

Total 737 623 654 109 1,050 1,136 2,140 6,772 13,221

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Table 3.2: Number of Dairy Farms

Source: Agriculture Directorate

It is once again to be reiterated that the small size of these holdings poses investment challenges due

to the inability of these holdings to reap economies of scale. The distribution of the beef sector is

shown in Table 3.3 whereby as expected most of heads are male and over 6 months of age.

Table 3.3: Livestock in Beef Farms by age

Source: Agriculture Directorate

From a geographical perspective the majority of cattle farms are located within the Southern and

Northern districts although the predominantly larger ones are located in the Western region as shown

in Figure 3.11.

Table 3.4: Number of Beef Farms

Source: Agriculture Directorate

Malta Gozo Total Malta Gozo Total

0-100 48 14 62 60% 41% 54%

101-400 30 18 48 38% 53% 42%

Over 401 2 1 3 3% 3% 3%

Total 80 34 114 100% 100% 100%

M0-6m M6m-1y M1y-2y M2+ F0-6m F6m-1y F1y-2y F2+ Total

Malta 257 407 414 41 53 53 104 152 1,481

Gozo 10 9 12 - 2 7 12 9 61

Total 267 416 426 41 55 60 116 161 1,542

Heads Malta Gozo Total Malta Gozo Total

0-10 117 8 125 77% 80% 77%

11-50 33 2 35 22% 20% 22%

Over 50 2 0 2 1% 0% 1%

Total 152 10 162 100% 100% 100%

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Figure 3.11: Bovine farms geographical distribution

3.1.5 Pigs

Similar to the trend in the cattle sector, the pigs industry experienced a significant decline in heads

after 2007 (Figure 3.12). In fact, the number of pigs registered in Malta declined by almost 15%

between 2007 and 2008, down to 61,183 heads. Again, this was an effect of the May 2008 deadline

for applications on planning permits to improve the manure storage and management system on-

farm.

Unlike the development within the cattle industry, the number of pigs following 2008 remained stable

while increasing in 2009 and 2010 only to decline significantly thereafter. From 2007 to 2013 the

number of pigs declined by 26,588 (-37%).

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Figure 3.12: Development of the Number of Pigs in Malta, 2007-2013

Source: NSO , Pig Census (2011-2014)

A breakdown of the type of pig heads as at March 2015 shown in Table 3.5 indicates that the majority

in Malta are grow pigs followed by sows. In Malta, the majority of holdings, at 48% hold between 100

and 500 heads.

Table 3.5: Pig population by type

Source: Agriculture Directorate

The geographical distribution of the farms is shown in Figure 3.13. The majority of farms are located

in Malta, as opposed to Gozo and are mainly located within the Western district with only a few farms

located towards the North of the Island.

Sows Boars Gilts Grow Total

Malta 5,360 277 638 33,367 39,642

Gozo 508 11 57 1,965 2,541

Total 5,868 288 695 35,332 42,183

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Table 3.6: Pig Farms by size

Source: Agriculture Directorate

Figure 3.13: Pig farms geographical distribution

3.1.7 Poultry

Consistent with other livestock categories, poultry heads have also decreased over the period of

analysis. In Malta, layer chickens have experienced the most drastic decline with a 47% drop

experienced between 2005 and 2013. (Figure 3.14). While the number of broilers has also declined,

the drop has been less significant.

Pig Farm

SizeMalta Gozo Total Malta Gozo Total

0-100 25 3 28 26% 27% 26%

101-300 33 5 38 35% 45% 36%

301-500 13 2 15 14% 18% 14%

501-999 17 1 18 18% 9% 17%

Over 1000 7 0 7 7% 0% 7%

Total 95 11 106 100% 100% 100%

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Figure 3.14: Development of the Number of Chicken in Malta, 2005-2013

Source: NSO, Agriculture and Fisheries (2013)

The geographical distribution of the poultry farms by size is shown in Figure 3.15. There is a

predominance of more broiler farms. These farms in Malta are mainly located in the Western and

Southern districts. About 22% of the poultry holdings in Malta hold over 5,000 broiler heads and 13%

hold over 5,000 layer heads.

Figure 3.15: Poultry farms geographical distribution

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3.1.8 Goats and Sheep

The number of goats and sheep in Malta has also experienced a decline. Over the period 2007-2014,

figures for both species have declined with a steeper decline registered for sheep. In 2014 the total

sheep population amounted to 7,639. The amount of goats registered in Malta experienced, on

average, a decline of 5% annually.

Figure 3.16: Development of the number of Sheep and Goat in Malta, 2007-2014

Source: NSO – Agriculture and Fisheries (2011-2014)

A distribution of the livestock as at March 2015 is shown in the Table below. In terms of goats, the

majority are adult females. In Malta there are almost triple the amount of goats compared to Gozo.

In terms of sheep, the majority are ewes and in Malta there are about double the amount of sheep

than there are in Gozo.

Table 3.7: Goat and sheep population by age

KidsAdult

Male

Adult

FemaleTotal Lambs Rams Ewes Total

Malta 572 243 2,405 3,220 992 243 5,841 7,076

Gozo 213 55 976 1,244 666 51 2,392 3,109

Total 785 298 3,381 4,464 1,658 294 8,233 10,185

Goats Sheep

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3.2 Gozo and Comino

This section focuses more intently on developments in the livestock sector in Gozo and Comino.

3.2.1 Number of Agricultural Holdings

The number of agricultural holdings, in Gozo and Comino, between 2005 and 2007 remained relatively

constant, to increase by approximately 16% between 2007 and 2010 and then stabilize again to an

amount of 2780ha of UAA in 2013 (Figure 3.17). On average, 75% of all holdings are relatively small

and consist of less than 1ha of UAA. Holdings with an area ranging between 1ha and 2ha of UAA

represent 15% of the total hectares while only 10% consist of an area greater than 2ha. As highlighted

in the holdings analysis for Malta, areas fragmented into small areas will put limitations on the

potential benefits that can be extracted from the agricultural land.

Figure 3.17: Number of Agricultural Holdings by Size

Source: NSO, Agriculture and Fisheries (2013)

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Figure 3.18: Utilized Agricultural Area (UAA) by Type

Source: NSO, Agriculture and Fisheries (2013)

Figure 3.18 shows that the total UAA in Gozo and Comino amounted to 2,135 ha in 2005 to increase

by 2% between 2005 and 2007. It continued to increase to 2,889 ha in 2013 representing a 17%

increase. About 63% of the land in Gozo and Comino is cultivated for forage production, followed by

market gardening (12%), Kitchen gardens (10%), other areas including fallow land (7%), permanent

land (4%), vineyards (3%) and potatoes (1%).

3.2.2 Employment

Total employment for Comino and Gozo within the agricultural sector in 2013 amounted to 4,071

persons. The employment growth rate in agriculture increased by an average rate of 8% between 2007

and 2013. Figure 3.19 shows that simliiar to Malta the number of females employed in agriculture is

significantly less than that of males. In fact, on average, for the period 2007-2013, males represented

around 80% of the total employed population in the sector. The number of males working within the

agricultural sector between 2007 and 2013 increased by an average growth rate of 7.8% while the

amount of females engaged in agricultural activity increased by almost 6.9%, on average.

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Figure 3.19: Total Employment in Agriculture by Sex

Source: NSO, Agriculture and Fisheries (2013)

The majority of workers in this sector, over 90%, are classified as part-time workers, clearly indicating

that agriculture is not the main source of income for most of the people representing the farming

community in Gozo. Between 2007 and 2013, the amount of full-timers in the sector ranged between

185 and 316 persons (Figure 3.20). Full-time employment amounted to 272 in 2013, that is almost 7%

of the all people engaged in agricultural activity in Gozo. Between 2007 and 2013, full time

employment decelined by almost 14%. On the other hand part-timers increased by 18%.

Figure 3.20: Employment in Agriculture by Type

Source: NSO, Agriculture and Fisheries (2013)

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Data in Figures 3.21 and 3.22 is based on the Census of Agriculture carried out in 2010. Full-time

persons engaged in agricultural activity aged less than forty-five amount to 59% of all full-timers while

part-timers within the same age-group amount to just 22% of all part-timers. Persons within the

farming community aged between 45 and 54 amount to 53% of the total employed while those

exceeding 64 years of age amount to 23% of all people employed within the agricultural sector.

Figure 3.21: Full-time Agricultural Employment by Age Group

Source: NSO, Census of Agriculture (2010)

Figure 3.22: Part-time Agricultural Employment by Age Group

Source: NSO, Census of Agriculture (2010)

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Figure 3.23 illustrates the employment stucture by Annual Work Units (AWUs). On average, 70% of all

workers enaged in agricultural activity work less than 25% of 1 AWU and 18% work between 25% and

100% of 1 AWU.

Figure 3.23: Total employment (number of persons) in agriculture by Annual Work Unit (AWU)

Source: NSO, Agriculture and Fisheries (2013)

3.2.3 Cattle

As shown in Figure 3.24 the livestock sector in Gozo and Comino is composed of cattle (primarily dairy

together with some specialized beef production), poultry (both layer and broiler), goat, sheep and

rabbits and swine albeit the latter category is less relevant than in Malta.

Figure 3.25 indictates that from all cattle farms, dairy farms in Gozo represent an average of 78%

during the period 2007-2013. Other farms rearing cattle reached a peak of 14 holdings in 2007 and

fell to 10 farms by 2013.

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Figure 3.24: Distribution of all farms by size of livestock

Figure 3.25: Cattle Farms by Type

Source: NSO, Cattle Survey (2008-2014)

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For the period 2007-2014, the number of cattle heads in Gozo was subject to a decreasing trend

(Figure 3.26). In fact, cattle heads declined by almost 1,395 heads or 13%. The decline was clearly

significant throughout the period post 2007, that is, just before the May 2008 planning permit

application deadline for investment in infrastructure with regards to the improvement of manure

storage and management.

Figure 3.26: Development of the Number of Cattle in Gozo and Comino, 2007-2014

Source: NSO – Agriculture and Fisheries (2011-2013)

Dairy cows in Gozo are also the most important component of the cattle industry. Indeed, as

previously indicated, dairy farms hold a significantly high proportion of all cattle heads, dominating

the cattle industry. Figure 3.27 shows that on average, almost all cattle heads are reared within dairy

farms. This data also indicates that dairy production remains the primary source of income for the

local herdsmen.

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Figure 3.27: Distribution of Cattle by Farm Type

Source: NSO, Cattle Survey

As shown in Table 3.6, unlike the dairy farms in Malta which hold less than 100 heads, the majority

(53%) of farms in Gozo hold between 100 and 400 heads.

When it comes to beef farms in Gozo, as in Malta, they are small in size with about 80% of the farms

holding less than 10 heads (Table 3.4).

3.2.5 Pigs

Similar to the trend in the cattle sector, the pig industry in Gozo and Comino experienced a significant

decline in heads after 2007 (Figure 3.28).

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Figure 3.28: Development of the Number of Pigs in Gozo and Comino, 2007-2013

Source: NSO , Pig Census (2011-2014)

Tables 3.5 and 3.6 show that of the remaining 11 farms catering for pigs in Gozo, as at March 2015, 7

of them hold less than 500 heads.

3.2.6 Poultry

Figure 3.29 shows the level of poultry heads distributed between layers and broilers in Gozo. Unlike

Malta, the level of broilers have increased. On the other hand the number of layers have decreased

Indeed layer chickens have experienced minor trend changes over the analysed time period, ranging

from 54,932 to 110,917 heads between 2005 to 2013.

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Figure 3.29: Development of the Number of Chickens in Gozo and Comino, 2005-2013

Source: NSO, Agriculture and Fisheries (2013)

3.2.7 Goats and Sheep

The number of goats in Gozo is also less than the amount of sheep (Figure 3.30). Over the period 2007-

2014, the level of goats remained relatively constant while the number of sheep heads, like Malta,

also declined. In 2014 the total sheep population amounted to 2,887 in Gozo while the goat

population amounted to 1,136.

Figure 3.30: Development of the number of Sheep and Goat in Gozo, 2007-2014

Source: NSO – Agriculture and Fisheries (2011-2013)

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An analysis of the distribution of the livestock as at March 2015 presented in Table 3.7 shows that in

terms of goats, the majority in Gozo are adult females.

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4. Forecast of the Livestock Sector (2016-2030)

In order to derive a forecast of the livestock, a comparative country analysis has been undertaken to

assess developments in the respective livestock sectors in Malta compared to other countries within

the EU, particularly Mediterranean countries which are subject to similar terrain and climatic

conditions, such as Cyprus and Greece. The cross country comparison is undertaken on the basis of

population as well as land area in terms of km2.

4.1 Cattle

The cattle population on a per capital basis is lowest in the Southern Mediterranean countries namely

Greece, Cyprus and Malta reflecting the climatic conditions of the region and the respective challenges

associated with the sustainability of the sector. According to data published by Eurostat, the cattle per

population in Malta as at 2013 amounted to 0.03 compared to a significantly higher ratio of 1.4 in

Ireland.

Figure 4.1: Cattle heads per Capita

Source: Eurostat

A cross country comparison is also undertaken based on cattle per km2. It is interesting to note in this

regard that the while Cyprus and Greece continue to register a relatively low ratio of cattle per km2,

Malta with a land area of 316km2 registers one of the highest ratios. Indeed, as at 2013, the total

amount of cattle in Malta amounted to about 50 heads per km2. This is also to be considered in light

of the fact that Malta registers the highest population density ratios in the EU at 1265 inhabitants per

km2. In making this analysis, Malta is even more at a disadvantage because of the virtually complete

absence of grazing land, as opposed to the three countries which feature a higher ratio of cattle per

km2.

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Figure 4.2: Cattle heads per km2

Source: Eurostat

A snapshot of the development of the cattle sector in Malta between 2005 and 2014 allows for an

assessment of historic data which provides the basis of the forecast up to 2030. As can be seen from

Figure 4.3 cattle population in Malta has been persistently declining. This in part reflects the

restructuring process which has taken place within the sector whereby larger farms have invested in

appropriate facilities including waste management ones while the smaller and fragmented farms have

closed down as explained in further detail below.

Figure 4.3: Cattle Population MALTA

Source: Eurostat

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It is interesting to compare the development of the sector with Greece and Cyprus. The cattle sector

in Greece has also experienced a persistent decline in cattle with heads falling significantly in 2013

and with a further decline registered in 2014. On the other hand, the cattle sector in Cyprus

experienced a decline in heads up to 2009 after which it rebounded. This however is to be noted within

the context that the number of heads in Cyprus are low reaching about 59,000 in 2014.

Figure 4.4: Cattle Population Greece and Cyprus

Source: Eurostat

In order to forecast the expected number of heads to 2030 and derive the volume of manure, four

different methods have been utilised. The first method considers the extrapolation of past data based

on a log function. This function takes into account the growth of the sector in percentage terms over

time. The second method also uses past data but extrapolates through the use of an autoregressive

function. This type of function used to forecast the number of cattle heads is undertaken through the

use of a linear combination of past values of the variables itself. It thus takes into account also the

predicted change in the number of heads over the forecast horizon. The third forecast method is based

on the concept of convergence and thus it considers how the cattle sector in Malta is expected to

develop taking into account the development of the same sector in Greece and Cyprus. The

convergence criteria is based on two indicators namely sustainability which takes into account the

analysis presented in Figure 4.4 and hence analysis of the number of heads per km2 while the indicator

on security is captured through the number of heads in relation to the population. Based on these two

variables a convergence value has been derived which takes into account the average value between

Greece and Cyprus and with a respective weight applied to sustainability and security which varies by

sector. In the case of the cattle sector, the value of the sustainability indicator is 4.07 in Greece and

5.46 in Cyprus. This is in turn considered in relation to the value registered in Malta which amounts to

47.1 cattle per km2 such that the forecast considers a decline in the ratio. In terms of the security

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indictor the value in Greece and Cyprus is 0.06 per person and 0.07 respectively while the value in

Malta is 0.04 implying that convergence would require an increase in this indicator.

In this case the sustainability indicator is assigned a weight of 75%. Given the relative importance of

the cattle sector for dairy purposes, a weight of 25% has been applied to the security indicator. Based

on this analysis, the forecast of the number of cattle heads is expected to continue to decline albeit

to a lesser extent than through the use of the AR function. In fact, figures derived through the

convergence approach are similar to the forecast determined through the log approach.

In the case of the cattle sector, a fourth forecast method is utilised. The Agriculture Directorate has

presented an expert assessment on the sustainability of the dairy sector based on the number of farms

which have or have not restructured distinguishing between currently restructuring, those which are

to be relocated, have already applied for restructuring with the MEPA and those with are expected to

closed down also on account of the fact that they have as yet not restructured. As at March 2015,

there were 13,221 heads on dairy cow farms distributed in farms according to the breakdown

provided in the Figure below.

Figure 4.5: Total Heads on Dairy Cow Farms MALTA

Source: Agriculture Directorate

According to this data, over 75% of the dairy heads are located within farms which have already

invested in waste storage facilities. Of these, 56% of the heads are located within Malta and 44% are

located within the island of Gozo. About 7.5% of the dairy heads are located in farms which have not

to date undertaken any restructuring and which have already indicated that they will be closing down.

As can be seen from the Table below, the majority of these farms are located within Malta.

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Table 4.1: Restructuring of Maltese Dairy Farms

Further analysis is presented in the Table below which provides data on the number of farms and the

average size of the farms. It is clearly evident that the largest farms have already invested on farm,

are currently undergoing restructuring or are in the process of applying with MEPA. In addition, the

larger farms will also be relocated so that they are moved out of residential zones. The smaller farms

have either not restructured or else have already indicated that they will be closing down. The

restructuring of the sector is likely to persist as smaller farms close down while the larger ones

maintain operation.

Table 4.2: Size of Restructuring Farms

The fourth forecasting methodology is thus based on this assessment whereby it is assumed that the

number of dairy heads in farms which have already invested , are currently undergoing restructuring

or will be relocated will continue to experience a decline in line with sectoral developments albeit of

1% per annum up to 2020. Thereafter, it is assumed that the number of dairy heads in these farms will

remain constant. On the other hand for farms which have already applied with MEPA it is assumed

that the number of heads will decline by 25% up to 2016, by 1% per annum up to 2020 and remain

constant thereafter. Farms which will be closing down are assumed to do so by the end of this year

while the number of heads are expected to decline by half in 2015 and by 100% in 2016. In order to

derive the total cattle population the number of beef heads are assumed to remain constant from

2015 onwards.

Total

HeadsMalta Gozo

Invested on Farm 10,096 56% 44%

Restructuring ongoing 467 69% 31%

Relocation list 958 100% 0%

Applied with Mepa 705 73% 27%

No restructuring 825 95% 5%

Closing down 170 100% 0%

Total 13,221 63% 37%

Number of

farms

Heads/

farm

Invested on Farm 76 132.8

Restructuring ongoing 3 155.7

Relocation list 7 136.9

Applied with Mepa 7 100.7

No restructuring 12 68.8

Closing down 9 18.9

Total 114 116.0

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Based on this assessment, this forecast scenario which is also shown in the Figure below indicates that

while the decline in heads is expected to be maintained up to 2020, the number of heads are assumed

to remain constant thereafter as can be seen from Figure 4.6.

Figure 4.6: Forecast Cattle Population

Source: Authors estimate

4.2 Pigs

A similar analysis is undertaken for the pig farming sector. Figure 4.7 and 4.8 refer to the convergence

criteria used for the forecast. In terms of pig population per capita, Malta and Greece register

relatively low ratios of 0.11 and 0.09 per capita respectively. On the other hand, Cyprus has to a

greater extent focused the livestock sector on pig farming with about 0.4 heads per population.

It is interesting to once again note that assessing the sustainability of the sector through the number

of heads per km2 indicates that Malta registers a high ratio of 154 per km2. Cyprus and Greece register

lower ratios with Cyprus registering a ratio of 37 heads per km2 while Greece registers a ratio of 9

heads per km2.

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Figure 4.7: Pig Population per Capita

Source: Eurostat

Figure 4.8: Pig Population per km2

Source: Eurostat

In terms of developments in the pig farming sector in Malta over time, Figure 4.10 highlights a

persistent decline since 2005 with the number of heads amounting to 47,000 in 2014, almost half the

level registered in 2005. As identified in earlier sections of the report, the pig sector in Malta, unlike

the diary sector, has not invested in sound and sustainable agricultural waste management practices

to the same extent as the cattle sector. Furthermore as shown in Table 3.6 the pig sector in Malta is

characterised by a large number of farms which have a relatively low number of heads. Indeed, 62%

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61

of the pig holdings hold less than 300 heads and about 7% of the holdings hold 37% of the heads as at

2015.

It is evident from Figure 4.9 that the trend in the number of heads in the pig sector is in decline also

in Greece and Cyprus. While Cyprus, like Malta has registered a persistent decline in the number of

pig heads, the declining trend in Greece, which is more pronounced, started in 2011.

Figure 4.9: Pig Population Greece and Cyprus

Source: Eurostat

A decline in the number of pig heads is also evident across most other EU Member States. This is due

to a combination of factors but the underlying reason is one of an economies of scale through

concentration as the smaller farms have closed down while the larger ones have maintained

operations. According to a report published by Eurostat, the decline in pig herds is also attributed to

the low profitability of the sector coupled with volatility in the feed prices.14 Enhanced competition

from China has also resulted in a decline in the sector.

14 http://ec.europa.eu/eurostat/statistics-explained/index.php/Pig_farming_sector_-_statistical_portrait_2014

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Figure 4.10: Pig Population - MALTA

Source: Eurostat

Forecasts up to 2030 are shown in Figure 4.11 based on five forecast methods, three of which have

been explained above. The sharp decline in the sector is expected to persist albeit to a lesser extent

than that registered over the last ten years.

Figure 4.11: Pig Population Forecast

Source: Authors estimates

From a research perspective, while the autoregressive method is reported for the sake of

completeness, this scenario is discarded on the basis that:

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63

- the forecast is based on a time series involving a considerable downsizing which is not likely to be

repeated in future;

- the sector may in future be affected by a number of considerations that are not subject to forecasting

at this stage.

In terms of the convergence approach, the value is assumed to depend entirely on sustainability and

not on security given the lesser importance of the sector with respect to security. Based on these

observations, the total number of heads is expected to continue to decline reaching 7,000 heads by

2030 from a current level of 47,000 heads.

The fourth forecasting methodology applied in this case is based on the latest data of pig heads as at

March 2015 which is used as a base to extrapolate data linked also to the AR function. According to

this fourth approach the total number of heads will continue to decline. As can be seen from Figure

4.11 this forecast methodology is very similar to the number of forecasted heads derived through the

AR function with the exception of the level shift downwards in 2015.

An additional forecasting methodology is applied to determine the scenario of pig heads over the

period of assessment. This methodology is based on a less steep decline in the number of heads as it

is assumed that only farms which currently have over 300 heads are likely to be maintained in the

future. This is based on the assumption that the viability of pig farms depends on the size of the farm.

In part, farms of a larger size are more likely to engage in investment for the management of slurry.

Smaller farms, partly due to their size, may find that it is less viable to engage in such investment.

Furthermore enhanced competition is likely to limit even further the viability of smaller farms which

tend to register higher per unit costs. Based on this forecasting assumption, the number of heads is

likely to decline in a progressive manner reaching 34,480 heads by 2030 implying that 82% of current

level of heads registered as at March 2015. This approach is based on a policy direction as to the most

likely future scenario which the relevant authorities would be contemplating as most likely to consider

for the purposes of waste management planning.

4.3 Goats

Contrary to the analysis presented for cattle and pigs, both Greece and Cyprus have focused in a more

intensive manner on the rearing of goats and sheep as is evident from the Figures below.

The number of goats per km2 are the highest in Greece followed by Cyprus. Malta at less than 15 heads

per km2 also registers a high ratio compared to other Member States. Similarly, the goat population

per capita is markedly higher in Cyprus and Greece. The significantly high ratio reflects the importance

of the cheese (feta) market in these two countries which is derived from goats and sheep. Malta on

the other hand, despite the use of goats and sheep milk for the production of cheeselets and similar

products , registers a significantly lower ratio on a per capita basis.

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Figure 4.12: Goats per km2

Source: Eurostat

Figure 4.13: Goat Population per Capita

Source: Eurostat

While the goat population has been declining in Cyprus, Greece as well as Malta, there is scope for

the sector in Malta to develop further. Indeed small ruminant farming is an important economic

activity for European countries, especially those with a typical Mediterranean climate.15

15 Prevalence and Risk Factors of Gastrointestinal Parasitic Infections in Small Ruminants in the Greek Temperate Mediterranean Environment

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Figure 4.14: Goat Population Malta

Source: Eurostat

Figure 4.15: Goat Population Cyprus and Greece

Source: Eurostat

A forecast of the number of goat heads up to 2030 is shown in Figure 4.16 If one is to extrapolate the

forecast based on historical data through the use of the log function or the AR function, the number

of heads would be expected to continue to decline. However if one is to consider the potential of the

goat sector in line with the strength of the sector in Greece and Cyprus, then the convergence criteria

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allows for a forecasted increase in the number of goat heads. The convergence criteria is in this case

based on 85% sustainability and 15% security. As a result, the number of goat heads would increase

by about 1.6% per annum reaching 5,920 heads from the current level of 4,600 heads in 2030.

Figure 4.16: Goat Population Forecast

Source: Authors Estimate

4.4 Sheep

Likewise the sheep sector, which is also mainly utilised for the production of traditional cheeselets

and similar products, is also small in Malta compared to Greece and Cyprus. As can be seen from Figure

4.18, on a per capita basis, a proxy for sustainability, the ratio in Malta is among the lowest in the EU

while it is markedly higher in Cyprus and Greece.

In terms of sheep per km2 the ratio in Malta at about 34 heads per km2 compares well with Cyprus but

is lower than the ratio registered in Greece.

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Figure 4.17: Sheep Population per km2

Source: Eurostat

Figure 4.18: Sheep Population per Capita

Source: Eurostat

The development of the sheep sector, gauged through the number of heads is shown in Figure 4.19

and 4.20. Unlike developments in Malta where the sector has registered a decline over the last ten

years, the trend in Greece and Cyprus is a growing one. In Malta the use of goat milk and larger

quantities of cow milk to produce cheeselets played a role in the decrease of the sheep population.

(MDP, 2010). Other factors which may have played a role in the decline of the sheep sector is the lack

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68

of investment undertaken by the sector coupled with the fact that the ovine sector is mainly manned

by part-timers.

Figure 4.19: Sheep Population MALTA

Source: Eurostat

Figure 4.20: Sheep Population Greece and Cyprus

Source: Eurostat

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The forecast of the number of sheep heads is shown in Figure 4.21. Once again, similar to the forecast

for goats, the extrapolation of data based on the log function and on the AR function results in a

persistent decline in the number of heads.

On the other hand, if one is to consider the convergence approach and apply a weight of 90% on

sustainability and 10% on security, the number of heads would be expected to increase and to reach

the levels registered in 2005. This implies an annual growth rate of 2.4% per annum up to 2030.

Figure 4.21: Sheep Population Forecast

4.5 Potential Forecast Scenarios (Heads)

Given the prevalent uncertainty in the development of the livestock sector as well as the relatively

long forecast horizon over a fifteen years, this section of the report presents forecast scenarios ranging

between minimum and maximum values rather than a point estimate. The values are based on the

forecasting methods exercises explained in the previous section. The section essentially focuses on

the main livestock sectors which contribute towards agricultural waste management challenges in

Malta. In this respect, the report focuses intentionally on the cattle and swine sectors. Other sectors

which pose less of an agricultural waste management challenge such as the poultry sector have not

been included for the purpose of generating a manure forecast. Indeed, poultry waste is relatively

contained in terms of total generation, tends to pose less of a nitrates management challenge due to

its physical characteristics, and is planned to be in good part catered for within the Malta North waste

treatment plant. Furthermore, data on the volume of manure generated by rabbit and horse

husbandry was not available, though it is also considered that these volumes are also relatively

contained when compared to those generated by cattle and pig farming.

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Table 4.3: Forecast Scenarios

In terms of the cattle sector, both the minimum and maximum scenarios refer to a decline in the

number of heads which in 2030 may vary from 8,000 heads to 12,800 heads. It is to be noted that in

terms of the minimum scenario, the number of heads would be expected to decline in a persistent

manner over the forecasted horizon. On the other hand, the maximum scenario refers to values

derived from the analysis undertaken on the extent of restructuring undertaken by farms. In this case

the number of heads would be expected to decline further up to 2020 but it would be optimistically

expected to remain stable after 2020.

In the case of pigs, the minimum scenario is taken to reflect the convergence approach given that as

explained previously the AR approach has been discarded. The convergence approach refers to a

decline in the number of heads from 39,700 in 2015 to 7,940 by 2030. On the other hand, the

maximum scenario also refers to a declining trend albeit less drastic to 34,500 by 2030. As explained

in the previous section, this is based on the assumption that farms which currently contain over 300

heads are sustained over the timeframe.

Similarly, two scenarios based on the minimum and maximum values are presented for the sheep and

goat sector. In this case, the forecast values are derived from the three forecasting techniques used

for sheep and goat. The minimum scenarios for both the sheep and goat refers to a decline in the

number of heads. On the other hand, the maximum scenario which is based on the convergence

approach refers to a steady increase in the number of heads reaching 5,900 for goats and 15,300 for

sheep.

4.6 Potential Forecast Scenarios (Manure/Slurry)

This section of the report presents a forecast of livestock manure generation based on expected

developments in livestock heads presented in the previous section. This section also refers to the

minimum and maximum scenarios which are also ties to a varying level of waste per head.

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Table 4.4: Scenario Ranges for Manure and Slurry Production

The volume in cubic metres per year of waste generated by type of livestock is derived through values

presented by the Agriculture Directorate as well as published sources. In this regard, it is to be

appreciated that the estimates of waste production are subject to significant uncertainty, which is in

part reflected in the available international literature in this regard, as well as the absence of

sufficiently detailed studies focusing on the Maltese context. This uncertainty is invariably reflected in

the estimates provided in this study, but does not significantly impinge on the conclusions derived and

on the policy recommendations, which are in themselves aimed at dealing with uncertainty through

the establishment of a variety of measures allowing for a significant degree of flexibility in effectively

meeting challenges once their extent is established to a reasonable degree of precision.

In the case of manure production, estimates of production per head which can be obtained from the

literature vary as detailed in Table 4.5. The annual production in cubic metres of a typical 450kg dairy

female cattle varies from just below 10 to almost 18 according to various international studies.

Adjusted for the distribution of cattle of different sex and age in Malta, and based on their space for

storage for manure as per planning requirements as shown in Table 4.6, an estimate of the annual

production per cattle head in Malta is obtained. These very between 5.72m3 to 10.33 m3, as shown in

Table 4.5.

Table 4.5: Estimates of Manure Production Per Head of Cattle Livestock

Min Max Min Max Min Max Min Max

2015 80.5 145.4 12.5 157.3 1.2 1.4 94.2 304.1

2020 67.7 131.8 7.1 146.7 1.0 1.6 75.7 280.2

2025 55.4 132.0 4.1 136.4 0.8 1.7 60.3 270.1

2030 46.5 132.0 2.1 127.2 0.7 1.9 49.3 261.0

Scenario Ranges for Manure and Slurry Production (m3000s)

Cattle Pigs Goats and Sheep Total

Source Country Context

Annual Production

Per 450kg

Reference Head of

Cattle (m3)

Annual Production

per Head adjusted

for Distribution of

Cattle in Malta (m3)

Department of Agriculture and Fisheries,

Government of Queensland, Australia

Australia 9.86 5.72

United States Department of Agriculture,

New JerseyUnited States 13.20 7.67

American Society of Agricultural Engineers

(2005)United States 14.78 8.59

Vanderholm (1984) New Zealand 17.79 10.33

Sources :

https://www.daf.qld.gov.au/environment/intensive-livestock/cattle-feedlots/managing-environmental-impacts/manure-production-data

http://www.nrcs.usda.gov/wps/portal/nrcs/detail/nj/technical/cp/cta/?cid=nrcs143_014211

http://www.dairyingfortomorrow.com.au/wp-content/uploads/characteristics-of-effluent-and-manure.pdf

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Table 4.6: Basis for Per Head Production Adjustment for Malta

For the purposes of this study, it is considered appropriate to use the lower and upper values of these

ranges, as well as an average of these values which stands at 8.08m3. This is consistent with guidance

given by the Agriculture Directorate. This provides a range of manure generation standing between

80,500m3 and 145,600m3 in 2015, as shown in Table 4.4. For 2030, the range is between 46,500m3

and 132,000m3.

The wide range in the production of pig manure is due to the uncertainty in the practice of waste

management practices particularly in terms of the use of water to dilute the manure. Greater

uncertainty lies with the pig sector whereby the volume of manure waste may vary from 12,500 m3 in

2015 to a significantly higher volume of 157,300m3. This sector which is considered to pose the

greatest challenges in the implementation of the agricultural waste management plan as current

practices associated with the disposal of this manure cannot be continued. It may furthermore be the

case that this sector imposes larger challenges also from the amount of generation in volumetric

terms.

As expected, the level of manure generated by the sheep and goat sector is significantly less reflecting

the number of heads. In this case the total volume of manure may vary in 2030 from 700m3 to

1,900m3, which do not represent significant changes from the estimated 2015 levels.

Males 0-

6m

Males 6m-

1y

Males 1y-

2y

Males

2years+

Females 0-

6m

Females

6m-1y

Females

1y-2y

Females

2years+

Total

Heads

Number of Dairy

and Beef Heads

(2015)

1,004 1,039 1,080 150 1,105 1,196 2,256 6,933 14,763

% of total 6.8% 7.0% 7.3% 1.0% 7.5% 8.1% 15.3% 47.0% 100.0%

Production

relative to Female

2years+ = 1*

0.179 0.179 0.248 0.248 0.179 0.179 0.248 1.000 0.581

*based on planning requirements for cesspit and clamp sizing

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5. Strategic Options towards Manure and Slurry Management in Malta (2016-2030)

This section details the elements involved in the derivation of strategic options with respect to manure

and slurry management in Malta and describes a number of scenarios which can be envisaged in the

future in this regard. A number of potential strategic approaches are outlined in this section and a

baseline planning scenario is derived, for further consideration over the forthcoming phases of this

assignment. These scenarios presented are based on theoretical considerations and do not necessarily

reflect technical considerations. The derivation of effective strategic options towards manure and

slurry management in Malta depends on four factors:

1. the characteristics of the underlying manure and slurry generation and sink mechanisms,

intended as the expected development of the livestock industry and the absorptive capacity of

the crop industry in terms of manure and slurry being generated;

2. the constraints governing the system, the principal of which may be categorised into:

a. the need for Malta to meet its obligations as a Nitrates Vulnerable Zone entailing potential

constraints at three levels, from soft to hard:

i. a limitation not to exceed an application of N of 170kg/ha/yr on crop land;

ii. a limitation not to exceed the potential uptake by crops, which is estimated at around

110kg/ha/yr as per the Gross Nitrogen Balance (2007) study undertaken by the NSO;

iii. the need to potentially limit the application of N to crop land in a manner whereby crops

would be absorbing N already contained within the soil from over-application in

previous years16, to be as yet determined through specific studies regarding the N

content in soil and rendered effective through Nitrate Management Plans at the farm

level in conformity with the Code of Good Agricultural Practice.

b. the need for Malta to eliminate lack of compliance with the requirements of the Water

Framework Directive and the Urban Wastewater Directive in terms of bathing water

quality, which issue is arising principally from the discharge of slurry into sewers.

c. the need for Malta to sustain the economic competitiveness of the livestock farming, as an

integral component of the multi-functionality of agriculture in Malta, which calls for the

pursuit of cost-effective solutions to manure and slurry management;

d. likewise, the need for Malta to sustain the competitiveness of the horticultural sector ,

which entails the optimum use of fertiliser while meeting the requirements of Nitrate

Management Plans, which influences:

i. the quantity of fertiliser used;

ii. the mix between locally-sourced organic fertiliser and imported non-organic fertiliser

16 This has been estimated at 116.9km/ha in the 2007 Gross Nutrient Balance Study, the fourth highest among 19 EU Member States.

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3. the objectives to be optimised within the system which is taken to be the minimisation of the

financial and externality costs of the management system, including those related to:

a. manure and slurry management practices at the level of the livestock farms;

b. transport activities;

c. fertiliser costs applicable to crop farms;

d. the net costs of treatment to enable disposal in compliance with Nitrates and Water Quality

constraints, factoring revenues where applicable;

e. the costs of final disposal, including potentially, export.

4. the policy levers available, which could potentially include regulatory and financial instruments

influencing:

a. the management of manure and slurry on livestock farms, including issues such as:

i. the extent of water which is used and added to the volume of waste, particularly with

regards to pig slurry;

ii. the extent and location of discharges to the public sewers, which although currently

not permitted by legislation in Malta, are in effect taking place and could in future

potentially take place in conformity with the Water Quality Directive if effective prior

treatment is undertaken;

b. the methods of use of fertiliser on crop land, particularly with regards to the mix between

organic and inorganic fertilisers;

c. the potential development of treatment infrastructures to enable the sustainable and

legal disposal of manure and slurry, whether centralised or decentralised, at the local or

farm level;

d. the potential engagement in export of manure and slurry;

e. effective governance to cater for the potential establishment of a centralised system of

manure waste management, possibly at the separate regional levels of Malta and Gozo

The system features elements of uncertainty and is dynamic, entailing that changes in circumstances

are expected over time, which may themselves depend on actions taken in earlier periods. The main

elements of uncertainty emanate from:

1. insufficient data regarding critical state variables, particularly:

a. the volume of pig slurry generation, as this depends on individual on-farm practices

particularly with respect to the addition of water – while this does not alter estimates for

the mass of N, which depend upon the better-measured variable on the number of heads

of livestock, this variable would be critical with respect to such issues as transport and

treatment;

b. likewise, the amount of cattle manure generation is subject to uncertainty, and is at this

stage considered within a range established on the basis of available literature and subject

to the guidance provided by the Agriculture Directorate, as discussed in Section 4.6;

c. the amount of N which will be permitted to be applied to crop land in future years,

particularly because the extent of N currently present in the soil, and the way in which this

is to be dealt with, are at this stage not known;

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2. insufficient information regarding future trends in livestock farming, and to a lesser extent,

the value of utilised agricultural area. For the purposes of this study, a prudent approach is adopted,

whereby the number of heads will be assumed at maximum levels derived through the forecasts

provided earlier on;

3. uncertainty with regards to the effectiveness of policy measures, which will depend upon the

credibility of the governance system, the incentives provided and the extent to which operators would

have to deviate from their normal practices. For the purposes of this study, the likelihood and

potential extent of these types of risk will be indicated for suggested measures as may be relevant,

together with remedial measures as may be applicable. It is however to be noted that effectiveness

may be affected by the fact that the problem in Malta is one which is long-standing, and which has

time and again met with significant resistance to change;

4. uncertainty regarding the costs and potential benefits of key elements within the system,

including:

a. cost of inorganic fertiliser, whose price is typically volatile reflecting developments in

international commodity markets;

b. costs of treatment, which are themselves dependent on scale of infrastructures, and which

may in turn affect transport costs;

c. costs related to and availability of export markets.

The elements of dynamism in the problem emanate from factors including:

3. the measures adopted may themselves influence the development of livestock, and to a lesser

extent, crop farming in future years;

4. the adopted fertiliser plans which outline the extent to which N can be applied to crop land

may change in future as N content levels in soil are altered as a result of the actions taken.

Solutions must cater for risk through sufficient elements of flexibility, and evolve over time to cater

for expected changes in circumstances.

5.1 Scenario Analyses

The considerations made above are here presented in terms of possible scenarios which would lead

to a better understanding of the extent of waste to be managed over different periods of time, thereby

leading to the formulation of potential options. In formulating scenarios, a number of key variables

are exogenously determined as anchors across all scenarios, while others are set at different levels

across scenarios so as to examine effects on the results. Within the latter set of variables, there would

be ones which are subject to uncertainty, or which can be influenced by policy.

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The scenario analysis presented in this section focuses on the management of cattle manure and pig

slurry, with the understanding that these two elements constitute well over 90% of manure and slurry

waste streams in terms of volume, weight and mass of N. This is for the purposes of simplification of

analysis at this level.

This scenario analysis focuses on four representative years in the context of the horizon covered by

this study, namely 2015, 2020, 2025 and 2030. Its aim is to identify, in each of these years and subject

to different system conditions, the amount of manure and slurry which would require treatment for

eventual disposal and/or export, measured in terms of both kilograms of N and cubic metres of

material. This would subsequently enable a mapping of policy alternatives under different situations,

including the identification of solutions which afford important degrees of flexibility in the face of

uncertainty. The anchors which are held constant across all scenarios are shown in Table 5.1.

Table 5.1: Anchor Variables for Scenario Analyses

The anchor variables relate to N generation through manure and slurry, and the potential uptake of

the same by crops in each year covered by the analysis. For the purpose of deriving the options, the

number of heads are conservatively considered, for the purposes of this analysis, at the maximum

levels obtained through the forecasting exercise presented earlier on. This is multiplied by the rate of

N generated per thousands of head per year, amounting to 51,887 for cattle and 9,993 in the case of

pigs17. The total N generated is estimated at 1,158,307kgs in 2015, dropping by 12.6% to 1,012,853

kgs by 2030, on account of the expected reduction in livestock heads. Out of the total, the share of N

generated by pigs is expected to fall from 36.8% to 34.4%. For the purposes of this exercise, the

conversion from N to cubic metres of cattle manure equivalent is affected on the basis of the average

level of manure generation per head from the range of estimates provided in Section 4.6.

The uptake of N by crops is based on an estimate of the 2015 value for utilised agricultural area, set

at 11,618 on the basis of the values reported by the NSO in the publication on Agriculture and Fisheries

in 2013. In recognition of a potential consolidation of future activity, this value is conservatively

estimated to drop by 0.5% per annum. The N uptake by crops is calculated on the basis of the

estimated uptake per hectare found in the 2007 Gross Nitrogen Balance study, which is approximately

110kg/ha. This implies an estimated uptake of 1,274,323 kgs in 2015, dropping by 7% to 1,182,022 kgs

17 These values are sourced from the Gross Nitrogen Balance Study, 2007, published by the National Statistics Office, and is consistent with a number of scientific sources.

2015 2020 2025 2030

Cattle

Heads (000s) 14.1 12.8 12.8 12.8

N (kgs) 731,602 664,149 664,149 664,149

volume (m3) 113,891 103,391 103,391 103,391

Pig

Heads (000s) 42.7 34.9 34.9 34.9

N (kgs) 426,705 348,703 348,703 348,703

Total N (kgs) 1,158,307 1,012,853 1,012,853 1,012,853

UAA (ha) 11,618 11,330 11,050 10,776

N uptake by crops 1,274,323 1,242,781 1,212,021 1,182,022

N Application to Crop

Generation

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in 2030. It is to be noted that the potential uptake of N is higher than the generation of N throughout

the forecast period.

The extent to which the N generated will however be absorbed by crops is in this analysis made

dependent on two variables which constitute the bases of the formulation of the different scenarios.

These are:

1. the extent of use of inorganic fertiliser, which would thus crowd out the use of manure, with

this variable considered at three different levels namely:

a. no use of inorganic fertiliser;

b. inorganic fertiliser is used to an extent of 25% of total intake by crops i.e. an annual

average of 306,947 kgs during the period;

c. inorganic fertiliser is used at a level of 635,000kgs, that is the value reported in the

2007 Gross Nitrogen Balance study;

2. the extent to which an uptake of N by crops from soil content is prioritised over the application

of fertiliser, which is also considered at three different levels:

a. no prioritisation, whereby all uptake will be satisfied through organic and inorganic

fertiliser, without there being any over-application of fertiliser;

b. 25% of crop uptake is prioritised to be taken from soil between 2015 and 2020;

c. 50% of crop uptake is prioritised to be taken from soil between 2015 and 2020.

Scenarios 2b and c are assuming a soil restoration period of five to six years, programmed to occur by

means of a reduction in fertiliser use, of different intensities. This will depend on the extent of N

content which is already existent in the soil.

Table 5.2: Scenarios

2015 Scenarios

Surplus N (kgs)m3 of cattle

manure eq

Surplus N

(kgs)

m3 of cattle

manure eqSurplus N (kgs)

m3 of cattle

manure eq

None 116,015- - 202,565 31,534 521,146 81,129

25% of crop uptake 202,565 31,534 521,146 81,129 839,727 130,723

2007 level 518,985 80,792 837,565 130,387 1,156,146 179,982

2020 Scenarios

Surplus N (kgs)m3 of cattle

manure eq

Surplus N

(kgs)

m3 of cattle

manure eqSurplus N (kgs)

m3 of cattle

manure eq

None 229,929- - 80,767 12,573 391,462 60,940

25% of crop uptake 80,767 12,573 391,462 60,940 702,157 109,308

2007 level 405,071 63,059 715,767 111,426 1,012,853 157,675

Surplus N (kgs)m3 of cattle

manure eq

Surplus N

(kgs)

m3 of cattle

manure eq

None 199,168- - 169,169- -

25% of crop uptake 103,837 16,165 126,336 19,667

2007 level 435,832 67,848 465,831 72,518

None 25% of uptake 50% of uptake

Prioritisation of Uptake of N from Soil by Crops between 2015 and 2020

Inorganic fertiliser

use

Prioritisation of Uptake of N from Soil by Crops between 2015 and 2020

Inorganic fertiliser

use

None 25% of uptake 50% of uptake

Inorganic fertiliser

use

2025 Scenarios 2030 Scenarios

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In each scenario, it is assumed that the application of fertiliser would in no circumstance exceed the

potential uptake by crops during a particular year. It is further assumed that there is no disposal of pig

slurry into the public sewer network.

In the 2015 simulation, results indicate possible surplus N values of between 200,000kgs and

840,000kgs, with a potential extreme value of 1,160,000 kgs. These correspond to an equivalent

volume of cattle manure18 of between 31,500m3 and 130,400m3, with a potential extreme value of

180,000m3. In the 2020 scenario, the maximum amount of N surplus is estimated at an equivalent of

157,700m3 of cattle manure. In the 2025 and 2030 scenarios, the results indicate that the maximum

surplus of N would be in a range between 68,000m3 and 73,000m3 of cattle manure equivalent.

These results are summarised in Figure 5.1, which shows the range of results for each year. Across the

time horizon of the analysis, a shift from the potential maximum to the most likely results can be

affected by limiting the application of inorganic fertiliser up to 25% of the total uptake by crops. Annex

1 to this report presents the full details of the simulation results presented here.

Figure 5.1: Potential Range of N Surplus

5.2 Implications of this Analysis for Strategic Options

The following general implications to be further considered in deriving strategic options which emerge

from this analysis are:

- the use of manure and pig slurry as a fertiliser for crops is not inconsistent with the country’s

obligations in terms of the Nitrates and Water Quality Directives in the long term. While it

18 This equivalent value captures N surplus arising from the aggregate of cattle manure and pig slurry, translated into a corresponding volume of cattle manure. The latter base is selected because of variations in the N content of pig slurry volumes.

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is recognised that it is not currently permitted to use pig slurry as a fertiliser the use of slurry

at the level of developing the strategic options from a theoretical perspective is not ruled

out at this initial stage of strategic considerations – the implications of more realistic

scenario where such slurry is not applied to crops is considered further on;

- over the forthcoming 10 year period, the system needs to manage a total surplus of at least

580,000m3 of cattle manure equivalent, with a potential annual peak of around 120,000m3

and an average of 83,000m3.

The solution over the coming ten years can feature a mix of:

- limitations on the application of inorganic fertiliser;

- on-farm measures to improve the marketability and use of organic fertiliser including:

- reduction of water input to facilitate transport and excessive leaching of nitrates and other

constituents;

- treatment/processing so as to obtain better controllability of N content within organic

manure;

- extension of open season, in view of Malta’s climate, to obtain a more stable flow of activity

and better manage storage facilities;

development of treatment facilities for denitrification and production of energy and/or

compost, at capacity levels which are efficient in the context of the expected decline in

surplus N over the 10-year period;

consideration of exports of excess N for a short term period should such an approach be

needed and prove to be more financially viable.

The next step in this analysis, which will follow in the forthcoming phase of work, will be to develop

concrete scenarios based on estimations of actual costs and benefits in order to arrive at the

identification of a preferred solution. It is furthermore to be considered that the Malta North facility

for municipal and manure waste treatment, which is expected to come on line by 2017, will already

have a capacity to treat around 39,000 m3 of cattle manure. In this sense, it should already be an

important part of the solution which can be envisaged for the Island of Malta.

Due to issues of transport, it is likely that such solutions would need to focus on the Islands of Malta

and Gozo separately, and possibly at two distinct regions in Malta.

5.3 Discussion on a Potentially Realistic Scenario

A practicable approach to take this discussion forward is to view these conclusions in terms of a

potentially more realistic scenario whereby:

- only manure is used for the purposes of application to crops;

- pig slurry is neither applied to land nor discharged to public sewers;;

- restrictions on the application of inorganic fertilisers within the context of the observance of

Nitrates Management Plans may not necessarily be either feasible or totally desirable;

- the restrictions on total N application associated with Fertiliser Plans will are adhered to.

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The scenario results in this approach, which are presented in full detail in Annex 2 are summarised in

Table 5.3 and Figure 5.2.

Table 5.3: Scenarios where Only Cattle Manure is Applied to Crops

Figure 5.2: Potential Range of N Surplus (Only Cattle Manure in Applied to Crops)

In this case, 2015 results indicate a likely range of N surplus of up to 64,000m3 per annum of cattle

manure, with an extreme maximum of just over 113,000m3 per annum. By 2020, these indicators are

2015 Scenarios

Surplus N (kgs)m3 of cattle

manure eq

Surplus N

(kgs)

m3 of cattle

manure eqSurplus N (kgs)

m3 of cattle

manure eq

None 542,721- - 224,140- - 94,441 14,707

25% of crop uptake 224,140- - 94,441 14,707 413,021 64,317

2007 level 92,279 14,370 410,860 63,981 729,441 113,591

2020 Scenarios

Surplus N (kgs)m3 of cattle

manure eq

Surplus N

(kgs)

m3 of cattle

manure eqSurplus N (kgs)

m3 of cattle

manure eq

None 578,632- - 267,937- - 42,759 6,659

25% of crop uptake 267,937- - 42,759 6,659 353,454 55,041

2007 level 56,368 8,778 367,063 57,161 664,149 103,424

Surplus N (kgs)m3 of cattle

manure eq

Surplus N

(kgs)

m3 of cattle

manure eq

None 547,872- - 517,873- -

25% of crop uptake 244,866- - 222,367- -

2007 level 87,128 13,568 117,127 18,240

None 25% of uptake 50% of uptake

Prioritisation of Uptake of N from Soil by Crops between 2015 and 2020

Inorganic fertiliser

use

Prioritisation of Uptake of N from Soil by Crops between 2015 and 2020

Inorganic fertiliser

use

None 25% of uptake 50% of uptake

Inorganic fertiliser

use

2025 Scenarios 2030 Scenarios

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expected at almost 58,000m3 and 103,000m3. By 2030, the surplus is expected at no more than

19,000m3 per annum.

The Malta North plant having a capacity of 39,000m3 per annum can therefore be expected to play an

important role in dealing with the excess N from cattle manure, albeit not to the extent of providing

a full solution to the country’s requirements. This is furthermore subject to two important

considerations:

1. there may be scenarios where the surplus N from cattle manure may, over the period around the

year 2020, be around 60,000m3 per annum in excess of the treatment capacity of the Malta North

plant;

2. the governance and management systems to ensure the effective application of the required

cattle manure on fields and the delivery of surplus manure to the Malta North plant and additional

facilities are still to be put in place.

The implications of this approach for the strategic options analysis presented earlier on are therefore

to focus on the need to:

manage pig slurry, in a range between 350,000kgs and 425,000kgs of N per annum, or up to

150,000m3, strongly depending on water content;

provide for potential additional capacity/capability for managing up to 60,000 m3 for cattle

manure, and around 5,000 tonnes of manure of other animals per year;

devise a governance and management system for effective operation.

The next phase of this work will review a number of technological options in this regard, and provide

high level feasibility conclusions.

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6. High-Level Assessment of Treatment Options

The previous section focused on nitrogen surplus from agricultural wastes in comparison with the

requirement for nitrogen as a fertilizer. This is important so that the Fertiliser Plans can be adhered

to. However, the management of nitrogen (and indeed other nutrient components) of agricultural

wastes represents only one part of the complex issue to be addressed. Also of particular importance

is the solid content in comparison with the liquid fraction, which is of relevance to the nitrogen

availability.

As noted above, there is a great deal of uncertainty regarding the quantities of agricultural wastes and

their properties, in particular relating to the composition of pig slurry, which is dependent on the

proportion of water added as a result of management practices in washing down as highlighted in the

Pig-slurry load to Malta North Sewage Treatment Plant Assessment Study Report (COWI, 2005). The

report notes that if water saving incentives were introduced, significant reductions in the volume of

pig slurry could be achieved, with favourable comparisons between Maltese pig management and that

in Denmark, where slurry production of 1m3 per annum per head is quoted.

Much emphasis has been placed around the world in recent years on nutrient management plans to

avoid nutrient leaching to groundwater (hence the Nitrates Directive) or to surface waters leading to

eutrophication. A great deal of research and effort has gone into management plans for animal wastes

and manures to optimise nutrient utilisation and minimise nutrient loss by run-off or leaching,

including restricting the period during which manures or slurry can be spread, taking into account the

season, weather conditions, topography and so on. Further effort has gone into developing techniques

to apply animal based fertilisers to soil to avoid ammonium nitrogen volatalisation; hence nitrogen

loss, thus maximise nutrient uptake, and minimise other environmental impacts such as odours

associated with land application. However, reliance on those management plans alone is not

applicable in the Maltese situation, where it can been seen from Table 5.3: Scenarios where Only

Cattle Manure is Applied to Crops that, taking nitrogen alone, there is a calculated excess of nutrients

arising from agricultural wastes in comparison with the requirement for soil crops.

Key strategic options for the management of nitrate identified above include:

1. Limitations on the application of inorganic fertiliser (maximising agricultural waste for nutrients;

hence reducing the requirement for further treatment of farm wastes);

2. On-farm measures to improve the marketability and use of organic fertiliser including:

a. reduction of water input to facilitate transport and excessive leaching of nitrates and

other constituents;

b. treatment/processing to obtain better controllability of N content within organic manure

c. extension of open season, in view of Malta’s climate, to obtain a more stable flow of

activity and better manage storage facilities;

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3. development of treatment facilities for denitrification and production of energy and/or

compost, at capacity levels which are efficient in the context of the expected decline in surplus

N over the 10-year period;

4. consideration of exports of excess N for a short term period.

Of these, Option 1, 2a and 2c require policy decisions and/or financial incentives to drive changes in

agricultural practice. They also require detailed analytical studies to determine the level of existing

nitrates by parcel of land and the extent to which further nitrates can be applied to land. Option 4

requires the identification of markets but for the purpose of this report is studied at a high level in

particular taking into account the logistics associated with this option and the costs involved with

exporting manure/slurry. Further consideration is given here to technical options to Option 2b and 3,

although option 3 contains a number of options within it.

6.1 Critical Parameters

In looking further at the options, it is important to note that some significant policy decisions have

been taken, namely:

To ban the application of slurry or liquids directly to land.

To effectively prevent the discharge of pig slurry to the sewage system which is considered

more important in light of the EC recommendation on the implementation of the Water

Framework; and

To develop the Malta North anaerobic digestion system (MBT).

It is understood that, at least in part, the decision to stop accepting pig slurry to the sewage system is

due to the COD loading placed on the treatment system and the cost of treatment in comparison with

that for treatment of human sewage.

The physical attributes of the wastes are of importance. Slurry, by its nature, is high in liquids and low

in solids, whereas dry manure has a higher solids content. The distribution of carbon and nutrients is

related to a certain extent to the two fractions; carbon (and COD) and phosphorous tend to be

concentrated in the solids, nitrogen in the liquid fraction, although some nitrogen is found in organic

form, typically associated with the solids fraction and that can be released on breakdown of the

organic materials. The actual loading and concentrations of the available and organic nitrogen is likely

to vary depending on the source of the manure or slurry (for example in pig slurry, the majority of

nitrogen is likely to be found as available ammonium-nitrogen predominantly in the liquid fraction,

whereas in cattle farmyard manure, the majority of the nitrogen is likely to be found in organic form

in the solid fraction). This could influence the choice of options.

Other factors associated with the origin of the manure will influence options, in particular the

carbon:nitrogen ratio. Pig manure tends to have a low carbon: nitrogen ratio (in the order of 6:1 to

8:1, but again variable depending on the source), whereas cattle manure has a higher carbon to

nitrogen ratio. This is relevant when considering biological treatment options; good anaerobic

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digestion requires a carbon:nitrogen ratio in the order of between 16:1 and 30:1 (various authors

quote different values depending on feedstock and process controls).

6.2 Current Policy and Practice

In recent years within Europe and elsewhere there has been a move to the development of anaerobic

digestion facilities as part of the management plan for agricultural wastes, including pig manure, for

instance as part of the BalticSea2020 foundation pig manure management plan19. One of the principal

drivers is the incorporation of anaerobic digestion in waste management strategies. Its benefit is the

production of “renewable energy”. As the animal wastes represent biogenic wastes containing carbon

that has been locked up in the recent past, it can be considered that CO2 would be released in any

case from these sources as a result of degradation (short cycle carbon). Other benefits of anaerobic

digestion of animal wastes are the improved fertilizer value as a proportion of the organic nitrogen is

converted to mineral fertilizer; hence facilitating more accurate control of nitrogen application to land.

The by-product of anaerobic digestion is a digestate that can be separated into a liquid fraction, in

which the majority of the nitrogen is found, and a solid fraction with the majority of the carbon and

phosphorous. When applied as part of an overall “closed loop” agricultural management plan, the

segregation of these fractions may allow more accurate dosing of nitrogen and phosphorous than

direct manure application (manure applications that comply with the nitrogen load allowed by the

Nitrate Directive maximum may provide an excess of phosphorous fertilization).

Whilst advantageous in agricultural fertilizer management, when taking account of the calculated

excess nitrogen requirements, these advantages do not provide a solution to agricultural waste

management in the Maltese context although the possibility of exporting the fertilizer remains an

option.

As identified previously, the Malta North anaerobic digestion facility is under construction, designed

to accommodate municipal waste and in the process will allow for the co-mingling of 39,000 tonnes

per annum of animal manure. However, whilst anaerobic digestion will reduce the organic loading,

the digestate will still contain a significant organic and nutrient content. It is understood that

discussions have been on-going with regulators regarding disposal options for the digestate from the

Malta North facility, including the use of the solids fraction as landfill cover. It is understood that the

use of digestate in the restoration of landfill has not been finalized.

Whilst anaerobic digestion reduces some of the carbon loading, it cannot be seen as a final disposal

option as it has only limited overall effect on the weight or volume requiring ultimate disposal; of the

39,000 tonnes per annum of manures to be treated at the Malta North plant, it is estimated that there

will be 27,300m3 of waste water (centrate) and 6,600 tonnes per annum of dewatered digestate. The

centrate and digestate require further treatment to minimize environmental impact at the point of

19 Frandsen, T. Q. Rodhe, L., Baky, A., Edström, M., Sipilä, I., K., Petersen, S.L., Tybirk, K., 2011. Best Available Technologies for pig Manure Biogas Plants in the Baltic Sea Region. Published by Baltic Sea 2020, Stockholm

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final disposal. The decision to pre-treat by anaerobic digestion therefore is dependent on energy policy

and economics, rather than considering it as a final disposal route in its own right.

For anaerobic digestion, the process must be moved in the reaction vessel to maintain optimum

reaction conditions, which requires the materials to be in a liquid or semi liquid state, the preferred

liquid to solids ratio depending on the process design (even “dry” digestion processes have a higher

ratio of liquids to solids). A consideration is whether to add water to solid manures to increase the

moisture content or to “blend” liquid manures with dry manure to achieve the required moisture

level. Low solids slurries are likely to achieve a low rate of production of biogas in comparison with

the plant size, hence capital cost.

Given that the performance of anaerobic digesters is related to process variables such as nutrient

ratios, there is also a case for considering feedstocks from a number of waste sources including from

different industrial sectors, rather than considering animal manures in isolation (for example,

researchers have enhanced methane production rates by combining pig slurry with crop residues such

as straw, abattoir wastes, food industry wastes or organic fractions of household waste to improve

the carbon:nitrogen ratio). Greater control; hence process optimization, may also be achieved by

some pre-treatment, such as separating the solid and liquid fractions of slurries, to increase the

carbon:nitrogen ratio of the solid portion or to provide a high nitrogen feedstock to balance with low

nitrogen wastes from other waste sources.

Pre-treatment may also be beneficial as a pre-cursor to treatment options for specific components of

the agricultural waste stream, for example taking the higher nitrogen liquid fraction for denitrification

prior to discharge to sewer or sea or concentrating solids for biological or thermal treatment. The

Water Services Corporation (WSC) Strategic Plan 2012/16 includes under wastewater Treatment an

action step (2) to

“Develop sites that can handle receipt of farm liquid waste to have it partially treated prior to discharge

into our network”.

6.3 Technology options

For the purpose of the technology review, simple on-farm treatment, such as aerobic degradation by

composting (farmyard manure heaps) are not considered, as it is assumed that these options have

not, nor can provide the degree of management required to limit nutrient control to satisfy the

fertilizer plans.

A summary is given below of some of the main options likely to be applicable in the Maltese setting.

It should be stressed that this only represents a summary and that not all advantages and

disadvantages may be presented and these would require detailed consideration at the design stage.

It should also be noted that further enhancement techniques might be available for some treatment

options that may, again, be highlighted on further discussions with manufacturers and suppliers. Lack

of inclusion here, does not imply they might not form part of a strategy at a later date subject to a

financial case being put forward (an example being ammonium stripping to extract a high nitrogen

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fertilizer, which has not been considered at this stage, as that will impact on nitrogen only and not

other nutrients).

6.3.1 Physical treatment: Mechanical Separation

This can be applied to untreated slurry as a pre-treatment or to the residues from anaerobic digestion.

It must be recognized that these techniques provide mechanical separation and will not reduce the

pollutant or nutrient loading (other than possible fugitive losses, for instance of nitrogen through

ammonia emissions). Therefore both the solid fraction (cake or thickened sludge) and the liquid

fraction will require further treatment.

In its simplest form a degree of mechanical separation can be achieved by settlement using a simple

thickener in the form of cylindrical chamber with a conical base, from where solids can be removed.

A limitation on this is that the process is slow in comparison with mechanical separation and produces

a thickened sludge rather than a solid, together with a liquid fraction with relatively little quality

control. Greater separation of solids can be achieved by electrolyte application.

More complex mechanical separation techniques suited to larger scale applications include:

Manure separators

Screw and auger separator

Sieve belt presses

Centrifuge and decanters

Filter presses

Most of these techniques are common to the wastewater treatment industry and are well proven, but

the efficiency and costs are dependent on the standard of liquor or cake required (particularly with

respect to solids content) and the physical composition of the manures or slurries at the input. As

mentioned previously, some degree of nitrogen and phosphate separation may be achieved by

mechanical separation. Enhanced separation can be achieved by the addition of metal salts such as

ferric chloride or polymer clarifiers to reduce the solids content in the liquor.

Physical separation of solid and liquid fractions could play a significant part in management of manure

and, in particular, pig slurries if the option for export of stabilized solids or thermal treatment of solids

are favored, provided that an outlet for the liquid fraction can be established. Transport of the

dewatered solid fraction, either for treatment or export, could be significantly reduced in comparison

with the un-separated slurry. The dry matter content of pig slurries is typically between 2% and 6%

(DEFRA 2010), although the degree of separation will depend on the mechanical technique employed

and the residual moisture content of the solid fraction (mechanically pressed digested cake from

sewage treatment, for example, has a dry matter content of around 20-25%, similar to a “dry” matured

farmyard cattle manure). Furthermore, complications of pumping or gravity discharge of the liquid

fraction would be significantly reduced (provided a suitable treatment/disposal option can be found

for the liquid). As the nutrient content would be likely to be lower than the untreated slurry or

digestate, the application of the solid to land may be more easily accommodated, although storage

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would be required outside the growing season when land application is not permitted due to the

potential for nutrient leaching.

Further moisture loss in the solids fraction can be achieved by thermal drying, to achieve far higher

solid content, reducing the weight for subsequent transport (a typical figure of 95% dry matter is

quoted by DEFRA for thermally dried biosolids). The volume can also be further reduced by pelletizing

for use as a fertilizer or for use as a fuel in energy recovery (see below). Drying can be achieved by the

application of heat, normally in the form of waste heat from combined heat and power plants, but

solar energy can be used. Clearly, the use of solar energy (for instance in ventilated greenhouses)

requires less external heat, but a combination of solar and added heat can speed up the process and

minimize the moisture content. Where thermal drying using external sources is used, this will typically

produce a condensate high in ammonia, which will require disposal. Where solar drying is involved,

the odour issue of ammonia can be a significant consideration particularly in a country the size of

Malta with a high population density.

Due to the capital costs of industrial scale dewatering and drying systems, it is likely that regional

centers for the farming industry would be favorable balancing the need to minimize transport distance

against the capital cost. Location of such units would clearly be influenced by proximity to the source

of the pig production units and disposal options for the liquid fraction (for example if disposal to sewer

is an option, then proximity to a sewer is preferable).

6.3.2 Aerobic treatment

Composting is a form of aerobic digestion of solid manures, which traditionally has been carried out

on farms. However, farmyard composting tends to be poorly controlled in terms of aeration, leading

to anaerobic conditions and the release of ammonia and hydrogen sulphide leading to odour nuisance.

As previously noted, however, it is assumed for the purpose of this study that on-farm composting is

not currently carried out and is not considered further here.

However, there may well be benefits for larger scale composting facilities either for previously

untreated farmyard manure or digestate from anaerobic digestion in association with other waste

streams. Composting is typically carried out in turned “windrows” or aerated static piles, although

static piles are more prone to the development of anaerobic conditions, which can lead to emissions

of ammonia; hence odour, although there are mechanisms that can be employed to reduce that.

Composting can be carried out in enclosed conditions (in-vessel composting) reducing the potential

for amenity impacts. To improve the structure of the material; hence improve the maintenance of

aerobic conditions, courser materials are added, in much the same way as is straw in farmyard manure

clamps. This may have the additional benefit of improving the carbon:nitrogen ratio. Other waste

materials have been used rather than straw, such as wood chip, bark and greenwaste (garden waste).

Other sources, could be investigated and “co-mingling” of waste streams to balance the

carbon:nitrogen ration has benefits in achieving good compost quality and structure and as part of an

integrated waste management system. The benefit of composting of solids is that it produces a stable

residue, with some loss of nitrogen and carbon and reduction in ammonia emission on handling, but

just as with farmyard manure, it requires an outlet for the use of the compost. From the discussion of

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the nitrogen requirements above, direct application to land for fertilizer may be a limiting factor.

However, composted biosolids also have a higher dry matter content; hence lower water content than

farmyard manures, which is a benefit when considering transport and may be a material consideration

in extending the land application season. Residual nitrogen is likely to be largely in organic form and

consideration of the rate of release, in particular carry-over to following growing seasons would

require consideration.

Composts can provide a useful soil conditioner and, when mixed with other materials can be used to

provide a soil forming material suitable in applications outside of agriculture, such as in landfill or

mineral works restoration or landscaping applications.

6.3.3 Aerobic treatment of slurries

This is used in some countries for the reduction of odours, particularly for pig slurries, and can be used

to reduce the nitrogen content. The efficiency is dependent on the retention time, technique

(continuous or sequential batch) and aeration rate. Problems can be encountered with ammonia

release, leading to odour problems, nitrous oxide emissions (a greenhouse gas) and foaming. Whilst

it may be of some benefit, it is considered unlikely to provide a significant solution in the Maltese

context.

6.3.3.1 Anaerobic Digestion

Anaerobic digestion (AD) is biochemical process involving hydrolysis, acidogenesis, acetogenesis and

methanogenesis, which although separate, can occur simultaneously within a digester vessel. The

feedstock (substrate) must be kept mixed to prevent stratification, which would lead to potential

inhibition of the different processes. Digesters can be designed to operate either within the mesophilic

range (32-450C) or within the thermophilic range (50-600 C).

Thermophilic processes produces gas more quickly, requiring a shorter retention time, but with higher

energy demand for the plant than mesophilic systems. It is more commonly used for “dry” (<80%

moisture content).

Mesophilic systems are commonly used for “wet” digesters (>80% moisture), and are more suitable

for feedstocks that can be converted to liquid e.g. foodstuffs or manures (pig slurry is likely to be well

in excess of 90% moisture, even if “thickened”). A pasteurization unit is used to heat the material

before or after digestion to achieve sanitization.

The size and design of anaerobic digesters is dependent on the input materials. Crudely, the higher

the organic solids content, the greater the reactor efficiency (ie the biogas production compared to

reactor volume). For low organic solids inputs, such as pig manure, the digester size; hence capital

cost, will increase, and the efficiency decrease, making the operating costs greater in comparison with

the benefits accrued from biogas production. If the efficiency of the reactor is sufficiently high, the

energy output can exceed the requirements, making the plant profitable.

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The output from the reactor comprises a mixture of solids and liquid. The solid rich fraction (sludge)

contains stabilized organic solids (which are less odorous; hence cause less nuisance when spread),

organic nitrogen, insoluble phosphorous and micronutrients.

The liquid fraction will contain soluble nitrogen in the form of ammonium and soluble phosphorous

and potassium, together with dissolved organic compounds.

6.3.3.2 Aerobic treatment (biological oxidation)

As mentioned previously, whilst anaerobic digestion will reduce the organic carbon loading of

materials (through generation of methane and carbon dioxide), there will remain a significant

pollutant load, particularly in the form of ammonium nitrogen and dissolved organic compounds

measured as COD and BOD. Both of these contaminants are barriers to the discharge of effluent either

to the municipal sewage system or to controlled waters. Treatment of these can be achieved by

aerobic biodegradation.

This process utilises two types of bacteria:

Nitrifying bacteria for conversion of ammonium nitrogen via nitrite into nitrate. These

bacteria are autotrophic i.e. they use inorganic carbon as their food source.

Heterotrophic bacteria for conversion of dissolved organic compounds to carbon dioxide and

water.

Whereas heterotrophic bacteria are relatively robust over wide ranges of temperature,

concentrations, pH levels etc., nitrifying bacteria require close control over their environment to

ensure they thrive and operate efficiently. An aerobic bioreactor must therefore be designed to

provide this environment that controls:

dissolved oxygen

mixing

food and nutrient sources including inorganic carbon, ammonium nitrogen, potassium,

phosphorus and essential trace elements

pH at values between 7 and 9

temperature between 15 and 25°C

uniformity

The dissolved oxygen is provided by the aeration system, which also provides adequate mixing.

Nutrient is normally present in sufficient amounts in the concentrate, but is dependent on the

feedstock to the anaerobic digester. Where there are nutrient deficiencies, these require

rectification, such as the addition of phosphorous by phosphoric acid dosing.

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The nitrification process generates acidity and it is often necessary to dose caustic soda solution in

order to maintain the correct pH level. The temperature will be maintained by heat generated by the

exothermic reactions although for seeding and any subsequent re-start operations an electric heater

is fitted. Uniformity is provided by blending the centrate in a balancing tank prior to treatment and

close control of input rates. The process typically creates foaming and this is controlled by dosing with

antifoam solution.

The anoxic denitrification process utilises the same heterotrophic bacteria which continue to oxidise

organic compounds with the formation of carbon dioxide and water but, instead of using dissolved

oxygen, they use combined oxygen from nitrate as their source of oxygen. During this process the

nitrate nitrogen is converted into nitrogen gas and alkalinity is formed with the advantages of

reducing total nitrogen, reducing the amount of aeration needed and reducing the requirement for

caustic soda dosing. This process is carried out in a separate bioreactor which receives untreated

centrate from the anaerobic digester and blends it with mixed liquor from the aerobic bioreactor

containing nitrate. The dissolved oxygen level in this tank is maintained at zero and adequate mixing

is provided.

Several different types of plant are suitable for treating AD centrate including:

Sequencing Batch Reactor (SBR)

Membrane Bioreactor (MBR)

Moving Bed Bioreactor (MBBR)

Each of these has advantages and disadvantages, which would need to be explored in detail based on

the quality and quantity of effluent to be treated. Unsurprisingly, manufacturers of the different types

press the advantages of their system, with conflicting claims of the comparative capital and running

costs.

Typically an MBR uses the smallest size of bioreactor and, because of the high ammonia design

loading; the savings on capital costs of the bioreactor tanks can outweigh the extra cost of the

membrane filter system in comparison with non-membrane bioreactors. An MBR typically also has

advantages in footprint and quality of effluent (particularly for COD and suspended solids) in

comparison with other bioreactors, although manufactures may offer different opinions on this,

particularly with evolving technology.

The membrane filtration unit typically incorporates multi-tubular membrane modules through which

the activated sludge from the bioreactor is pumped at a constant flow rate. Mixed liquor is pumped

through the UF filtration modules to provide a clear permeate and sludge. The majority of the sludge

is pumped back to the bioreactor and the permeate discharged to holding tank or direct to sewer or

other disposal outlet such as surface water or sea, depending on the quality standards to be achieved.

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6.4 Thermal treatment of solids

There are a number of techniques available that have been used in the sewage industry for the

treatment of sewage sludge that can, and are being used or considered more widely for the solids

content of digestate from anaerobic digestion, particularly where land-based applications are not

practical (as is the case in Malta).

Incineration has been the most widely used technique to date, particularly for biowastes such as

sewage sludge. Waste to energy, where energy recovery is incorporated, is preferable, but a barrier

to that is the relatively low calorific value of digestates and the high moisture content. If the calorific

value or the solids content is too low (with a dry solids content typically less than approximately 40%),

additional heat is likely to be required to maintain combustion. Where the calorific value is sufficiently

high and moisture content low (and the incinerator efficiency is high), the process can become auto-

thermal. Incineration with other, higher calorific wastes may be more viable to achieve auto-

combustion.

The process produces ash, which may be disposed to landfill or possibly used in construction materials,

depending on the feedstock. Air pollution control residues are also produced that require disposal.

Pyrolysis is the thermal degradation in the absence of oxygen, similar to the production of coke or

charcoal, and produces a “syngas” comprising hydrogen, methane and carbon monoxide, and “char”.

Pyrolysis requires a relatively low moisture content (dry solids content of 65% or above), a calorific

value in excess of 10MJ/kg and pelletized, pourable or free flowing form, requiring a high level of pre-

preparation. At least one manufacturer (PYREG of Germany) offers the technology on a commercial

scale for the treatment of sewage sludge or biomass (so could well be applicable to digestate from

anaerobic digestion) and claims advantages including self-sufficiency in energy generation requiring

limited quantities of third party gas for start-up. The equipment is provided in modular systems with

limited footprint, so can be scaled up. The solid residue may have uses such as a soil additive for

compost, soil conditioner or fertilizer (char from sewage sludge is high in phosphate).

Gasification is thermal degradation in limited oxygen, like pyrolysis producing a syngas, but comprising

mainly carbon monoxide and hydrogen. Also, like pyrolysis, it requires the fuel to be of low moisture

content and pourable or pelletized. It is reported (WRAP 2012) that pilot studies on digestate from pig

manure have shown that energy recovery can be achieved but that the additional gain over AD alone

is low.

Aqueous wastes containing organic material can be treated by wet air oxidation, that is oxidation by

molecular oxygen in the liquid phase, at high temperature (200–325°C) and pressure (up to 175 bar).

This method is suited to the treatment of domestic sewage sludge, so may well be used for animal

slurries. It is an enclosed process, with a limited environmental emissions in comparison with

incineration, although off-gasses such as ammonium will require treatment before discharge to

atmosphere. There are a low number of industrial reactors are in Europe, but they are apparently for

large scale waste water treatment works treating a high possibly as a result of the high capital

investment requirement, making them more suitable for large scale operations. There is a solid

residue requiring disposal and a liquid effluent that will require further treatment before discharge.

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6.5 Application in the Maltese Islands Context

In the short-term, export of excess manures may be necessary, but that is likely to have high

operational costs as explained in the next section of the report. In addition, and in particular, it can be

considered unsustainable from an environmental perspective and counter to the proximity principle

for waste management. The following sections therefore focus more closely on the medium to longer-

term options.

In considering the application of technical options, a number of prominent factors must be considered.

As outlined above, the principle challenge for the agricultural waste sector is the excess nitrogen with

respect to the application to land and the Nitrates Directive (although other nutrients such as

potassium and phosphorous will also be significant). From a physical management perspective, the

low dry solids content of agricultural wastes is a significant factor. Other significant factors regarding

the management of agricultural wastes include amenity factors such as the release of ammonium and

hydrogen sulphide.

From previous studies and reports, there is significant uncertainty regarding both the quantity,

physical characteristics including the dry solids content of agricultural waste (particularly pig slurries)

and the chemical composition of wastes; hence their treatability. At this stage, therefore it is possible

to make general technology recommendations, which will require further investigations to ascertain

their feasibility.

For the purpose of this review, it is assumed that the quantities of agricultural wastes for treatment

are in the order of:

- Up to 150,000m3/a of pig slurry, with volume and nitrogen concentration strongly dependent

on water content

- Up to 60,000m3/a of cattle manure (again, with the volume dependent on water content)

- Up to 5,000t/a of other animal manure.

As previously mentioned, the strength of the pig slurry is unknown, but may be dilute, i.e. of low dry

solid matter, due to farm practices. Whilst this will not affect the total load of solids or nitrogen to be

treated, it will affect the quantity of slurry to be transported. Assuming slurry has to be transported

to central or regional facilities (or a port in the case of export) a reduction of 5% in water used on farm

in pig slurry generation would result in a reduction of vehicle trips of approximately 270, assuming

large, 28m3 tankers; if smaller tanker trucks were used, the figure would be correspondingly higher.

In addition, the solids content of the slurry would be increased, making subsequent treatment or

separation easier.

The potential for on-farm thickening or separation of slurries might also be considered, particularly

for larger units, reducing further the volume of slurry for transport to collection or disposal points.

However, unless there is an outlet (such as sewer discharge) for the liquor, there is little benefit in this

from the vehicle movement perspective, as the water will still be heavily contaminated with some

solids and significant nitrate loading which would require treatment, and, presumably transport off

site. There might, however, be benefit in the reduced quantity of thickened sludge for treatment if a

separate route, such as sewer disposal of the liquid fraction can be secured. Discussions with the WSC

are recommended to ascertain whether there is any further scope in this regard. A likely barrier to

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this would be the need for regulation and quality control of the liquor for discharge to avoid repetition

of the problems encountered at treatment plants in the recent past.

If there is any potential for the discharge to sewer of liquor arising from thickening or clarification of

sludge, greater control could be achieved at local/regional physical collection/separation points using

mechanical means. Such units could be located, for instance, on larger pig units providing local

collection points. The principal advantages would be the minimisation of travel distance for farmers

to transport their raw slurry, possibly similar to that they enjoyed when previously discharging to

sewer discharge points, increased solids content of the slurry, making treatment by anaerobic

digestion more favourable, and reduced volume of the organic fraction, reducing transport

requirements to treatment plants. This approach could also be adopted as a means of reducing the

volume for export in the short-term; even greater reduction could be achieved by the use of

mechanical separators or presses, although the capital and operating cost would increase. There might

also be opportunity for the application of some of the nitrogen rich liquor as fertilizer to land, with

greater control of the rate of application of specific nutrients at the peak growing times, as the

nitrogen in the liquor is likely to be predominantly in the available form, maximising both crop yield

and minimising mineral fertilizer application. It is considered likely that this strategy might be

particularly applicable in Gozo, where the volume of pig units is low in comparison with Malta. It may

prove cost effective to transport thickened sludge to treatment facilities elsewhere, although the co-

treatment of cattle manure and pig slurry, together with other wastes on Gozo could render a

treatment facility there viable.

In the event that there is no prospect of discharge of liquor from the thickening of sludge, it might be

that local or regional collection points might still be favourable, rather than collection from individual

farm units. Such facilities would be likely to consist of simple tanks for untreated slurries. There is also

the possibility to add higher solids content manures, provided the material remains pumpable,

although this might add to capital and operational costs if additional agitation was necessary to keep

the material pumpable. The slurry would then be collected by tanker to treatment at a regional

treatment centre. The advantage of this localised collection over collection from individual farms

would be the reduction in time for collection rounds and fewer lorry movements in comparison with

individual farm collections. Assuming the addition of no other manures, the daily storage requirement

for 150,000m3 of pig slurry amounts to approximately 410m3 per day. Even assuming that several days

retention time were required, spread between a number of local collection facilities, with the size

dependent on the catchment and stock number of farms, the size of the facilities would be relatively

small. Indeed, smaller facilities could be established on a temporary basis with limited civil works by

using, for example, tanks fitted to roll-on-off skids that could be simply picked up full, and replaced by

an empty tank barrel.

The issue of the nitrogen and solids (carbon rich) fraction can be considered separately or collectively

with the whole product. In the simplest format, slurries, together with higher solids manures if

required, could simply dewatered to form a “cake” for disposal, with the liquid taken for treatment by

denitrifcation. This has a number of disadvantages in that the dewatering is likely to be energy

intensive and the solids will still be likely to have a high moisture content (depending on the technique

employed). Either additional drying would be required to achieve a dry solids content capable of auto-

thermal incineration or suitable for alternative thermal treatment by pyrolysis or gasification, so

additional energy sources would be required for disposal by that route, hence it is likely there would

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be a significant operational cost as well as capital cost in that option. The cake would not be stabilised;

hence would be likely to be odorous to store or handle, for instance for treatment by aerobic biological

treatment (composting). Additional drying would be sure to lead to ammonium generation requiring

significant abatement. For the liquid fraction, there would still be a requirement for treatment to

achieve de-nitrification.

The treatment by anaerobic digestion of the slurry and manures offers potential advantages, in that,

provided the carbon (solids) content can be raised and the carbon:nitrogen ratio optimised, the

process can produce excess energy over the operating requirements, and the resulting solids are

stabilised. As explained earlier, anaerobic digestion of pig-slurry alone may not be advantageous due

to the low solids content hence rate of methane production in relation to the volume of the digester

vessel. Further analysis of the pig slurry is required together with the identification of potential higher

organic content waste streams, in the same way as some waste streams from the mechanical

treatment facility are intended for mixing with the cattle and poultry litter at the Malta North facility.

Slurry thickening or partial dewatering as pre-treatment of pig slurry may be an option, although that

will affect the operating costs. The liquor (centrate) will require treatment for de-nitrification, just as

the untreated liquor would if the raw manures were simply dewatered.

It would, therefore, seem logical that anaerobic digestion be considered further as part of the

agricultural waste strategy. This is consistent with the policies being adopted throughout Europe.

Germany and northern European countries have many anaerobic digestion plants operational over

many years and other countries such as the UK are adopting them as part of waste management

strategies. Examples of on-farm anaerobic digestion plants are common in Europe and the US and

further proposals are commonly coming forward for manure management, although it must be

recognised that in most cases, additional carbon sources are used in co-treatment. It is recommended

that anaerobic digestion be investigated as part of an integrated waste management strategy.

However, careful consideration given to other waste sources that might be used. In particular,

consideration must be given to the potential after use of the solid digestate and quality protocols for

saleable products.

As outlined above, solid digestate can be applied as a fertilizer of soil conditioner, but whether that is

feasible will depend on the requirement, which it has been shown earlier in this report, is likely to

change. Two broad treatment methods were discussed earlier, aerobic treatment, or composting, to

provide a saleable soil forming materials suitable for use in horticulture, or thermal treatment.

Composting will require a significant land footprint if windrow composting is adopted, a lower

footprint with static pile. It is likely that additional materials will be required to achieve the necessary

carbon:nitrogen ratio and provide an open structure to maintain aerobic conditions. Careful

consideration will be required in the location of composting plants as they can lead to odour nuisance

if not properly controlled, but logically, they would be located close to the source of the source

materials (ie the anaerobic digestion plants). Greater control over odours can be achieved over both

aerobic conditions and odours by in-vessel composting, but that will lead to a higher capital cost. The

choice of additional materials would also have to be carefully considered in the quality of the

“product’, as that would affect the suitability. Quality protocols are being adopted in European

countries for stabilised compost.

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Of the thermal treatment options available, incineration offers some attraction, in that it may require

the least drying of the digestate residue, provided that there is sufficient support fuel in the form of

higher calorific waste available. If not, either support fuel will be necessary, or additional drying of the

digestate residue necessary, again with further cost. It has been identified that additional incineration

capacity would be required, incurring additional capital cost. Incineration also suffers from poor public

perception, although usually unfounded given the emissions standards required under European

legislation. It is noted that a policy for thermal treatment of household wastes and sewage sludge is

currently under consideration and it is recommended that potential synergies with that be explored.

Whilst the volume of agricultural wastes is significant, it should be recognised that the dry matter

content is low. Assuming a dry matter content of 4% for pig slurry and 15% for cattle manure, the total

solids content for the quantities outlined above is only 6000te/a for pig slurry and 16,200te/a for cattle

manure, assuming no loss during pre-treatment, for example by anaerobic digestion, although the

additional solids content of any co-digested wastes would have to be taken into consideration.

Of the alternative thermal processes, it appears gasification is less well tested in this application, whilst

pyrolysis has been developed at both pilot and commercial scale for sewage sludge and similar wastes.

From the research carried out to date, it appears that modular pyrolysis plants are available, affording

flexibility in approach, and again given the relatively low quantities of solid matter arising from the

agricultural wastes, it is recommended that this option be taken to the next stage of investigation. It

must be recognised, however, that for pyrolysis, the digestate residue must have a low moisture

content, so sludge drying would be necessary, increasing the capital costs.

For the liquid fraction of the digestate, or centrate, biological oxidation and anoxic denitrification

seem the obvious choice; the method is well understood in the waste water treatment industry, as

well as in the anaerobic digestion industry for centrate treatment. It is recommended that discussions

be held with WSC to ascertain whether synergies and cost savings can be accomplished by either

contributing to extending or upgrading existing treatment facilities.

The application of other technologies which are used in other Member States may be considered more

innovative for the application to the domestic sector. Of particular relevance here is the development

of fertiliser plants and the potential to treat pig slurry in a manner which allows for eventual discharge

into the sewer system. Both of these options have not been implemented in Malta and require further

in depth studies to determine their technical viability.

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7. Determination of the Financial Costs of the Technological Alternatives for the Handling and Treatment of Agricultural Waste

This section of the report seeks to present a high level estimate of the financial costs of the options

presented in the previous section while taking into account the viability of the options from a short-

term, medium-term and long-term perspective. Further to the previous section, this section also

distinguishes between the generation, treatment and disposal of manure/slurry.

On account of the distinct composition and uncertainty associated with the composition of pig slurry,

the options analysis presented in this section shall also distinguish between the options available for

treatment and disposal for cattle and other livestock manure and pig slurry.

As stressed in previous sections of this report, there are a number of uncertainties associated with the

generation and treatment of manure/slurry and as a result one of the key facets of this report has

been to develop options which allow for flexibility. This is mainly due to the fact that forecasts of the

livestock units cannot be undertaken with a credible degree of precision. Taking into account the

downward trend of the recent few years would imply that livestock units are to continue to decrease

sharply. However the adoption of policy which considers the security of supply implies that

intervention would be required to avoid such a drastic decline in livestock units. This level of

uncertainty in the livestock units also translates into uncertainty in the generation of manure/slurry

and hence requires an element of flexibility in the derivation of options in a bid to cater for any of the

scenarios which might materialise in the future.

Further elements of uncertainty which underpin the need for flexibility is the management of manure

and slurry. This, in particular, holds for the generation of slurry where the use of water to dilute pig

slurry ranges significantly between farms. Furthermore, due to this uncertainty, the composition of

pig slurry continues to vary significantly limiting the potential treatment options.

Other elements of uncertainty include the soil nitrogen supply to determine the soil intake capacity.

Towards this end, a detailed study is required on nitrogen inputs which in turn will determine the

amount of manure/slurry to be treated and thereafter disposed. It is to be noted in this regard, that

the data is indirectly being collected through the fertiliser plans drawn up by the FASC on behalf of

the farmers but it remains unprocessed and hence has not been adequately analysed, as yet.

The final element of uncertainty which underpins this agricultural waste management plan is the

availability of options within the local context. It is to be noted in this regard that the Maltese Islands

are small in size and are characterised by a significantly high population density. As a result, the

application of treatment options at a centralised level which are adjacent to dwellings remains to be

studied. Furthermore options which may have been adopted in other countries need to be studied in

detail in order to determine their applicability within the local context.

The development of options within the local context will thus distinguish between:

- Pig Slurry

- Manure generated by cattle, poultry and ovine

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Furthermore options are also derived at the levels of:

- Waste generation

- Waste treatment

- Waste disposal

7.1 Waste Generation

A key element in addressing agricultural waste management is the management of livestock heads. It

is evident from the economic assessment of the agricultural sector, that a number of farms,

particularly the smaller ones, are not financially sustainable. Despite the availability of financial

assistance offered through funding sources such as the Common Agricultural Policy and the Rural

Development Policy, the enhanced and rigorous competition offered by larger scale farms which

benefit from economies of scale continues to dent the financial sustainability of these farms.

It is thus not surprising that the continuous reduction in livestock units is expected to be maintained

in the future. The uncertainty lies with the extent of this reduction. An option to address the reduction

in the livestock units in a sustainable manner and hence a reduction in the generation of

manure/slurry is through the encouragement of diversification of farming into rural activity. This

requires allowance for development permits in line with the Rural Policy Guidance issued by the Malta

Environment and Planning Authority (MEPA) in 2014.

The ODZ policy (2014) states that there is scope for diversification of farms by small scale enterprises

such as small scale farm retail, farm-based visitor attractions and agro-tourism accommodation. The

policy also indicates that whilst established rural activities may not be well sited by today's standards,

their reasonable expansion on site needs to be considered. The conversions and changes of use are

ways of making efficient use of buildings constructed to meet economic and social needs which have

since changed. They provide a way of allowing necessary or desirable changes without too great an

impact on the open countryside.

There is thus already the basis through the ODZ policy to diversify the use of farms. This needs to be

extended to focus on the potential creation of dwellings within reasonable and approvable boundaries

that would generate employment and value added. It would allow for diversification of farm land use

towards sustainable rural real state of high value added. It may also be opportune to provide guidance

to farmers on the potential of diversification in this regard and to facilitate the process.

For farms which express a lack of desire towards diversification, the potential use of ‘buy outs of

production rights’ might be considered. This option has been used in countries such as Netherlands

which face an environmental challenge associated with manure/slurry whereby government opted

for a buy-out scheme in 2000 and 200120 which reduced the manure surplus significantly. In fact, over

5000 farms applied, with pig stocks declining from 13 million in 1999 to 11.5 million in 2002 (CBS

StatLine21). Similarly in the Netherlands, a social economic plan for animal husbandry was adopted to

focus on advising livestock farmers about future developments and about termination of farming.

20 ‘MINAS: A post mortem?’ , Rosklide University, Mallia and Right (2004) 21 http://statline.cbs.nl/StatWeb/Start.asp?lp=Search/Search&LA=EN&DM=SLEN

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Another key element in addressing waste generation is through enhanced emphasis on sustainable

and efficient farming practices to minimise number of heads and waste. This is to be further backed

by greater emphasis on enforcement to ensure that farming practices which are not in line with legal

requirements continue to be reprimanded in an effective manner ensuring that only sustainable

farming practices and farms are maintained.

7.2 Waste Treatment

This section provides a high level estimate of waste treatment taking into account the capacity

availability at the Malta North Biological Treatment Plant (MBT) as well as the costs associated with

other digestion plants and incineration. Detailed studies are required, to determine with more

precision, these financial costs which ultimately depend on the actual design parameters of the

technical options.

Malta North Mechanical and Biological Treatment Plant (Co-mingling)

The overall objective of the MBT is the treatment and disposal of municipal waste in Malta to

respect the limits established on the landfilling of biowaste whilst also contributing, albeit to a lesser

extent, to recycling targets and packaging waste targets.

It is to be noted that the plant is not aimed directly at resolving manure waste issues in Malta, and in

particular the compliance with the Nitrates Directive, but the co-mingling of manure presents an

opportunity to improve the overall performance of the waste management system. The treatment of

manure is undertaken to exploit opportunities provided by the establishment of the plant at

enhancing the efficiency of the overall waste management system in Malta.

The scope of co-mingling lies with the fact that there exists an economic opportunity to generate

overall improvements in the waste management system in Malta by co-mingling manure with

municipal waste which could potentially:

- improve the desirable qualities of the output from the municipal waste system;

- reduce the overall costs of treating manure waste in Malta, as compared to other

interventions aimed at achieving the Nitrates and related Directives which are expected

to be undertaken within the country.

The overall economic benefits of co-mingling municipal waste and manure are the significantly higher

yield of biogas which is generated with the use of cattle manure and other dry manure, the shared

use of processing plant and equipment as well as the enhanced stabilization of the AD process.

The inclusion of manure bears no burden on the financial aspect of the project from the operator’s

point of view or from a funding perspective due to the expected imposition of a full cost recovery rate

for the treatment of manure. Towards this end, the additional costs incurred to allow for the co-

mingling of waste is minimal compared to the total cost of the project with the additional investment

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amounting to €2.2 million, construction and machinery of €1.5 million and civil works and other costs

of €0.8 million. The annual operational costs amount to €120,000.

The co-mingling aspect also generates a net disposal revenue on an annual basis. whereby the net

effect of revenue and costs coupled with the investment cost results in prime dynamic cost for the

treatment of manure of about €6/tonne.

Digestion Plant

An estimate of the cost of a digestion plant which caters solely for manure is also presented based on

technical parameters for a plant which was initially envisaged to cater for the treatment of 42,800m3

of cattle manure in Malta22. The technical parameters which are shown in the Table below indicate

that in the process of treating manure, the plant would generate output in the form of losses in terms

of water and nitrates occurring during the drying of the manure and liquid fertiliser which is to be

disposed of in sewer. The plant will also generate revenue through the generation of biogas as well as

through the generation of solid high quality fertiliser. One of the key aspects of the financial

sustainability of the plant is the application of the feed-in-tariff which for the purpose of the

assessment undertaken to determine the cost benefit analysis of the plant in line with EU funding

regulation, was estimated at €0.11/kWh based on the marginal cost of electricity. It is also to be noted

that the price of land has not been taken into consideration.

Table 7.1 Technical Parameters of an Anaerobic Digestion Plant

The investment cost of the plant, typical of this size, is estimated at €6.8 million of which €2.2 million

is machinery and equipment as well as annual operational costs of €0.5 million. Part of this operational

cost is the transport required to transport the manure of neighbouring farms to the plant and the

transport of liquid fertiliser to sewer. Based on these high level estimates, the prime dynamic cost of

22 Residents in Siggiewi have raised objections to the siting of the plant and the ensued activity that may occur on account of the location of the Plant. As a result the development of the plant remains uncertain.

Manure (m3) 42,800

LandfillLosses to air: Water 100 Losses to air: N 100 Biogas to electricity 1,500 Solid High quality fertiliser 8,500

Liquid Fertiliser to sewer 32,600

Input

Electricity (kwh) 1,070,584

Diesel (Litres) 15,000

Output

Electricity from manure (kWh) 2,400,000

Input

Energy Flow/annum

Output

Manure Plant

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the plant based on a lifetime of 20 years and a financial discount rate of 5% is estimated at €20/tonne

of manure.

Incineration

Another treatment option considered in this section of the report is the possibility of incinerating the

manure/slurry. A feasibility study is currently being undertaken to determine the viability of

incineration for the treatment of municipal waste and other related waste streams. It is however to

be noted that following discussion with the contracting authority23, the study is not considering

specifically the inclusion of manure/slurry for incineration.

The costs of incineration presented in this section are based on a high level estimate of the cost of

incineration at the Marsa Thermal Treatment Facility operated by Wasteserv Malta. The incinerator

which is located in Marsa currently treats abattoir waste, clinical waste, refused derived fuel, and

other waste including industrial sludge. The costs of treating this waste amounts to about €430/tonne

of waste. It is to be noted that this cost reflects solely the technical parameters of the incinerator at

the plant and is not necessarily reflective of the costs of an incinerator which would cater for

manure/slurry.

Other technical options which have been presented in the previous section of the report require in-

depth studies of the input and the technical nature of the plants which might be innovative for the

local market and thus require experimentation to determine their feasibility. Of particular relevance

is the potential development of fertiliser plants which develop organo-mineral compounds, with high

iron and organic substance content which are pelletized through a procedure that preserves organic

substances by maintaining bacteria count. Such plants which cater for the generation of fertiliser

through the treatment of cattle manure currently exist in a number of EU countries. A project

promoter from Sicily indicated that it may be technically possible for these plants to also cater for pig

slurry. This however required further in-depth study to determine the viability of such plants.

7.3 Waste Disposal

Export of manure/slurry

The third element which is considered in this study is waste disposal whereby the costs pertaining to

the export of manure/slurry are considered in this section. Manure is classified as ‘Category 2’

according to ABP regulations and Regulation (EC) No 1069/2009. Article 21 indicates that the

competent authority may authorise the transport of manure between two points located on the same

farm or between farms and users of manure within the same Member State (MS) without a

commercial document or health certificate. However trade between Member States must follow the

procedure outlined in Article 48.1 of the EU Control Regulation which indicates that anybody

proposing such trade must notify the competent authorities in both the MS of origin and the MS of

destination. The Competent Authorities in the MS of destination will then decide whether the trade

can be allowed, and if so whether any additional conditions need to be imposed. This is a similar

23 MSDEC

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procedure which is adopted in the Netherlands, which as explained further below, also

exports/imports manure/slurry to other Member States.

The technical and financial viability of the export option depends on a number of variables including

the volume of manure/slurry, the required frequency of trips to collect the manure/slurry from farms

as well as the frequency of vessel trips at the port. These issues determine the optimal size of trucks

and storage units required to transport the manure/slurry.

Given that in general, cattle and other livestock manure is expected to be catered for in the medium

term mainly on account of the existing MBT plant and the possible development of other similar

plants, this option focuses more intently on the export of pig slurry particularly in the short term.

A high level estimate of exporting slurry has been undertaken based on two options. Both options

presented hereunder are based on the costs that would occur to transport the level of slurry expected

to be generated in 2016 taking into account the minimum and maximum volume of slurry.

From a logistical perspective, the farms are rather dispersed and can be found in both Malta and Gozo.

The larger farms which hold over 300 heads are mainly based in Malta and can be found in the South

East and North of Malta with a few farms also located on the West side of the Island. The distribution

of pig farms across the Maltese Islands is presented in the Table below.

Table 7.2 Distribution of Pig Farms

Figure 7.1: Geographical Distribution of Pig Farms

Pig Farm Size Malta Gozo Total

0-100 25 3 28

101-300 33 5 38

301-500 13 2 15

501-999 17 1 18

Over 1000 7 0 7

Total 95 11 106

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The total amount of pig slurry produced in 2016 may vary from as much as about 12,300m3 on an

annual basis to 155,600m3. Based on a truck size of 33,000m3 the total number of trips required on an

annual basis to transport the volume of slurry may vary from about 370 trips in the minimum scenario

to over 4,700 trips in the maximum scenario.

The first export option considered in the report, labelled as ‘Option 1’, is based on a setup that would

require the collection of slurry from different locations across Malta and Gozo and the transportation

of the slurry in 33,000 litres trailers. The slurry would be stored at a central location in trailers for 3 to

4 days reflecting the vessel availability to export the slurry. The diagram below shows the logistical

process required for Option 1.

In a scenario which generates the minimum volume of manure in 2016, this option would require four

trucks to collect the manure from the farms and eight trailers located at the central collection depot

to store the manure for eventual exportation. The financial cost of these trucks and trailers amounts

to about €600,000.24 The operational costs of this option consist of wages and transportation costs.

The latter amounts to an annual value of €1.6 million. The wages element is based on five truck

drivers25 earning about €18,000 per annum. The annual cost of fuel is based on 50,000 km travelled

per truck to collect the slurry.26 Shipment costs to Catania are based on the assumption that demand

for slurry uptake is available in Sicily. The shipping costs amount to about €1,000 per trip per truck. In

addition haulage costs are also taken into account based on the assumption of ongoing haulage rates

per km.

In the maximum scenario, this option would require six trucks to collect the manure from the farms

and over 100 trailers located at the central collection depot to store the manure for eventual

exportation. The financial cost of these trucks and trailers amounts to about €2.9 million.27 The

operational costs on this case amount to an annual value of €8.7 million.

The prime dynamic costs of this option taking into account a lifetime of 7 years for the trucks and

financial discount rate of 5% is estimated at €136/tonne in the minimum scenario and drops to

€108/tonne in the maximum scenario with the lower cost reflecting the greater utilisation of the

investment.

In total operational costs may thus vary from €1.6 million on annual basis to € 16.1 million in the

maximum scenario. The reduction in the volume of slurry is critical to minimise the transportation

costs.

24 A 33,000m3 truck is assumed to cost €30,000 and each tractor units cost €90,000 25 Standard logistical assumption based on 1.2 workers required per truck. 26 It Is further assumed that each truck can cover a distance of 2km per litre and the cost of diesel is taken at €1.36/litre. 27 A 33,000m3 truck is assumed to cost €30,000 and each tractor units cost €90,000

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Figure 7.2: Export Option 1

Table 7.3: Financial Costs: Export of Slurry Option 1

Infrastructure Infrastructure

Total number of Trucks 4 Total number of Trucks 26

Total Number of Large Tankers 8 Total Number of Large Tankers 104

Cost (€) 611,042 Cost (€) 5,442,492

HR HR

Total Number of Drivers 5 Total Number of Drivers 31

Cost (€) 72,000 Cost (€) 466,499

Transportation Transportation

Fuel Malta 554,012 Fuel Malta 3,524,661

Ship To Catania 635,484 Ship To Catania 8,085,988

Haulage Sicily 317,742 Haulage Sicily 4,042,994

YEAR 1

Investment Cost 611,042 Investment Cost 5,442,492

Operational Costs 1,579,238 Operational Costs 16,120,143

Prime Dynamic Cost/tonne 136.23 Prime Dynamic Cost/tonne 108.56

MIN generation of pig manure MAX generation of pig manure

Option 1: Large Truck pickup on a weekly basis from each farm and straight to Port

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The second option, labelled ‘Option 2’ is similar to Option 1 yet the workload of collecting the manure

is distributed. Option 2 requires that each farmer delivers the manure in smaller trucks on a regular

basis to one of the depots set up specifically for the system. These costs are considered to be sunk

costs. In each depot there will be numerous tanker trailers for the farmers to transfer the

manure/slurry from their truck into the trailer. Once the trailers are full, they will be transported by a

larger truck and shipped out based on a regular schedule similar to Option 1. This will reduce the cost

of the operation as the costs of the large trucks required to collect the manure is reduced.

Figure 7.3: Export Option 2

The costs associated with this option are shown in Table 7.4 below. In the minimum scenario, eight

tankers would be required to store the slurry and one 33,000 litre truck to transport the slurry for

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exportation. The operational costs of this option amount to €1.1 million in the minimum case scenario

but rises to €13.1 million in the maximum scenario. It is to be noted that in the case of the maximum

scenario the number of large trucks required would need to increase to six to account for the large

volume of slurry.

The prime dynamic cost of this option ranges from €95.40/tonne of slurry to €87.21/tonne of slurry in

the maximum scenario.

Table 7.4: Export ‘Option 2’

The export option is considered as a stop-gap solution, allowing for flexibility albeit at a significant

cost. This cost can be mitigated, in the short run, through the continuation of current practices, until

more cost-effective solutions are developed in the medium term.

It is to be noted that the export option is also utilised by other European Member States which

generate an excess of manure/slurry. In some cases the untreated manure is exported whilst in other

cases it is the nutrients which are exported following treatment. In the Netherlands, excess manure

at farm level is transported to other farms. Pig and poultry farms have large manure surpluses. The

nutrients from the manure/slurry is exported to other countries such as Germany. The cost of

transport ranges from €5 to €20 per tonne as it only considers land transport and does not require

transportation via vessels as would be the case in Malta.

An overview of the procedure undertaken to export pig manure from the Flanders to the Netherlands

is shown in the figure below. In essence, there is the identification of the manure volume which is

based on an agricultural number in the Flanders and a client number in the Netherlands. These are

Infrastructure 0 Infrastructure 0

Total number of Trucks 1 Total number of Trucks 6

Total Number of Large Tankers 8 Total Number of Large Tankers 104

Cost (€) 334,417 Cost (€) 3,649,995

HR HR 0

Total Number of Drivers 2 Total Number of Drivers 7

Cost (€) 30,000 Cost (€) 108,000

Transportation Transportation

Fuel Malta 136,000 Fuel Malta 816,000

Ship To Catania 635,484 Ship To Catania 8,085,988

Haulage Sicily 317,742 Haulage Sicily 4,042,994

-

Investment Cost 334,417 Investment Cost 3,649,995

Operational Costs 1,119,226 Operational Costs 13,052,982

Prime Dynamic Cost/tonne 95.40 Prime Dynamic Cost/tonne 87.21

Assuming 7 year lifespan of investment

Option 2: Farmer Bring Manure to Govt Depot, offload into trailers and then trailers are rolled onto Vessel for

Export

MIN generation of pig manure MAX generation of pig manure

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not recognised across borders but are specific to the region or Member State. Exportation also

requires veterinary authorisation but only one authorisation is required to avoid doubling this

administrative step.

In terms of the transport of the manure there is a sample analysis and authorisation undertaken to

export and import by the respective different authorities.

Figure 7.4 Procedure of exporting manure

Source: Organic Transport Fertiliser across borders – transparency in legislations

Other innovative technologies

Another disposal option which may be considered is the transformation of pig slurry into material

similar to human waste allowing for discharge to sewer. This option is still currently being studied and

hence the feasibility of the option from a technical, financial and economic perspective remains to be

seen. This option, can in the medium term be considered as an innovative approach which caters for

the treatment of waste.

7.4 Technical Options available for generation, treatment and disposal

This section of the report presents a summary of the options available in Malta up to 2030

distinguishing between treatment and disposal of pig slurry as opposed to cattle and other livestock

manure.

Pig slurry

The options, the technical details of which have been explained in previous sections of the report,

distinguish between the viability of options at generation, treatment and disposal. In terms of pig

slurry, a key element of the management of waste rests on generation in the first place. As discussed

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previously, emphasis on sustainable and efficient farming practices to minimise the number of heads

and waste is considered particularly important. The over abundant use of water has to be discontinued

to enable the efficient use of treatment and disposal options. Indeed, whether the waste is treated

and biogas generated from it or whether it is exported requires more efficient use of water in pig

slurry. In the case of the former, the production of biogas and hence the feasibility of the option

depends on the extent to which the slurry is diluted while in the case of the latter, the cost of exporting

depends significantly on the volume of slurry.

At generation level, there is also the option of diversification of farm land use towards sustainable

rural real estate. The number of heads may through a policy decision decline thus addressing the

generation of slurry through the diversification of farm land use which ties in with the sustainability

of rural areas. Livestock farmers could be presented with the option of diversifying the farm land use

themselves or possibly with a pig farm buy out scheme which can be implemented by the governance

structure itself which is explained in the next section of the report. It is to be noted that pig farm buy

out schemes have been implemented in the Netherlands and Belgium to decrease manure surplus

(OECD, 2003). The case in the Netherlands can provide basic indications on the expected costs of such

a scheme; the Government in the first round of buy-out bought a total of about 5,000 farms. The total

cost to the government for the buy- out scheme has been estimated at €900 million.

It is to be noted that diversification from farming towards the creation of small businesses in rural

areas is a support measure which is supported by EAFRD. Diversification is also tangent to other policy

documents such as the National Tourism Policy (2015-2020) which identifies rural tourism as a niche

sector.

Table 7.5 Options for the generation, treatment and disposal of pig slurry

Waste treatment options for pig slurry are not perceived to be available in the short term and the

viability of the options presented in the matrix below from 2020 onwards remains to be studied in

technical detail. In particular the options of producing fertilisers, thermal treatment and disposal to

sewer following the treatment of the slurry remains to be tried and tested within the local context.

The financially feasibility of these options also needs to be studied in greater detail. While technically

speaking the digestion plants can treat pig slurry, the viability of these plants greatly depends on the

composition of the slurry in the first place.

2016/2018 2020 2030

Digestion Malta North Digestion Malta North

Digestion Other Malta Digestion Other Malta

Digestion Gozo Digestion Gozo

Fertiliser Production Fertiliser Production

Waste treatment to sewer Waste treatment to sewer

Thermal Thermal

Export Export Export

Sewer (after treatment) Sewer (after treatment)

Landfill (after treatment) Landfill (after treatment)

Waste Disposal

Waste Treatment

Pig Slurry

Waste GenerationDiversification of farm land use towards sustainable rural real estate

Emphasis on sustainable and efficient farming practices to minimise number of heads and waste

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In the short term, export is considered as a viable option albeit a stop-gap one until other options are

developed in the medium to long term. Furthermore in the analysis, export is taken to absorb the

residual of the waste volume which is not treated.

Cattle and Other Livestock Manure

Similar to the generation of pig slurry, the options at generation level to address the generation of

cattle and other livestock manure are aimed at diversification of farm land use towards sustainable

rural real estate as well as further and enhanced emphasis on sustainable and efficient practices to

minimise the number of heads and volume of manure.

In terms of treatment, the Malta North Biological Treatment Plant is in the short term the only

treatment plant at a centralised level which can cater for part of the cattle and other livestock manure.

In the medium term, treatment of this manure can be further complemented by other digestion plants

or treatment options. It is however to be reiterated that in the case where the minimum scenario of

cattle manure materialises, the scope of having additional centralised plants may be limited.

Finally disposal of manure must also be taken into consideration particularly following the treatment

of manure through digestion plants. In particular, this relates to the application of manure on crop

land, as well as the export option. The disposal of water which is generated through the treatment of

manure and any other output such as digestate will have to be disposed of in other manners following

treatment.

Table 7.6 Options for the generation, treatment and disposal of cattle, and other livestock manure

7.4 Summary of Options

The high level financial estimates presented above are summarised in this section of the report for

three periods namely 2016, 2020 and 2030. Once again a distinction is made between the cattle and

other livestock manure and pig slurry.

2016/2018 2020 2030

Digestion Malta North Digestion Malta North Digestion Malta North

Digestion Other Malta Digestion Other Malta

Digestion Gozo Digestion Gozo

Fertiliser Production Fertiliser Production

Thermal Thermal

Crop Land Crop Land Crop Land

Export Export Export

Sewer (after treatment) Sewer (after treatment) Sewer (after treatment)

Landfill (after treatment) Landfill (after treatment) Landfill (after treatment)

Waste Treatment

Cattle and Other Livestock Manure

Diversification of farm land use towards sustainable rural real estate

Emphasis on sustainable and efficient farming practices to minimise number of heads and wasteWaste Generation

Waste Disposal

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The total financial costs vary according to the volume of manure/slurry generated which in turn

depends on the number of heads and farming practices. A distinction is made between the minimum

and maximum scenarios.

Cattle and Other Livestock Manure

In 2016, the financial cost of treating and disposing cattle and other livestock manure may be as high

as €8.4 million on an annual basis if the maximum volume of manure materialises. In the case of the

minimum scenario, taking into account the revenue would be generated by the system on account of

application of manure to crop, the net costs would be limited to €0.7 million. Likewise, in 2020, should

the minimum scenario materialise, the system would create an overall revenue of €0.6 million per

year but could generate an overall cost of €7.4 million on an annual basis should the maximum

scenario unfold.

Table 7.7 Cattle and Other Livestock Manure: Financial Costs 2016

2016Prime

Dynamic

Cost Cattle and Other Livestock Manure Min Max Min Max

Production (m3 in 000s) 80.5 145.4

Applied to Crop 13.3 28.6 -24 319- 686-

Excess volume (Treatment or Disposal) 51.9 132.1

Treatment and Disposal

MBT (co-mingling of manure) 39.0 39.0 6 234 234

Other solutions 12.9 93.1

Digestion

Incineration

New Technologies

Export 12.9 93.1 91.3 1,180 8,500 Total Cost (€ 000s) 728 8,414

Total Financial Cost

(€ 000s)Manure Generation

0.0

0.0

0.0

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Table 7.8 Cattle and Other Livestock Manure: Financial Costs 2020

On the other hand, as can be observed from Table 7.9 in 2030, the system for treating and disposing

of cattle and other livestock manure could result in financial outcomes ranging from an overall

revenue of €1.5 million to a net cost of €5.5 million.

This is essentially due to the fact that the decline in the livestock heads would result in a significant

drop in the surplus of manure to the extent that the manure and its application to land coupled with

the capacity available at MBT would cater for a larger proportion of the supply of generated manure.

Table 7.9 Cattle and Other Livestock Manure: Financial Costs 2030

2020

Prime

Dynamic

Cost

(€/tonne)

Cattle and Other Livestock Manure Min Max Min Max

Production (m3 in 000s) 67.7 131.8

Applied to Crop 12.1 21.9 -24 290- 526-

Excess volume (Treatment or Disposal) 45.8 119.7

Treatment and Disposal

MBT (co-mingling of manure) 39.0 39.0 6 234 234

Other solutions 6.8 80.7

Digestion

Incineration

New Technologies

Export 6.8 80.7 91.3 618 7,369 Total Cost (€ 000s) 326 7,312

Manure GenerationTotal Financial Cost

(€ 000s)

?

?

?

2030

Prime

Dynamic

Cost

(€/tonne)

Cattle and Other Livestock Manure Min Max Min Max

Production (m3 in 000s) 46.5 132.0

Applied to Crop 27.9 64.4 -24 670- 1,546-

Excess volume (Treatment or Disposal) 0.0 104.1

Treatment and Disposal

MBT (co-mingling of manure) 39.0 39.0 6 - 234

Other solutions 0.0 65.1

Digestion

Incineration

New Technologies

Export 0.0 65.1 91.3 - 5,941 Total Cost (€ 000s) 1,546- 5,505

Total Financial Cost

(€ 000s)

?

?

?

Manure Generation

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Pig Slurry

The financial cost associated with the treatment and disposal of pig slurry is much more costly on

account of the greater reliance on export as an option to cater for its disposal. In 2016, the entire

volume generated would have to be exported on account of the fact that there are no treatment or

disposal facilities which can cater for the volume of pig slurry. As a result, the costs on an annual basis

could vary from €1.4 million to €14.4 million. It is to be reiterated once again that the variance in the

volume of pig slurry generated between the minimum and maximum scenarios is based on the

forecast uncertainty in the number of heads but also on the volume of water used to dilute the slurry.

The use of less water would result in a lower volume and hence lower export costs.

Table 7.10 Pig Slurry: Financial Costs 2016

Likewise the costs outlined in 2020 and 2030 also vary significantly. The costs presented in Table 7.11

and Table 7.12 respectively reflect the reliance on the export option at least in the short term as

dependence on technological options which can be applied in Malta and which can cater for pig slurry

remain to be studied in detail following the potential innovative element of applying these

technologies locally. In such a case the costs may vary from €0.6 million to €13.4 million in 2020 and

€0.2 million to €11.6 million in 20130.

2016

Prime

Dynamic

Cost

(€/tonne)

Pig Slurry Min Max Min Max

Production (m3 in 000s) 12.5 157.3

Applied to Crop 0.0 0.0

Excess volume (Treatment or Disposal) 12.5 157.3

Treatment and Disposal

MBT (co-mingling of manure) 0.0 0.0

Other solutions 12.5 157.3

Digestion

Incineration

New Technologies

Export 12.5 157.3 91.3 1,141 14,362 Total Cost (€ 000s) 1,141 14,362

Total Financial Cost

(€ 000s)Manure Generation

0.0

0.0

0.0

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Table 7.11 Pig Slurry: Financial Costs 2020

Table 7.12 Pig Slurry: Financial Costs 2030

A summary of the total annual financial costs for both the minimum and maximum scenarios is

presented in Table 7.13. Overall, the total costs in the short term which take into account the

treatment and disposal of cattle and other livestock manure and pig slurry could vary from €1.9 million

to €22.8 million on an annual basis with the latter costs reflecting the greater reliance on the export

option particularly in the short term on account of the fact that the only existing option to cater for

excess cattle manure is the MBT plant. The maximum total potential costs of about €22.8 million in

2016 represents 31% of the turnover generated by the livestock sector. The imposition of this cost on

the sector would result in competitiveness issues and severely dent the sustainability of the sector. As

a result, the extent to which government can provide support within the constraints of State Aid need

to be studied.

2020

Prime

Dynamic

Cost

(€/tonne)

Pig Slurry Min Max Min Max

Production (m3 in 000s) 7.1 146.4

Applied to Crop 0.0 0.0

Excess volume (Treatment or Disposal) 7.1 146.4

Treatment and Disposal

MBT (co-mingling of manure) 0.0 0.0

Other solutions 7.1 146.4

Digestion

Incineration

New Technologies

Export 7.1 146.4 91.3 648 13,367 Total Cost (€ 000s) 648 13,367

?

Manure GenerationTotal Financial Cost

(€ 000s)

?

?

2030

Prime

Dynamic

Cost

(€/tonne)

Pig Slurry Min Max Min Max

Production (m3 in 000s) 2.3 127.2

Applied to Crop 0.0 0.0

Excess volume (Treatment or Disposal) 2.3 127.2

Treatment and Disposal

MBT (co-mingling of manure) 0.0 0.0

Other solutions 2.3 127.2

Digestion

Incineration

New Technologies

Export 2.3 127.2 91.3 210 11,614 Total Cost (€ 000s) 210 11,614

Manure GenerationTotal Financial Cost

(€ 000s)

?

?

?

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Table 7.13: Summary of Financial Costs

In 2020 and 2030 the costs decline reflecting the drop in the number of heads of both cattle and pigs,

though the costs in the maximum scenario remain high at an annual value of €17 million. In the case

of the minimum scenario, it is possible for the system to generate an overall revenue of €1.3 million.

This also reflects the drop in livestock heads but is also marked by the more efficient use of water in

the management of agricultural waste. It is also to be noted that the revenue is also characterised by

the sale of the cattle manure for application to land which outweighs the costs of treating the excess

of cattle manure and the disposal of pig slurry.

Pig Slurry Min Max

2016 1,141 14,362

2020 648 13,367

2030 210 11,614

Bovine and Ovine Manure Min Max

2016 728 8,414

2020 326 7,312

2030 1,546- 5,505

Total Min Max

2016 1,869 22,777

2020 975 20,680

2030 1,336- 17,119

Annual Financial Cost (€ 000s)

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8. Agricultural Waste Management Governance System

It is evident that in order to ensure the optimal use and treatment of manure in compliance with the

regulatory obligations of the country, a holistic governance structure is required. This section thus

focuses on the development of a proposed centralised system under the auspice of the Ministry for

Sustainable Development, Environment and Climate Change (MSDEC).

The overall objective of the governance structure is to continuously update, co-ordinate and

implement the agricultural waste management plan as a matter of national policy with the

involvement of all key stakeholders. The proposed holistic system would cater for the

registration/acceptance of waste produced, the oversight of application to fields consistent with

regulatory arrangements, the implementation/oversight of treatment approaches leading to

production of fertilisers, energy and other output as well as the disposal of residual waste including

export of untreated waste.

The governance structure could ensure that the national system enters into long term agreements

with producers and users of manure and providers of treatment/disposal facilities to safeguard the

sustainability of its operations.28 In the short term, policy makers may consider implementing the

system in a manner to cater for the production, treatment and disposal of slurry which as explained

in the context section of the agricultural waste management plan, is the agricultural waste which is

clouded in most uncertainty and which is posing the greatest challenges for treatment and disposal.

Eventually the structure could be rolled out to cater for manure generated by all livestock including

cattle, goat, sheep, poultry and rabbit.

It is possible for the national system to function through the utilisation of a number of facilities,

possibly operated by both public and private operators under the principle of a Public Private

Partnership (PPP). In terms of funding, it is proposed that the system could fund the cost of its

operations and of its constituent parts, allowing for an element of reasonable profit, where relevant,

and subject to public policy decision making with respect to the agricultural sector. The system could

be financed through a combination of revenue sources including fees on the producers of manure,

applied in a standard manner across all operators although the rates would vary by the type of

livestock, given that cost of treatment for manure/slurry varies. The cost would need to take into

account and implement the principle of recovery which on the one hand will dent the financial

sustainability of the livestock sector and yet on the other hand may be subject to State Aid scrutiny.

This section of the report thus seeks to provide an overview of the proposed governance system taking

into account the stakeholders involved, the strategic elements of the system, its functions as well as

the corporate structure.

28 It is suggested that the livestock limit is established in L.N 94 of 2015 Schedule 4. In terms of the application of manure to land, the limit could be set at less than 2 tumoli.

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8.1 Stakeholders involved in the Governance System

The proposed system is a centralised system which would operate under the auspices of the MSDEC.

The direct key stakeholders who would be involved in the governance system are all livestock farmers

which are the generators of the manure/slurry and crop farmers. The Agriculture Directorate and

Directorate for Environment and Climate Change both have a key role to play in the effective

management of the system. Other interested parties who should be involved in the governance

structure are the crop producers, the Sustainable Energy and Water Conservation Unit (SEWCU) in

particular the water unit, the Malta Environment and Planning Authority (MEPA), providers of

agricultural waste management services such as transport providers, treatment providers and other

relevant entities as well as Non-Governmental Organisations (NGOs).

8.2 Strategic Elements of the Governance System

The scope of the governance system will be to implement the Agricultural Waste Management Plan

with respect to the collection, treatment and disposal of manure/slurry while ensuring compliance

with key legislation. The role of the governance structure will not be to regulate but to ensure

adherence with regulatory requirements. Indeed the scope of the governance system will be to

manage the system but not implement enforcement. This role will remain under the responsibility of

respective competent authorities such as the Agriculture Directorate . It is however to be noted that

the effectiveness of the governance structure depends on the enforcement of regulatory

requirements.

One of the key strategic elements of the governance structure is to encourage the minimisation of

waste generation. This not only entails the monitoring of heads but also establishing a system which

incentivises the efficient generation of manure/slurry including the discontinuation of abundant use

of water leading to high volumes of diluted slurry.

The objective of the centralised governance structure is to optimise the management options

discussed in the previous section of this report. This entails avoiding any duplication of efforts in

catering for the use, treatment and disposal of manure while ensuring a steady stream of manure to

be treated and disposed of and thus ensuring the effective utilisation of any agricultural waste

infrastructure. The governance structure should also serve as a reference entity to stakeholders and

a one stop shop for all entities involved with manure/slurry management.

The governance structure also has an important strategic role to play in developing a technological

mix of treatment and disposal options which are efficient and minimise costs. As a result, while in the

short term, export seems to be the most viable solution particularly in terms of managing slurry, the

governance structure should ensure that less costly innovative solutions are sought in the medium to

long term.

As explained in previous sections, a number of options which may be technically viable remain

untested in Malta and thus the applicability of these options remains to be studied. In particular, the

wide range of water volumes used in pig slurry limits its treatment and disposal options. Furthermore,

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the limited land area in Malta coupled with the high population density restricts the availability of land

upon which large scale treatment and disposal facilities could be located. Therefore an additional key

strategic element envisaged for the governance system is the promotion of innovative technologies

and the setting-up of pilot projects to cater for manure and slurry, particularly in the medium to long

term.

8.3 Functions of the System

It is proposed that the governance system which may be established through a legislative framework,

would have four key functions namely an administrative role, strategic planning, operational

monitoring and development of the system in an innovative manner.

8.3.1 Administrative Role

The administrative role of the governance system entails the registration and licensing of all

manure/slurry producers. It is to be noted in this regard that the role of the governance structure will

not be to duplicate functions which are already undertaken by other government departments but

rather to utilise existing structures and provide one full picture. Towards this end, it is understood that

the Agriculture Directorate already has a registry of licensed manure/slurry producers whereby the

registry contains relevant data such as the location of farms and number of livestock held. This is useful

in this regard.

Following the collection of registry information on manure/slurry producers, the volume of

manure/slurry to be produced by each producer for a 12 month forward looking period will be

determined. This will be based on available literature and expert opinion whereby the expected

volume of manure/slurry would depend on the type of livestock, number of heads as well as other

parameters such as conformity with environmental and animal husbandry regulations and good

animal husbandry practices. Towards this end, current on-farm practices are to be considered taking

into account the inefficiencies which exist in terms of the use of water particularly for slurry produced

by pig farms. Once the volume of manure/slurry is established, the governance structure would have

to ensure a declaration and authorisation for the generation of manure/slurry by the producers.

The structure would also require registration and licensing of manure/slurry users as well as the

volume of manure/slurry29 to be used by each user on a 12 month forward looking basis taking into

consideration the Fertiliser Plans. The Agriculture Directorate has a registry of the number of farmers

and the respective land area upon which crops are grown. Soil analyses is currently being undertaken

as part of the fertiliser plans to collect data will allow for a detailed estimate of the extent to which

fertilisers can be applied to land varying by land parcels. It is also to be noted that farmers are,

29 While the application of slurry to land is currently not permissible, it may be considered as an option following the required pre-treatment.

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according to legislation, obliged to maintain data on the use of manure/slurry according to a

predetermined template set by the Agriculture Directorate. Once the users are registered, the

governance structure would have to ensure a declaration and authorisation for the use of

manure/slurry by land owners. Excess manure/slurry would need to be catered for through pre-

established treatment and disposal options.

The Agriculture Directorate is also in the process of developing a registry for manure/slurry

transporters. The transporter will be legally obliged to register and to maintain a registry of the volume

of manure transported. Transporters will also be legally obliged to maintain information on the source

of origin of the manure/slurry and the end user of the manure/slurry. It is proposed that the services

providers are periodically identified through a request for proposals following public procurement

rules. This process should also entail the identification of services provision as well as minimum and

maximum capacity levels on a 12-month forward looking basis.

The system would also require the registration of and licensing of manure/slurry treatment providers

which should also be periodically identified through a request for proposals which also follows public

procurement rules. This could include proposers of new treatment proposals, which require a period

of experimentation to ensure feasibility for Malta. The treatment providers would also be required to

provide a minimum and maximum capacity level on a 12-month forward looking basis.

In terms of the export option, the governance system would also require the formulation of

agreements with competent authorities abroad regarding the quantity of waste to be exported and

the characteristics of the manure/slurry which can be exported on a 12 month forward looking period.

Following the registration of manure/slurry producers, users, transporters and treatment service

providers the governance structure requires the formulation of contracts for the retrieval of manure

from farms, for transport, application to land, treatment and export with relevant counterparts

spanning a 12-month basis. These contracts will provide specific details such as the waste volumes

and prices as well as all operating parameters with counterparties involved affecting the relevant

characteristic of such waste. This thus includes the type of on farm waste management practices,

transport modalities, characteristics of waste sent to treatment facilities and other relevant

parameters. These contracts would be legally enforceable instruments which induce appropriate

practices by all parties involved. The breach of the contract would be subject to fines and revocation

or limitation of operating licences. This is similar to the Manure Transfer Agreement which was

adopted in the Netherlands in 2001 whereby livestock farms sign an agreement which states that the

surplus amount of animal manure is contracted by other farms that can adequately accommodate the

manure. When farms with a surplus amount of animal manure are not able to submit such a manure

transfer agreement, the license for animal production for the next year is lost.

Administrative simplification is to be ensured through integration with existing administrative

registers/databases/licensing/permitting systems. Furthermore it is suggested that farms falling

within the livestock limit as established in L.N 94 of 2015 Schedule 4 are exempted from the system.

Likewise, it is suggested that crop farmers with an area of less than 2 tumoli of utilized land are

exempted from the system.

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8.3.2 Strategic Planning

The second function of the proposed centralised governance structure focuses on strategic planning

and determining the destination of the manure/slurry produced on a 12 month forward looking basis

on a weekly frequency basis. The system will account for the supply of manure/slurry as well as

demand and cater for the treatment and eventual disposal including export of manure which is not

applied to land.

The governance structure also has a key role in establishing the cost/prices of manure and slurry

produced in Malta and applied at farm gate. The cost will have to be pre-determined based on the

upcoming 12 months. The value derived will take into account all elements of the system including

generation, transportation, treatment and disposal including export and would need to establish

prices to be paid for internal transport, sale, treatment and export of manure and slurry within the

context of overall financial sustainability of each activity. Ultimately the cost/price of manure and

slurry in Malta to be paid/received by farmers within the context of the overall cost, revenues and

financial sustainability of each activity will have to be determined for each type of livestock category

or groups of livestock. The prices, incomes payable and receivable by all operators in the system on a

12-month forward looking basis should be announced to ensure transparency.

As explained in the previous section, the cost of treatment and disposal varies significantly and it is

the role of the governance structure to determine a national cost which takes into account all of the

different elements. It is to be noted in this regard, that given the various uncertainty elements in the

generation of manure/slurry which exists by the different type of livestock and the various treatment

options which also depends on the manure/slurry generated by the livestock, it is suggested that the

price varies by livestock particularly distinguishing between the management of manure generated by

cattle, goats, sheep and poultry as opposed to slurry generated by swine.

It is to be noted that the rate would need to take into account the financial sustainability of the

agricultural sector and may thus be subject to support from public resources subject to the resolution

and monitoring of State Aid issues.

8.3.3 Operational Monitoring

The third function of the proposed governance structure is the operational monitoring of the system.

The centralised governance structure must oversee the operation of the contracts and compliance of

the contracts by all parties involved in the system including the waste producers, transporters, users

of manure, treatment service providers and exporters. Deviations from contracts should be penalised

accordingly.

The governance structure must also coordinate with relevant authorities involved in compliance with

legislative and regulatory requirements. It is once again stressed that the role of the governance

structure will not be to regulate but to ensure compliance with regulatory requirements through the

setup of the system.

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In the absence of private operators who would partake in the treatment and disposal of the

manure/slurry, it is proposed that the governance structure should be directly involved in the

transport, treatment and exporting activities. It is thus not excluded that the governance structure

engages in a private public partnership agreement to undertake these activities.

8.3.4 System Development/Innovation

The final function of the governance structure will be to spur innovation and not rely on short term

solutions such as export. The governance structure will need to develop the system in a manner which

considers technologies which might be tried and tested abroad as explained in the previous section

but which may be experimental to Malta. Therefore the governance structure would be involved in

the formulation of contracts with entities testing innovative treatment technologies in Malta. The

governance structure could also pre-determine the financial support if relevant, to determine these

technologies including aspects such as land use on behalf of Government. These contracts would also

establish the delivery of manure to ensure utilisation of testing infrastructure. Following the

experimental stage, which may vary depending on the type of technology, the governance structure

should also be involved in the decision making regarding the acceptability of the system.

This element is considered particularly important given the use of partnership agreements expected

under the recently approved RDP 2014-2020 where expenditure has been allocated for encouraging

co-operation. Of particular relevance is the support for pilot projects and technologies whereby

manure is considered as a relevant area of intervention. The management of farm waste has been

identified as a weakness in the Programme and measures identified inthe Programme will seek to

address nitrate pollution by targeting livestock farming and prioritising investments in manure

storage.

8.3.5 Corporate Structure

As explained above, in the absence of private operators which partake in the treatment and disposal

of manure/slurry, the governance structure could be based on the principle of a Private Public

Partnership (PPP). The private operators would be established through a request for proposals with a

five year operational horizon to minimise State Aid issues. These operators could also involve waste

producers and/or treatment services providers which can also apply through an RFP as a group or

participate with other groups. The five year period is considered adequate to cater for development

in the number of farms and heads of livestock as well as technological solutions. It also not excluded

that that the private operators, as a group, are represented under a single entity which is also selected

following a request for proposal.

The Government could allocate a financial support element to the PPP to sustain its operation on a

five year forward looking basis. This could be spelled out in the initial request for proposals, and

estimated at levels which are consistent with climate emissions, water and other environmental cost

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savings due to the operation of the system. This support would ultimately have a significant influence

on the final cost of the system to farmers and would be subject to state aid considerations.

From a corporate structure point of view, the system would require a Management Board and

Secretariat as well as Executive functions Rural Development Policy across the EU supports the set-up

of co-operations which allow for the set-up of adequate organisation structures for biomass delivery

with emphasis on the utilisation of agricultural waste and residues for renewable energy production

or for bio-based products.

In order to operate the system, it is envisaged that a chief executive officer is required, one or two

agricultural engineers, an environmental specialist in waste management, a logistics officer to cater

for the transport of manure/slurry as well as two legal officers to monitor and update contracts as

well as four support staff.

The operational cost is likely to approximate €450,000 per annum including salaries, renting of office,

running costs and external support. Thus is to be considered in addition to the support to be allocated

by Government to the system in order to alleviate the burden on livestock farmers, subject to State

Aid considerations.

8.3.6 Governance Structure Milestones

A tentative structure of the milestones for the implementation of the Governance structure is

presented hereunder. These milestones take into consideration the deadlines established by the

European Commission in relation to the implementation of the Water Framework Directive

Programmes of Measures, whereby the Commission states that in its second River Basin Management

Plan Malta must submit a plan on resolving the discharge of animal husbandry waste in the sewage

collecting system.

Towards this end, the approval of the Updated Agricultural Waste Management Plan including the

Governance Structure is aimed towards the end of the year, December 2015. Following approval, the

set-up of the Governance Structure should be developed by January 2016 with recruitment of staff

occurring by the first quarter of 2016.

The business plan for the Governance Structure is aimed for completion by May 2016 after which

there will be the issuance for the request for proposals and transformation of the structure in to a

private public partnership by July 2016.

The implementation of Business Plan will include the following elements:

Determination of solutions for each of the 40 largest pig operators by December 201630

Drawing up of contracts with each operator and roll out of solution implementation by June 2017

Determination of solution for each of the largest 50 cattle operators by July 201731

30 Suggested largest pig operators which is to be approved by policymakers. 31 Suggested largest cattle operators which is to be approved by policymakers.

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Drawing up of contracts with each operator and roll out of solution implementation by October

2017

Following the initial operational developed of the governance structure, it is suggested that there is a

gradual rollout to all other livestock operators such that by the end of December 2017, all livestock

operators falling outside the limit set by LN 94 of 2015 are included in the structure.

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Figure 8.1: Governance Structure Milestones

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov DecGovernment approval of the Updated Agricultura l

Waste Management Plan including the

Governance Structure

Setting up of the Governance Unit

Recruitment of s taff

Drawing up of bus iness plan

Issuance of RFP and transformation of

Governance unit into PPP

Implementation of Business Plan which includes the

following elements:

Determination of solutions for each of the 40 (?)

largest pig operators

Drawing up of contracts with each operator and

rol l out of solution implementation

Determination of solution for each of the largest

50 (?) cattle operators

Drawing up of contracts with each operator and

rol l out of solution implementation

Gradual rol lout to a l l other l ivestock operators

2015 2016 2017

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9. CONCLUSION

This Agricultural Waste Management Plan has been developed in a manner which takes into account

the legislative framework under which the livestock sector must operate as well as current practices

in the treatment and disposal of waste distinguishing between the generation of slurry and manure.

The specific constraints in developing the options outlined in the Plan have mainly focused on

adherence to the Nitrates directive, Water Framework Directive and Urban Wastewater Directive.

As explained in the report, there are a number of uncertainties associated with the generation of

manure/slurry including albeit not restricted to the uncertainties associated with the forecasts of

livestock heads, the mass of waste generation which is also affected by the water added to the pig

slurry, the amount of nitrates applied to land as well as the future development of cost variables.

These elements of uncertainty and risk have set the framework for the development of options which

cater for a degree of flexibility.

In the short term, the system will have to rely on the export of agricultural waste with the option

serving as a stop gap solution until other technical options are developed and implemented. In the

medium to long-term the system will need to implement innovative solutions which take into account

the specific characteristics of the Maltese Islands. It is emphasised that this report is not indicating

any one particular solution as being the preferred one, but rather advocates the need for a mix of

solutions which consider specific needs and requirements of different farms at different points in time.

The critical activities in the development of the system are to:

To obtain forecasts for application of N to land on basis of soil sampling under Nitrates Action

Plan

Promotion of efficient on-farm practices to minimise generations of waste

Obtain decisions regarding whether the development of digestion plants in Malta and/or Gozo

are politically/socially acceptable and consider the environmental and planning feasibility of

the infrastructure

Obtain policy decisions regarding change of use of farms

Promote experimental and innovative methods of treatment and disposal to determine the

technical viability of these options for Malta

These pillars of the agricultural waste management plan cannot be considered in isolation. A coherent

and flexible policy mix is required to contribute towards a compliant and cost effective system. This in

turn requires a framework of effective supervision and enforcement of legislation. The effective

supervision requires the development of a governance structure which can focus on each elements of

the pillar including the minimisation of waste generation, compliance with legislation, optimisation of

management options as well as promotion of innovation at least within the local context.

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REFERENCES

Envico Consultancy, (2013), ‘Report on Volume Excretion Figures (per animal type) for Three Main Animal Categories (Sows, Heifers & Calves)’. European Commission, (2015), ‘Commission Staff Working Document Report on the progress in

implementation of the Water Framework Directive Programmes of Measures.

Frandsen, T. Q. Rodhe, L., Baky, A., Edström, M., Sipilä, I., K., Petersen, S.L., Tybirk, K., (2011). ‘Best

Available Technologies for pig Manure Biogas Plants in the Baltic Sea Region’

Ministry for Sustainable Development. The Environment and Climate Change, (2014), ‘Waste

Management Plan for the Maltese Islands 2014-2020 (WMP2014-2020)’

MEPA, (2011), ‘The Water Catchment Management Plan for the Maltese Islands‘

MEPA, (2009). ‘Malta’s Biennial Report on Policies and Measures and Projected Greenhouse Gas

Emissions’.

National Statistics Office, (2013), ‘Agriculture and Fisheries’.

National Statistics Office, (2010), ‘Census of Agriculture’.

Sustech Consulting, (2008), ‘Agricultural Waste Management Plan for the Maltese Islands’.

Mallia and Right (2004), MINAS: A post mortem?’, Rosklide University,

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Annex 1: Detailed Scenario Results (Cattle Manure and Pig Slurry Applied to Crops)

2015 2020 2025 2030 2015 2020 2025 2030 2015 2020 2025 2030

Cattle Cattle Cattle

Heads (000s) 14.1 12.8 12.8 12.8 Heads (000s) 14.1 12.8 12.8 12.8 Heads (000s) 14.1 12.8 12.8 12.8

N (kgs) 731,602 664,149 664,149 664,149 N (kgs) 731,602 664,149 664,149 664,149 N (kgs) 731,602 664,149 664,149 664,149

volume (m3) 113,891 103,391 103,391 103,391 volume (m3) 113,891 103,391 103,391 103,391 volume (m3) 113,891 103,391 103,391 103,391

Pig Pig Pig

Heads (000s) 42.7 34.9 34.9 34.9 Heads (000s) 42.7 34.9 34.9 34.9 Heads (000s) 42.7 34.9 34.9 34.9

N (kgs) 426,705 348,703 348,703 348,703 N (kgs) 426,705 348,703 348,703 348,703 N (kgs) 426,705 348,703 348,703 348,703

Total N (kgs) 1,158,307 1,012,853 1,012,853 1,012,853 Total N (kgs) 1,158,307 1,012,853 1,012,853 1,012,853 Total N (kgs) 1,158,307 1,012,853 1,012,853 1,012,853

UAA (ha) 11,618 11,330 11,050 10,776 UAA (ha) 11,618 11,330 11,050 10,776 UAA (ha) 11,618 11,330 11,050 10,776

N uptake by crops 1,274,323 1,242,781 1,212,021 1,182,022 N uptake by crops 1,274,323 1,242,781 1,212,021 1,182,022 N uptake by crops 1,274,323 1,242,781 1,212,021 1,182,022

N (kgs) 116,015- 229,929- 199,168- 169,169- N (kgs) 202,565 80,767 199,168- 169,169- N (kgs) 521,146 391,462 199,168- 169,169-

GNB/ha -9.99 -20.29 -18.02 -15.70 GNB/ha 17.44 7.13 -18.02 -15.70 GNB/ha 44.86 34.55 -18.02 -15.70

Cumulative starting in 2015 -9.99 -85.68 -181.48 -265.78 Cumulative starting in 2015 17.44 78.84 51.60 -32.70 Cumulative starting in 2015 44.86 243.37 284.69 200.38

Treatment volumes (m3): Treatment volumes (m3): Treatment volumes (m3):

Cattle - - - - Cattle 31,534 12,573 - - Cattle 81,129 60,940 - -

N (kgs) 202,565 80,767 103,837 126,336 N (kgs) 521,146 391,462 103,837 126,336 N (kgs) 839,727 702,157 103,837 126,336

GNB/ha 0.00 0.00 0.00 0.00 GNB/ha 0.00 0.00 0.00 0.00 GNB/ha 0.00 0.00 0.00 0.00

Cumulative starting in 2015 0.00 0.00 0.00 0.00 Cumulative starting in 2015 0.00 0.00 0.00 0.00 Cumulative starting in 2015 0.00 0.00 0.00 0.00

Treatment volumes (m3): Treatment volumes (m3): Treatment volumes (m3):

Cattle 31,534 12,573 16,165 19,667 Cattle 81,129 60,940 16,165 19,667 Cattle 130,723 109,308 16,165 19,667

N (kgs) 518,985 405,071 435,832 465,831 N (kgs) 837,565 715,767 435,832 465,831 N (kgs) 1,156,146 1,012,853 435,832 465,831

GNB/ha 0.00 0.00 0.00 0.00 GNB/ha 0.00 0.00 0.00 0.00 GNB/ha 0.00 0.00 0.00 0.00

Cumulative starting in 2015 0.00 0.00 0.00 0.00 Cumulative starting in 2015 0.00 0.00 0.00 0.00 Cumulative starting in 2015 0.00 0.00 0.00 0.00

Treatment volumes (m3): Treatment volumes (m3): Treatment volumes (m3):

Cattle 80,792 63,059 67,848 72,518 Cattle 130,387 111,426 67,848 72,518 Cattle 179,982 157,675 67,848 72,518

No prioritisation of Uptake of N from Soil by Crops

Surplus (assuming inorganic at 2007 level, 635000kg):

Surplus (assuming 25% inorganic):

Surplus (assuming no inorganic):

N Application to Crop

Generation

Surplus (assuming inorganic at 2007 level, 635000kg):

Prioritisation of Uptake of N from Crops at 25% of Uptake

Generation

N Application to Crop

Surplus (assuming no inorganic):

Surplus (assuming 25% inorganic):

Surplus (assuming inorganic at 2007 level, 635000kg):

Prioritisation of Uptake of N from Crops at 50% of Uptake

Generation

N Application to Crop

Surplus (assuming no inorganic):

Surplus (assuming 25% inorganic):

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Annex 2: Detailed Scenario Results (Cattle Manure Only Applied to Crops)

2015 2020 2025 2030 2015 2020 2025 2030 2015 2020 2025 2030

Cattle Cattle Cattle

Heads (000s) 14.1 12.8 12.8 12.8 Heads (000s) 14.1 12.8 12.8 12.8 Heads (000s) 14.1 12.8 12.8 12.8

N (kgs) 731,602 664,149 664,149 664,149 N (kgs) 731,602 664,149 664,149 664,149 N (kgs) 731,602 664,149 664,149 664,149

volume (m3) 113,928 103,424 103,424 103,424 volume (m3) 113,928 103,424 103,424 103,424 volume (m3) 113,928 103,424 103,424 103,424

Pig Pig Pig

Heads (000s) - - - - Heads (000s) - - - - Heads (000s) - - - -

N (kgs) - - - - N (kgs) - - - - N (kgs) - - - -

Total N (kgs) 731,602 664,149 664,149 664,149 Total N (kgs) 731,602 664,149 664,149 664,149 Total N (kgs) 731,602 664,149 664,149 664,149

UAA (ha) 11,618 11,330 11,050 10,776 UAA (ha) 11,618 11,330 11,050 10,776 UAA (ha) 11,618 11,330 11,050 10,776

N uptake by crops 1,274,323 1,242,781 1,212,021 1,182,022 N uptake by crops 1,274,323 1,242,781 1,212,021 1,182,022 N uptake by crops 1,274,323 1,242,781 1,212,021 1,182,022

N (kgs) 542,721- 578,632- 547,872- 517,873- N (kgs) 224,140- 267,937- 547,872- 517,873- N (kgs) 94,441 42,759 547,872- 517,873-

GNB/ha -46.71 -51.07 -49.58 -48.06 GNB/ha -19.29 -23.65 -49.58 -48.06 GNB/ha 8.13 3.77 -49.58 -48.06

Cumulative starting in 2015 -46.71 -291.17 -542.80 -786.89 Cumulative starting in 2015 -19.29 -126.64 -309.71 -553.81 Cumulative starting in 2015 8.13 37.89 -76.63 -320.73

Treatment volumes (m3): Treatment volumes (m3): Treatment volumes (m3):

Cattle - - - - Cattle - - - - Cattle 14,707 6,659 - -

N (kgs) 224,140- 267,937- 244,866- 222,367- N (kgs) 94,441 42,759 244,866- 222,367- N (kgs) 413,021 353,454 244,866- 222,367-

GNB/ha -19.29 -23.65 -22.16 -20.63 GNB/ha 0.00 0.00 -22.16 -20.63 GNB/ha 0.00 0.00 -22.16 -20.63

Cumulative starting in 2015 -19.29 -126.64 -241.16 -348.15 Cumulative starting in 2015 0.00 0.00 -55.40 -162.39 Cumulative starting in 2015 0.00 0.00 -55.40 -162.39

Treatment volumes (m3): Treatment volumes (m3): Treatment volumes (m3):

Cattle - - - - Cattle 14,707 6,659 - - Cattle 64,317 55,041 - -

N (kgs) 92,279 56,368 87,128 117,127 N (kgs) 410,860 367,063 87,128 117,127 N (kgs) 729,441 664,149 87,128 117,127

GNB/ha 0.00 0.00 0.00 0.00 GNB/ha 0.00 0.00 0.00 0.00 GNB/ha 0.00 0.00 0.00 0.00

Cumulative starting in 2015 0.00 0.00 0.00 0.00 Cumulative starting in 2015 0.00 0.00 0.00 0.00 Cumulative starting in 2015 0.00 0.00 0.00 0.00

Treatment volumes (m3): Treatment volumes (m3): Treatment volumes (m3):

Cattle 14,370 8,778 13,568 18,240 Cattle 63,981 57,161 13,568 18,240 Cattle 113,591 103,424 13,568 18,240

No prioritisation of Uptake of N from Soil by Crops

Surplus (assuming inorganic at 2007 level, 635000kg):

Surplus (assuming 25% inorganic):

Surplus (assuming no inorganic):

N Application to Crop

Generation

Surplus (assuming inorganic at 2007 level, 635000kg):

Prioritisation of Uptake of N from Crops at 25% of Uptake

Generation

N Application to Crop

Surplus (assuming no inorganic):

Surplus (assuming 25% inorganic):

Surplus (assuming inorganic at 2007 level, 635000kg):

Prioritisation of Uptake of N from Crops at 50% of Uptake

Generation

N Application to Crop

Surplus (assuming no inorganic):

Surplus (assuming 25% inorganic):