Annexe 26 - Etude nationale Malte
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Annexe 26 - Etude nationale Malte

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EVALUATION DES MESURES AGRO-ENVIRONNEMENTALES AGRI/ G4/ 2004 ANNEXE 26 : ETUDE NATIONALE MALTE Novembre 2005 Evaluation of agri-environmental measures - Malta TABLE OF CONTENTS 1. STATE OF THE AGRICULTURE AND AGRICULTURAL ENVIRONMENT IN THE COUNTRY 1 1.1 Brief description of the agriculture in the country............................................................ 1 1.1.1 Main categories of production (quantity, value).............................................................................. 2 1.2 Brief description of the environment in agriculture ............................................................... 6 1.3 Brief presentation of the AE system in the country ........................................................ 10 1.3.1 Description of the historic of implementation of AEM ................................................................. 10 1.3.2 Description of the portfolio of AEM in the country (main objectives of the AEM, possible zoning of intervention, etc.).................................................................................................................................... 11 1.3.3 – List of the AEM .......................................................................................................................... 12 1.3.4 Organisation of the implementation at national and regional level ............................................... 13 1.3.5 Level of ...

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        EVALUATION DES MESURES AGRO-ENVIRONNEMENTALES AGRI/ G4/ 2004  ANNEXE26 : ETUDE NATIONALEMALTE  
Novembre 2005
Evaluation of agri-environmental measures - Malta
TABLE OF CONTENTS 
1.STATE OF THE AGRICULTURE AND AGRICULTURAL ENVIRONMENT IN THE COUNTRY11.1Brief description of the agriculture in the country............................................................ 11.1.1 .............................................................................. 2Main categories of production (quantity, value)1.2 Brief description of the environment in agriculture ............................................................... 61.3Brief presentation of the AE system in the country ........................................................ 101.3.1Description of the historic of implementation of AEM ................................................................. 101.3.2AEM in the country (main objectives of the AEM, possible zoningDescription of the portfolio of of intervention, etc.) .................................................................................................................................... 111.3.3 List of the AEM .......................................................................................................................... 121.3.4Organisation of the implementation at national and regional level ............................................... 131.3.5Level of development of the good agricultural practice documentation........................................ 161.4The level of implementation of the measures................................................................... 192.ANSWER TO EVALUATION QUESTIONS ........................................................................ 212.1.1Q 9 : To what extent can the existing or planned institutional structures and working methods in the new Member States facilitate or hinder the construction of programmes and good quality agro-environmental measures ? .......................................................................................................................... 212.1.2of the programme adequate as regards the EU contribution,Q 10 : To what extent is funding Member State budget, regional budget ? .................................................................................................... 262.1.3monitoring, evaluation and supervision of the agro-environmentalQ 11 : To what extent are the measures in place in the Member States fit for the purpose ? ..................................................................... 272.1.4Q 12 : To what extent have the degree of application been influenced (or should be influenced) by other implementation factors or other relevant factors (such as the attitude towards the agro-environment, knowledge of the agro-environment at all levels within the Member State, the extent of GAPs, other CAP /EU measures, 5-year minimum contracts, limitation of beneficiaries to farmers only etc.) ............. 303.CONCLUSION ANDRECOMMENDATIONS............................................................... 33APPENDICES........................................................................................................................ 34Annex 1: List of people met ........................................................................................................... 34Annex 2: Main bibliography identified in relation with the study including reports made prior to the EU membership ......................................................................................................... 35TABLE OF TABLES Table 1. ......................................................................... 1Land Declared by Farmers by Region and TypeTable 2. ............................................................ 3Utilised Agricultural Area (UAA) by District and Type.Table 3.Total number of the different animal types bred by district and region. ..................................... 4Table 4. ................................. 5Share of most important products or products group in agricultural trade.TABLE OF FIGURES Figure 1.Share of Trade Partners. .............................................................................................................. 5Figure 2. ............................................................ 7Fertilizer Consumption per Hectare of Cropland, Malta.
AEM APA CAP CEFTA CoGAP Coll. CWD DG AGRI E EAGGF EC EEC EIA EK ERDF EU FIFG GAO GAP GDP GFP IACS IFOAM IPPC ISPA kg LFA LU MEPA MRAE MSA NATURA2000 NDP NGO NSO NUTS PA PG PGRLF PHARE RDD RDP RO SAPARD SF SMPPMA IBMA SWOT UAA WFMP
Evaluation of agri-environmental measures - Malta
GLOSSARY Agri-environmental measure Agricultural Paying Agency Common Agricultural Policy Central European Free Trade Agreement Code of Good Agricultural Practice Collection of Laws of the Malta Commission Working Document The European Commissions Agriculture Directorate-General Areas with environmental restrictions European Agricultural Guidance and Guarantee Fund European Community European Economic Community Environmental Impact Assessment European Commission European Regional Development Fund European Union Financial Instrument for Fisheries Guidance Gross Agricultural Output Good Agricultural Practise Gross Domestic Product Good Farming Practise Integrated Administration and Control System International Federation of Organic Agriculture Movements Integrated Prevention and Pollution Control Instrument for Structural Policies for Pre-Accession Kilogram less-favoured area Livestock unit Malta Environment & Planning Authority Ministry for Rural Affairs and the Environment Malta Standards Authority a coherent European network of protected areas National Development Plan Non Government Organisation National Statistics Office Nomenclature des unités territoriales statistique Paying Agency Producer Group Agricultural and forestry support fund Poland and Hungary Assistance for Restructuring of Economy Rural Development Department The Rural Development Plan regional office Special Accession Programme for Agriculture and Rural Development Structural Funds Special Market Policy Programme on Maltese Agriculture Intermediate body under Managing Authority Analysis of strengths, weaknesses, opportunities and threats Utilised agricultural area Whole Farm Management Plan
Evaluation of agri-environmental measures - Malta
1. STATE OF THE AGRICULTURE AND AGRICULTURAL ENVIRONMENT IN THE COUNTRY
1.1 description of the agriculture in the countryBrief The Maltese Islands are a group of small, low islands aligned in a NW-SE direction and located in the central Mediterranean near Sicily. They are located on a shallow shelf, the Malta-Ragusa Rise, part of the submarine ridge that extends from the Ragusa peninsula of Sicily southwards to the African coasts of Tripoli and Libya. The Maltese Islands are the southernmost point of the Apennines that starts in the Pyrenees. Geophysically, the Maltese Islands and the Ragusa peninsula of Sicily are generally regarded as forming part of the African continental plate. The Maltese Archipelago consists of three inhabited islands: Malta, Gozo, and Comino and a number of small uninhabited islets: Cominotto, Filfla, St. Pauls Islands, Fungus Rock and a few other minor rocks. The land area of the various islands is: - Malta: 245.7 km 2 - Gozo: 67.1 km 2 - Comino: 2.8 km 2 The Agricultural land in Malta or the total land declared by farmers, is classified into three categories as follows: - land (Raba'baghli) that is land that depends exclusively on rainwater for irrigationDry-farmed of crops, but may be watered on a few occasions. - Irrigated land (Raba saqwi) that is land that has a continuous supply of water all year round and is irrigated by water from sources other than rainwater. - Unutilised/garigue land (Raba Moxa), which is a term, used to describe all non-productive registered agricultural land. Table 1. Land Declared by Farmers by Region and Type
Source: Census of Agriculture 2001, NSO The sum of the first two categories represents the total agricultural land area that is further subdivided into uncultivated land and utilised agricultural area (UAA) that includes arable land, vineyards and orchards. In 2001, the total agricultural land area declared by farmers in the Maltese islands was established at 11,619.9 ha of which 1,471 ha or 12.7% were classified as garigue and the remaining 87.3% or 10,148 ha as agricultural land. An average of 4.8% of the agricultural area is unutilised or abandoned. While the island of Malta has 255.8 ha, Gozo has 236.3 ha of unutilised land area, representing 3.1% and 12.1% of the total agricultural land area, respectively. From the agricultural census of 1983 a decrease of 1,342 ha or 11.7% in agricultural land has been recorded from 11,491.0 ha declared in 1983 against a total of 10,148.6 ha recorded in the last
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Evaluation of agri-environmental measures - Malta
Census of 2001. This decline continues to accentuate the trend of loss of agricultural land established over the past years as can be seen in Table 8. There was a significant shift in the type of agricultural land from dry land to irrigated land. A 260% increase from 580 ha to 1,508.8 ha was recorded in the irrigated classification, which means a shift of 928.8 ha of dry land to irrigated land in these last 18 years. A total of 960 ha, representing 63.4% of the irrigated land is found in the Western and Northern districts with predominance in the locality of St. Pauls Bay area, which accounts for 13.9% of the total for the Maltese Islands. 1.1.1 Main categories of production (quantity, value) There are three major types of agriculture activity on the Maltese islands, mainly associated with: Irrigated land where the intensive cultivation of fruits and vegetables such as new potatoes, salad crops, tomatoes, artichokes etc., fruit and vines occurs. This type of farming has grown with the development of tourism to meet the demand for fresh high value food. Dry farming practices on land that depends exclusively on rainfall. Traditionally these areas were farmed using a 4-year rotation. Year 1 potatoes or onions, Year 2 cereals, wheat or barley. Year 3 legumes such as Sulla (Hedysarum coronarium) as a fodder crop. Year 4 potatoes or onions. Livestock farming based mainly on the intensive production of swine, rabbit, poultry and egg production for which Malta is self sufficient, and cattle mainly for dairy production and beef products whose supply remains insufficient to meet local demand. The total utilised agricultural area or UAA was recorded at 9,656,5 ha broken down into 7,471.0 ha arable land, 490.1 ha land under vines, 427.1 ha land under orchards and 1,268.5 ha fallow land as per Table 12. The percentage of fallow land was somewhat high reaching 13.1% of the total utilised agricultural area. The highest percentage of fallow land (19.8%) was recorded in the Western district with the localities of Dingli, Siggiewi and Rabat having the highest proportions of fallow land at 34.1%, 21.1% and 18.1% respectively. Crops grown locally include vegetables (e.g. artichokes, beans, beetroot, broccoli, carrots, cauliflowers, cabbages, cucumbers, garlic, lettuce, potatoes, spinach, endive, pumpkins, tomatoes, salad vegetables, marrows, onions and mushrooms, etc.) fruit (e.g. apples, apricots, grapes, nectarines, plums, peaches, strawberries, melons, oranges, figs, prunes, pomegranates, etc) flowers (especially carnations, chrysanthemums and roses), vines and fodder. The annual production of vegetables and fruit in Malta amounts to 72,000 tons and 6,000 tons respectively, equivalent to 65% of the annual needs in value terms. Of the total physical land area worked by the farmer of 8,388.2 ha, 84.7% or 7,471.0 ha is dedicated to arable land of which nearly 60% is cultivated with fodder. The remainder is under vineyards  490.1 ha or 5.6% of the total area worked and under orchards  427.1 ha or 4.8% of the total land worked. Just over half of the total arable land area is found in the Western and Northern districts where these account for 51.3% of the total arable land in the Maltese Islands. The island of Gozo accounts for 20.1% of the total arable land.
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Evaluation of agri-environmental measures - Malta
Table 2. Utilised Agricultural Area (UAA) by District and Type.
Source: Census of Agriculture 2001, NSO Both land under vineyards and land under orchards are predominantly found in the Western and Northern districts with 82.9% of all vineyards and 72.5% of all orchards, found in this locality. Another predominant feature is that most of the land dedicated to orchards and vineyards is below 0.5 ha in area. In the case of orchards 69% of the land area is below 0.5 ha whilst for vineyards this value reaches 66%. In contrast land areas over 2 ha account for only 3% of the total land dedicated to orchards but to 11% of that under vineyard. See Figures 10 and 12. As regards vineyards, out of a total 481.7 ha of productive vineyards (not including new plantations), 129.2 ha or 26.8% are quality wine varieties, 209.5 ha or 43.5% non-quality vines and 142.9 ha or 29.7% are vineyards producing table grapes. The majority of the vineyards are found in the Western and Northern districts where an area of 84.1 ha of productive vines are found, accounting for 79.7% of the total productive vineyards on the Maltese islands. New plantations in these districts which account for another 22.0 ha bring this sum up to 406.1 ha or 82% of the total vineyards. The total land area classified as orchards during the 2001 census was of 446.1 ha of which 19.0 ha are composed of land planted with prickly pears and carob trees. In total 10,274 holdings grew this commodity. As per Figure 14 peaches and other stone fruits are the predominant fruits covering 35% and 15% respectively of the total land dedicated to orchards, and grown in 4,310 holdings, followed by other fruit orchards with 32% of the land, cultivated in 4,082 holdings. The majority of land and number of holdings growing stone fruits including peaches are found in the Northern and Western districts which together comprise 84% of the total stone fruit land area and 60% of these stone fruits holdings. The next most widespread orchard land are those under oranges, lemons and other citrus with 10%, 6% and 2% respectively, i.e. 18% of the total orchard land is under citrus cultivation, distributed amongst 1882 holdings . In the district of Gozo and Comino the most predominant fruits are citrus with 24.3% of oranges, 15.9% of lemons and 7.0% of other citruses, i.e. a total of 47.1% of the total orchard land in Gozo against the 13% of the total orchard land in Malta. Peaches on the other hand are only cultivated in 13.3% of the orchard land in this district as against 38.3% of the orchard land in Malta. As regards to the total number of holdings where citrus fruits are cultivated,
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Evaluation of agri-environmental measures - Malta
47% of these are located in the Northern and Western districts and 27% in Gozo. However as far as land area under citrus cultivation the district of Gozo and Comino is the one with the most land at 34.7 ha under citrus or 41.5% of the total citrus land cultivated in the Maltese islands. It is important to note that the locations of the holding or farm given indicate the place of residence of the breeder rather than the actual location of the farms (hence the inflated figures for the Inner Harbour region, which is not an agricultural area). From an environmental viewpoint, this constitutes a serious deficiency in the data, as impacts (which are generally substantial) are mainly tied to the siting of the farm. According to the census of cattle farms carried out by NSO in 2000, there are 260 dairy and beef cattle units in Malta and Gozo. Most of the farms (about 55%) are not specialised and are engaged in both milk and beef production. The cattle herd was established at 20,326 heads. The breeding stock totalled 11,989 heads of which 9,306 were milking cows. There are 174 pig farms in the Maltese Islands of which 138 are production units, 18 are fatteners, 16 farms are engaged in both activities, and another two farms are involved in other activities. The pig stock amounted to 80,074 heads. In Malta there are approximately 1,100 breeders of sheep and goats with a total herd of 7,492 sheep and 3,328 goats (A. Atanasio, Department of Veterinary Services, personal communication). Most of these are small farms concentrated in rural areas and operated as a small cottage industry. The number of poultry animals is estimated at 5,500,000, the number of rabbits at 2,400,000 and the number of horses at approximately 600 (Jackson, 2001). Table 3. of the different animal types bred by district and region.Total number
Source: Census of Agriculture 2001, NSO Maltas total trade increased by 43.1 % in terms of exports and 38.6 % in terms of imports from 1999 to 2000. Due to the higher general level of imports, the overall trade deficit also increased (by 28.1 %) in this period, and reached a level of about  1 billion in 2000. However, most of the trade could be attributed to transfer trade, showing that Malta is an important trade hub in the Mediterranean area. Malta has strong trade relations with the European Union. Over the years 1999 and 2000, 40 % of all of Maltas exports went to EU destinations, and 62 % of its imports came from there. In bi-lateral trade the United States of America is an important trade partner, amounting for 25 % of Maltas exports and 10 % of its imports.
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Evaluation of agri-environmental measures - Malta
Figure 1. Share of Trade Partners.
Source: Census of Agriculture 2001, NSO The most important products (with a share of more than 5 % of imports or exports) are shown in Table 9 (for the years 1999 and 2000). On the export side Miscellaneous Preparations (45.3 %), Tobacco (24 % to 28 %) and Beverages (10 % - 12 %) are of most importance, while imports are led by Dairy produce (almost 10 %), followed by Preparations of cereals (over 9 %) and Beverages (8 %). Table 4. Share of most important products or products group in agricultural trade.
The Ministry for Rural Affairs and the Environment (MRAE) has as its Mission Statement: In a small island, where the impact of development on land is strongly felt, where rural areas enhance the characteristic beauty of the Maltese environment, where the sea and its produce are an intrinsic part of life, the integrated coordination of agricultural and fisheries production., rural and environmental management calls for the relevant policy designs and their implementation. The Ministry is headed by a Permanent Secretary, and encompasses a central administrative structure and three Directorate - General (DGs): Permanent Secretarys Office and Central Departments: - 1 Permanent Secretarys Office. - 2 Corporate Services Department. - 3 Policy Development Department. - 4 EU Affairs Department. - 5 Programme Implementation Department.
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Evaluation of agri-environmental measures - Malta
- 6 Information Management Office. - 7 Paying Agency. - 8 PARK (Parks, Afforestation and Countryside Restoration) (A) Directorate General for Agricultural Services and Rural Development Mission Statement: To assist and promote the economic development of agriculture, horticulture and live-stock, ensuring the provision of safe and wholesale produce, safeguarding the welfare of animals, and ensuring the conservation of the environment. - 1 Agriculture Department - 2 Plant Health Department - 3 Rural Development Department - 4 IACS Department (B) Directorate General for Food and Veterinary Regulation: Mission Statement: To safeguard veterinary public health and to contribute to the economically viable development of the livestock industry through the improvement of the legislative environment and through the employment of veterinary knowledge and resources in a cost-effective and socially conscious manner. - 1 Office of International and Legal Coordination. - 2 Food Health and Diagnostics Department. - 3 Animal Health and Welfare Department. (C) Directorate General for Fisheries Conservation and Control. Mission Statement: To sustain the fisheries industry, to conserve and manage the Islands marine resources, to put in place the necessary enforcement measures, and to monitor the development of aquaculture. - 1 Malta Centre for Fisheries Sciences. - 2 Market/Structures and External Relations. - 3 Fisheries Protection Group. MRAE interfaces with other bodies for various functions. Whereas the Plant Health Department administers the registration services for plant protection and seed, MRAE works with the Malta Standard Authority for the recognition of Agricultural products and foodstuffs designation. 1.2 Brief description of the environment in agriculture The major issues associated with the environmental impacts of agricultural activity are related to competition for land resources, displacement of natural biotic communities, and the release of chemical pollutants into the environment. The quantity of inorganic nitrogen fertiliser fluctuates from year to year. The maximum consumption of nitrogen on an annual basis was reached in 1998, when an average of 147 kg N/ha were used. Since the data refers to import statistics rather than actual consumption, the indication is that stocks are replenished regularly through imports. The import statistics do not include the land application of nitrogen through organic manures. In terms of phosphorus fertilisers, the importation is relatively stable at about a mean of 13kgP/ha/year.
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Evaluation of agri-environmental measures - Malta
Figure 2. Fertilizer Consumption per Hectare of Cropland, Malta.
Source: Census of Agriculture 2001, NSO The consumption of pesticides has also remained relatively constant in the past three years, however, when compared to 1998, the importation seems to have dropped by more than 50 %. The most important environmental implication of livestock farming is the generation of animal waste, and its disposal in such a manner as to prevent contamination of the freshwater aquifers, drinking water supplies, bathing water, air and soil. If managed properly, animal waste can become an important nutrient resource with economic value. Analysis of the density of animal farms in Malta (Jackson, 2001) suggests that the largest concentration of cattle and swine production units are located within the water catchment areas overlying aquifers with the highest nitrate levels. The temporary storage of manure on bare soils and leaking cesspits on the farms are thought to be the major point sources of nitrogen pollution (Mangion, 2001). A study on the quality of irrigation water in Malta (Farrugia, 2000) has also demonstrated that higher nitrate levels in the perched and mean sea level aquifers are associated with irrigation sources from sites in the vicinity of a noticeable source of pollution. On a national basis, the livestock density for the Maltese Islands can be estimated by taking into account the total agricultural land under forage cultivation. According to these estimates, the livestock density is 4.85 LU/ha. Further to the 2001 Census the majority of irrigated agricultural land, 1220.5 ha out of a total 1508.8 ha are served by drip irrigation. An area of 781.9 ha of drip irrigation is found in the western and northern districts. Cloches are most abundant in the locality of Mgarr, where 1.7 ha of crop are grown under cloches. The northern district where Mgarr is found has a total of 67.4 ha of cloches, representing 65.6 per cent on the island of Malta. As regards, reservoirs and wells, a total of 9,069 were captured during the last Census and more than half were constructed before the 1975. Windmills, which were predominant earlier in the century, still grace the landscape and 301 of them are still being used, mostly found in the western district. The rate of groundwater abstraction exceeds the maximum potential extraction rate for sustainable production, and is the main cause of groundwater depletion and seawater intrusion. Many of the high level springs used to low all year round, albeit with a much reduced flow in the dry period, however, most have now been tapped by farmers for irrigation. Accurate statistics on the exploitation of the aquifers (perched and mean sea level) by the agricultural sector are not available. This is mainly due to the fact that private groundwater abstraction (both for agriculture and industrial purposes) is not metered. As of July 2001, there were a total of 5,113 private groundwater sources registered with the Water Services Corporation in accordance with Legal Notices 120 of 1997 and 182 of 1999. It has been estimated (Mangion, 2001) that the utilisation of groundwater for irrigation purposes in Malta and Gozo amounts to 12.5 mm 3 per year (37,000 m 3 per day), or approximately 40% of the total productive capacity of the aquifers. In addition to groundwater resources, irrigated agriculture 7
Evaluation of agri-environmental measures - Malta
also makes use of harvested rainwater. Estimates for the billed potable water supplied through the public distribution system to a total of 1,822 premises classified as farms for the period 1999/2000 amounted to approximately 6 % of the total billed potable water consumption for this period, as shown in Table 4.8.14 (A. Riolo, Water Services Corporation, letter dated 30 th November, 2001). In Malta, there are several areas where localised salinity problems have been experienced as a result of irrigating previous dry land with poor quality irrigation water. Such cases were documented as early as 1960 (Bowen-Joneset al., 1961) in the South-east region, Bur ta Sufa, and are increasingly common nowadays. In the past decades, several fields in the coastal zone of Armier, which are exposed to the prevailing north-westerly winds, have been abandoned as a result of the combined effects of soil erosion and soil salinity. The use of treated sewage effluent for irrigation has been identified as a source of salinity in the southeast region (Muscat, 1997). Chemical testing of the soils in the irrigated area has shown that the electrical conductivity of the saturated extract increased by 278 % of its original value within one year by the end of the irrigation season. The accumulation of salts is prevented by irrigating in excess of crop requirements and maintaining a high leaching ratio. Compared to non-irrigated soils, the boron concentration of the soils in the southeast region was also found to be up to three times higher (Camilleri, 2000). In a study (Vella & Camilleri,in press.) on the extent of salt-affected soils in three selected sites  a dryland area, an intensively cultivated irrigated valley and the south-astern irrigated area, it was reported that the highest percentage of saline fields (35%) were diagnosed in the latter. Substantial data on the fertility status of Maltese soils is insufficient. A small number of unpublished dissertation studies have been conducted (e.g., Sacco, 1997; Vella 1997; Sciberras 1999). In particular, a study undertaken by Mr J. Callus (EPD), contains data on pH, conductivity, N and phosphorus (P) content of agricultural soils between October 1999 and March 2000, but to date no comprehensive survey has been conducted to assess the fertility status of soils on a national basis. There is also a complete lack of experimentation and related data to enable the quantification and dynamics of nutrient uptake by the most important crops and their response to fertilisation. The levels of extractable nutrients in the soils as determined by soil analysis have not been calibrated against crop response until today. The quality of the rural environment, its habitats, wildlife, landscape and historic features, is a source of economic advantage to rural areas and is valued by the general public and verseas visitors. But that quality has declined and parts of the rural environment remain under threat from two main sources. First, agriculture has had a major influence. The impact of agricultural intensification has been significant, with increased water extraction, greater pesticide use, declining maintenance of the rubble walls, damage to landscape features and archaeological sites and loss of habitats. Many habitats are very fragile and can only be safeguarded by the continuation of farm management practices that can be increasingly uneconomic (for example, the very labour intensive task of maintaining rubble walls). And the demands on resources, such as water, in some areas will require increasingly effective anagement if both environmental value and sustainable agricultural productivity are to be maintained. The Maltese Islands have limited natural supplies of water and this is a significant restriction on the productivity of the Maltese agriculture sector. The efficient and effective management of those water resources that are available to farmers is therefore essential for the continued survival and development of Maltese agriculture. Since rainfall is insufficient and unpredictable, the irrigation of cropped land is increasing and currently estimated at 1,143 hectares (10.7% of agricultural area) (National Statistics Office, 2001). The incentive for using irrigation is considerable - the value of production from land with access to an unlimited supply of water is on average at least 3.5 times that from dry land farming. In the case of potato cultivation the net economic return from productive irrigated land may be up to 20 times higher than that from the same area under dry land forage wheat production.
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