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Agriculture Land Reform White Paper - Feedback

Moviment Graffitti and the Malta Youth in Agriculture (MaYA) Foundation have jointly reviewed the “Acquisition and Ownership of Farmland Reform” White Paper. While we feel it is a much needed step in the right direction, in general the document is rather vague in its definitions, which leaves space for loopholes that can cause more harm than good.

We have therefore listed some issues we identified throughout the document pertaining to these definitions and offer some constructive criticism. In addition, we feel the document does not go far enough in addressing Malta’s future needs for ensuring an extent of food security and resilience, which can be affected by the type of land agreements currently being designed, especially in view of Malta’s modelled and expected climate in the coming decades.

Feedback to Consultation process - Agricultural Land - MG - MaYA
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Issues raised about the White Paper published on 4th October 2022

  1. What is a genuine farmer? This definition is lacking. Furthermore, leases of Government land can be transferred to bona-fide farmers. What is a bona-fide farmer? This is currently a massive loophole and needs to be avoided in this new legislation. The registered agricultural labour workforce decreased by 25% between 2010 and 2020 according to NSO. The vast majority of farmers are part-timers. Since Malta’s accession to the EU, it has been widely acknowledged that farmers are not only food producers but are also environmental stewards, therefore they cannot be solely viewed as stakeholders with an economic output.

  2. There is a danger in defining a genuine farmer based on ‘product value outgoing from agricultural land or farm over a period of one year’. The phrase “product value outgoing from agricultural land'' can easily be interpreted as if agricultural land that does not produce economic gains is not relevant. What about subsistence farmers? The numerous subsistence farmers who are also important in the upkeep of the rural landscape are not considered in terms of economic output. What if the current wording incentivises farmers to avoid long-term investments in order to reach product value targets to meet the ‘genuine farmer’ definition?

  3. 8 – 16 years max lease: This can be expanded for those planning to invest in long-term agricultural investments eg. fruit trees. Only longer-term leases can ensure feasible investment. Farmers need to be given reassurances regarding their tenureship.

  4. Long-term transformation of agricultural land will minimise climate change impacts. It would be good to integrate incentives taking into consideration Malta’s climate 20-50 years from now. This would prepare Malta to be both more climate and food security resilient.

  5. The market value of agricultural land is currently inflated. We recommend the value of land to be based not on market value but on established criteria such as water supply, size of land, soil fertility, proximity to access, and other criteria. This is also a phenomenon which spiked recently due to the high demand for rural recreational land and dwellings; both of which need to be better regulated in order to safeguard agricultural land.

  6. Enforcement is barely mentioned in the White Paper. There needs to be further investment in enforcement so that all the measures mentioned will not be subject to abuse and injustice.

  7. Agricultural officers need to be empowered in order to safeguard agricultural land based on their local expertise. They should have a say on PA decisions, especially on land in the vicinity of development zones, as there can be spillover effects from urbanisation (eg. water supply, pollution, sewage effluent).

  8. Re: Point 1 - land acquired by the Authority – how will ‘affordable rates’ be determined? Will the authority be acquisitioning land at market rates and lowering it for farmers?

  9. Re: Point 1 - Board of experts proposed on page 17: Who will the members of the board of experts be? What percentage of NGO representatives and experts will be allocated? What power will the board have over the PA? Additionally, will there be any mechanisms to ensure that these are independent and not affiliated to political power plays?

  10. Re: Point 5 - “The Authority shall establish measures to safeguard and ensure the need to cultivate agricultural land for its agricultural scope and purpose” on page 20: What are these measures?

  11. Re: Point 7 - “Landowners who intend to sell their agricultural land will have the option of selling land to the Authority.” On page 20 – will there be incentives to encourage landowners to sell their land to the Authority?

  12. Re: Point 8 - “The Authority as an intermediary” on page 21: How will it act as an intermediary? Within what scope and through which mechanisms? How autonomous, in terms of decision-making, would this new authority be? This could easily be included within MAFA’s portfolio since the scope of this White Paper is to preserve agriculture.

  13. Re: Point 9 - Coordination between Authority to be established and PA – page 22: “to strengthen control over the acquisition and tenure of land, leading to improvements in systems safeguarding agricultural land from undesirable development.” How and when will they work together? What if their policies contradict one another? What strength will the Authority have during PA hearing sessions?

  14. Re: Point 10: “Defining an agricultural lease in a just and fair manner” – In what way? Under which criteria? What weight will be given to upholding environmental and food security principles vs market price?

  15. While the right of landowners and their assets, in this case agricultural land, should be safeguarded, we strongly feel that food security and environmental stewardship and the agricultural sector’s key role in these areas should be given priority over commercial, residential or industrial interests which the land may take once it is leased.

  16. Even though in recent parliamentary discussions most MPs have chosen to give credit to future farmers, this document has no specific mention of already existing young farmers. Generation renewal and continuity of the farming sectors can only be ensured if our young farmers are given access to farmland.

  17. There is no mention of tenureship in terms of EU funds and long-term projects. Tenureship agreements need to be solid and legally binding, and they cannot afford to be subjected to the whims of landowners. In the case where farmers have obtained EU funding (ie. taxpayers’ money), the land will be required to maintain its agricultural activity to ensure that the beneficiary will maintain farming operations and activities.

  18. Over the past 20 years the sharp decline in the output of the agricultural sector in terms of GDP and GVA has continued, going from 2.97% of GDP in 2002 to 1.6% in 2012. GVA has declined from 1.3% in 2012 to 0.7% in 2020. Despite the agricultural sector’s decline in terms of monetary value and output, its real value has increased significantly in light of declining food security, rampant urbanisation and the sector’s importance in safeguarding the environment. The environmental stewardship and socially linked benefits have outweighed economic significance in agriculture by far, and this needs to be recognised in this document and in any further legislation.

  19. On page 9, a reference is being made to students (Studenti tal-biedja). It would be good to explain further who may qualify for this scheme, and with which level of qualification.

  20. On page 9. regarding the use of the word “suffer” - how can one assess who is suffering the most, or who is at the larger disadvantage, and how can it be measured?

  21. Food security keeps being mentioned. Have any studies been done for us to know more on how much land is needed to sustain our population, for a determined amount of time, and what type of land is needed?

  22. We strongly suggest that there will be a further public consultation to clearly define important terms such as ‘Genuine Farmer’ and “Agriculture”. The term “Agriculture” or “Farming” is a very generic one and it has been un/intentionally misinterpreted to the detriment of the sector. The definition for local agriculture should be one which respects traditions while embracing technological advancement, and which takes into consideration the islands’ limitations and strengths.


Ministry for Agriculture, Fisheries and Animal Rights (2022)

Parliamentary Secretary for Agriculture, Fisheries and Animal Rights (2018)

Photo by Tessa Mercieca.

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