Malta faces urgent agricultural challenges: food import dependency exceeds 70%; an aged or retiring farmer population; and insignificant student interest in agriculture. Whilst attempting to address these challenges with open discussion is commendable, we don't need an academic document, we need targets, timeframes and action plans which also result in tangible improvements for the farmer.

The "vision" lacks practical aims and tangible details, neglecting its own "First & Second Pillars": Securing Local Production Viability and Future-Proofing Food Supply. Considering America's new direction to ensure health in two years, Malta's public response deadline of 29 November seems premature. Key issues with the draft strategy document include:

Attracting new farmers: Strategies to engage new entrants, improve the farmer's income and provide education about creation of resilient ecosystems are missing. The focus on technology to reduce labour also discourages participation.

Addressing inefficient utilisation of land: 60% of agricultural land is used to grow second grade fodder. Efficient crop management can produce high grade fodder to considerably reduce the current 100% imported, high grade feed.

Food waste and resources under-utilisation: Despite identifying the issue (food waste increased 15% in the past decade), no material solutions are offered, such as repurposing waste products (example: drying waste from cheese production to produce whey powder to supplement feed). True resilience is investment in waste streams.

Pitkalija's role: Is building a new pitkalija the best use of €100m? Funds should be focused on improving facilities (adequate cold storage & freezing capacity), and standardised grading systems. Reforming the current trader-centric reward system and excessive digital platform fees which disadvantage farmers /producers and floor pricing to reflect equitable value distribution is a better use of funds.

Organic farming targets: The goal of 5% organic agricultural land by 2030 (currently 0.2%) risks undermining standards. The De Minimis State Aid could lead to "organic" dilution, incentivising producers to prioritise aid over genuine practices.

Generational renewal: The strategy lacks meaningful solutions for generational renewal. "Let's Talk Farming" is a hugely important tool and should be extended to include regenerative growing, biodiversity and ecological literacy.

Lack of flagship projects: No innovative or transformative initiatives are proposed, reflecting a lack of imagination.

Excessive bureaucracy: Overshadowing substantive progress. According to the Strategy, agriculture is 1.4% of Malta's economic output contributing to its neglect.

Genuine, tangible answers are needed in response to the comments and questions at the public consultation held on 6 November. Adding to them, the need for the strategy to:

Establish targets and incentives

• Set a percentage target for reducing current 70% food import dependency by increasing local production to 50% of food consumed.
• Again, is building a new Pitkali the best use of €100m? Improving facilities including adequate cold storage (yesterday not tomorrow) and building freezing capacity. Freezing is a proven system widely adopted in Europe; currently achieved in the private sector by sending produce abroad. This could be the flagship project and a better use of the manifesto promise.
• Incentivise sustainable food production (with regenerative practices ideally) and minimise waste by adopting systems successful in other countries.
• Incentivise small scale, family run aquaculture farms (successful in Italy).
• Rapidly establish national strategic food reserves; ideally with local produce.

Support for farmers:

• Provide technical expertise in the field, replacing vendor-based advice.
• 'Shadow' the Italian agronomist for local agronomy birth and development.
• Simplify bureaucracy: level the playing field; align policy with EU practices.
• Provide reliable access to good quality water prioritising food production including taking action on the Crop Plan based Water Strategy.

Educate and engage community:

• Free nationwide local council courses for all ages on i. home, rooftop, and indoor natural growing (e.g., microgreens, sprouts), ii. homemade wholefood preparation using wider varieties of local, seasonal produce, native edibles & secondary cuts and less popular fish species; and iii. 'Food as medicine'.
• Educate recreational farmers including hunters (now owning 1000s of tumoli of land) on agricultural, ecological literacy and regenerative practices.
• Provide healthy eating in hospitals, schools etc and educate the community replicating the successful 'Let's Talk Farming' to enhance community engagement with 'Let's Talk Health' & 'Let's talk Local Community'.

Promote local produce

• Ensure menus proudly display local food provenance, restore pride in Maltese produce and run attractive public awareness campaigns. Restore the herb & vegetable garden and a focus on using local food at ITS.
• Incentivise fresh seasonal juicing in public events and eateries/restaurants to save waste of local produce and promote it.
• Improve affordability, sustainability, and packaging of Maltese food products.
• Provide affordable organic produce for all.
• Address pesticide restriction differences between local and imported goods.
• Empower local councils to create food gardens in abandoned fields
• Ensure planners/designers of public gardens/urban spaces and local councils create predominantly edible and native pollinator friendly projects.

Attend to infrastructure and markets

• Ensure adequate parking for the new farmers' market (€10 million project)
• Upgrade not build a new Pitkalija as detailed above.
• Strengthen business ethics and transparency through education in local food sectors and the relevant government departments.
• Research and promote edible exotic fish species being seen in local waters.
• Provide a fund stream for Agenziija Rizorsi Agrikoli. Maybe PA fines?

Prioritise environmental concerns

• Actively mitigate climate challenges such as biodiversity loss, lack of shelter trees, soil degradation, erosion & loss by impermeable surfaces, poor water management & wastage through nationwide education and awareness programmes/campaigns, research for adapting proven techniques for the Maltese and Gozitan context supported by regulations, incentives and subsidies.

www.pffa-malta.org