Submissions by AD Gozo Regional Committee
The Director of Environment Protection,
Malta Environment & Planning Authority,
St. Francis Ravelin, Floriana CMR 01
PA/03798/02 Construction of a destination port comprising hotel, yacht marina and tourist village Qala.
Comments on Project Description Statement and Requests for information to be included as part of the Terms of Reference for the Environment Impact Statement.
Alternattiva Demokratika (AD) Gozo Regional Committee.
Friday 11th August 2006
The comments below were prepared prior to the announcement of the enactment into law of the Gozo Local Plan and are submitted in detailed critique of the proposal for good measure. However, in view of the changed legal scenario it is submitted that the proposal runs directly counter to Policy GZ-Qala-2 of the Gozo Local Plan with specific reference to the site on a number of counts and cannot be legally considered further by MEPA. The submissions below are made without prejudice to above which necessitates the immediate withdrawal or dismissal of the application.
GZ-Qala-2: The area of land shown on MAPS 14.8-E shall be a safeguarded area for a geological and industrial heritage park. The exact boundaries of the park shall be established following more detailed study of the area but it is expected that the park boundaries would be accommodated within the general area indicated.
The park shall focus on the geological and geomorphological heritage of the area as well as the rich traces of a long heritage of quarrying activity (utilizing different and evolving techniques) in the area. The latter may also provide for a link to the existing active quarries. The park shall provide interpretation of this extensive heritage as well as pedestrian routes between Dahlet Qorrot and Hondoq ir-Rummien.
Afforestation and habitat creation along the terraced abandoned agricultural land will be encouraged. Extension of the active quarries into this area shall be prohibited.
Alternattiva Demokratika (AD) remains committed to supporting, maintaining and developing a healthy economy for Gozo and its people. AD cares for Gozo and any major development proposal such as the Qala Creek Project however attractively presented must be carefully scrutinised at all stages before a final decision is taken.
The proposal requires a comprehensive and transparent evaluation of its impact on the social, economic and physical environments. The quality of life for Gozitans must not suffer because of such developments. In spite of promises of sustained employment of Gozitans the development must not be driven solely by political, financial and short term profit considerations.
The proposed development will fundamentally change the nature of the coastline and the immediate environment forever. It is therefore essential that the consultation and environmental impact studies are conducted in an open and fair fashion. If this crucial activity is structured in a narrow and selective way the consequences could be disastrous in the short, medium and long term.
Key questions need to be addressed and answered now in order to produce evidence in an open and unprejudiced investigation.
Questions for the EIS
1. What are the competences of the developers and/or architects to carry out such a project?
2. Which lessons learnt through other similar projects (such as the Portomaso project) will be applied in the Qala Creek Project and which indicators will be used for comparison?
3. Referring to section titled 'Why Qala Creek Marina?' on page 27, it is stated that a map based sieve analysis was carried out to identify the most suitable site. On which Terms of Reference and scientific criteria was this analysis based on? For such an extensive project, in order to ensure that all social, economic and environmental aspects are given their due consideration, an appropriate site selection exercise comprising the above should be carried out prior to considering carrying out an EIA at the Qala Creek site. Are their any plans to carry out a site selection exercise based on scientific criteria drafted by the appropriate competent body?
4. The existing foreshore at Hondoq Ir-Rummien is a national public resource with full right of public access as delineated by the existing coastline and MEPA maps. Who will own and/or have access to the total of the newly defined foreshore created by the excavation of the quarry and the new coastline created by the marina? As clearly indicated in the Project Description Statement the whole foreshore, (Figure 14.4, page 107) currently accessible to the general public will be taken up by the Marina entrance (Figure 8.1, page 37).
5. What environmental impact precautions and mitigation measures will be taken and maintained by the developers throughout the whole extent of the project including the quarry excavation and site clearing phase, the construction phase (i.e. new infrastructure and facilities construction and modification of the existing infrastructure) as well as the operational phase of the project, to prevent negative impact of:
* Noise pollution, air pollution, water course and sea pollution
* Heavy vehicle excavation and construction traffic
* Spillages of spoil, rock etc on roads, public and private property and surrounding natural areas such as the garigue habitat adjacent to the site.
* Restrictions of public access
* Damage to road surfaces
* Vibration damage to private and public properties and civic amenities
* Undermining of foundations and structure of roads and buildings
+.and will the laws/policies prohibiting excavation and building work in the summer months be complied with?
Information pertaining to how above mentioned precautions and mitigation measures will be monitored and enforced ensuring also that the civic and legal rights of the people of Qala are respected, should also be included in the EIS.
6. The Project's stated aspirations are: "The enhancement of the Maltese island's (sic) objective to act as an international hub for yachting and marine activities in the Mediterranean Sea; The development of the location as a destination port where yachts and boats can anchor in order to enjoy day/short-stay trips. The opportunity to seek after and cater for new markets, particularly those segments relating to yachting and maritime activity enthusiasts and higher spend tourists;" (Project Description Statement, Page 3).
Considering the island of Gozo's small size and the coastal, environmental and recreational resource needs of the indigenous Gozitan population and the currently tourist population visiting Gozo (see Malta NSO report v Departing Tourists, June 2006) how can the additional pressures on environmental resources at 'Qala Creek' and compatibility issues be addressed appropriately and fairly?
7. What is the evidence that the "alternative cutting-edge technology which eliminates the need for a break-water" (page 4 of Project Description Statement) is sufficiently tested and proven to effectively and safely enable access and egress to and from the marina, given the sea and wind conditions to which the Comino Channel in the vicinity is subject?
8. The implementation of the project plans will change the coastline and hydrodynamics in the proposed 'Creek' area. Have any Benthic surveys been carried out for the Qala Creek site? What risk assessment and analysis has been undertaken to identify the range of negative/positive impacts on the already prized marine flora and fauna of the coast and Channel and what were the results? Such studies should also be included in the Site Selection Exercise referred to above under point 3 above, and should also be considered in the EIS for this project.
9. The plans show the physical scale and dimensions of the proposed quarry excavations as extensive. What consideration has been given and risk assessment and analysis conducted to model and/or assess the lasting effects on the neighbouring coastlines, Comino Channel, Mgarr Harbour operations and fisheries? What were the results?
10. The time scales of the Project are stated as: quarry excavation 15-18 months; rest of project 4 years; finish date 2010. What practical and published guarantees are to be given by the developers to the people of Qala that the physical, family and social environment of the village of Qala and its immediate surroundings will not be disrupted or damaged at any stage in this long period of development of the project?
11. How many residents and business are to be affected by the wide range of heavy construction and disposal traffic which will be an inevitable consequence of the totality of the project activities? A survey to conduct, assess and evaluate this impact is imperative.
12. With respect to the excavated waste which as stated in the Project Description Statement will be deposited in Gozo quarries, information should be submitted stating clearly which quarries are actually being referred to and whether any studies have been carried out to determine these quarries have sufficient void space to cater for existing C&D waste being currently generated, apart from the Qala Creek Project?
13. What measures are to be taken that the excavated resource will be used rather than being disposed of and what measures are to be taken to ensure that any material currently dumped in the quarry which will be eventually disposed of or re-used, is not contaminated with hazardous material since only inert waste is to be disposed of in inert waste landfills.
14. What are the developers planning for comprehensive water and energy conservation strategies for the operation of the completed facilities at 'Qala Creek' ?
15. A detailed breakdown of the job opportunities created by this project is required in the short, medium and long term.
16. With reference to the current context, whereby the major Hotels in Gozo, such as the Mgarr Hotel, the Andar Hotel, the Atlantis Hotel, and others, have ceased to operate as hotels since this was being considered as not sustainable, resulting in the loss of job opportunities, have any audit and feasibility studies been carried out to justify the need for another hotel in Gozo.
17. Considering also the original plan of the Chambray Project with its huge negative visual impact, whereby the developers had originally proposed a hotel promising job opportunities for Gozitans as a justification for the project, which eventually failed to materialise. What guarantee can be given that the Qala Creek proposals will not follow in the footsteps of the Chambray Project.?
18. The proposal states on page 5 of the Project description statement that the Qala Creek Project will '+ provide new and different work opportunities to the indigenous population'. Against the background of an increasing number of foreigners being employed in the hospitality industry in Gozo at low wages, what guarantee can Gozo Prestige Holidays Ltd. give that they will employ the 'indigenous population' at regulated wages according to law and work conditions which abide by existing Health and Safety Regulations.
The above comments from point 1 to 18 were prepared by Sunday 6th August prior to the announcement (last Tuesday 8th August) of the enactment into law of the Gozo and Comino Local Plan. These submissions and comments are therefore made without prejudice to this latest development