Submissions by AD Gozo Regional Committee

Following are the submissions by AD Gozo Regional Committee to MEPA regarding the Qala Creek, sent in to MEPA today

The Director of Environment Protection,
Malta Environment & Planning Authority,
St. Francis Ravelin, Floriana CMR 01

Ref:
PA/03798/02 Construction of a destination port comprising hotel, yacht marina and tourist village Qala.

Subject:
Comments on Project Description Statement and Requests for information to be included as part of the Terms of Reference for the Environment Impact Statement.

From:
Alternattiva Demokratika (AD) Gozo Regional Committee.

Friday 11th August 2006

Preface

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.

Introduction

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

Submissions by Nature Trust Malta (with contribution from the Light Pollution Awareness Group)

Nature Trust Malta
(with contribution from the Light Pollution Awareness Group)
Comments on the:

PA 3798/02: Project Description Statement for the Proposed Qala Creek Project Gozo
(January 2006 Environment Management Design Planning Ltd. Obo Gozo Prestige Holidays Ltd.; Architects: Edward Bencini & Associates)

A. Main concerns

Nature Trust once again reiterates its position against this proposed development as it is completely Outside Scheme and is not justifiable. The authorities have just approved the loss of more undeveloped areas by including them in development schemes. This means that such a massive residential development ODZ now, more than ever, has simply no justification at all and should not even be considered.

2. The Government through its National Commission for Sustainable Development says it is committed to sustainable development, i.e. "that development which meet the needs of the present generation without compromising the ability of future generations to meet their own needs." This project does not pass the sustainability test and should therefore be rejected out of hand.

IT IS NOT SUSTAINABLE NOR JUSTIFIABLE to construct another 5star hotel when several hotels seem to be facing low occupancy rates.

The PDS states that works on site will start this same year “We are assuming a start to excavation works during 2006”. When will the EIA and its consultation be carried out to be able to fit within this timeframe?

There is mention of the public’s wishes and submissions – these should be fully included in the EIA. An important and obvious omission about this is that there is no mention of the referendum amongst Qala residents which decided against the proposed project (some 85% voted against).

The Local plan seems to have abruptly changed its policy on the site as it has now inexplicably changed from a site recommended for afforestation to one which states its use for tourism and marine purposes.

The reasoning behind the whole concept of allowing development to offset costs of rehabilitation is not clear. This seems to be a form of preferential treatment as in other quarrying cases it is the duty of the developer to rehabilitate the site and no compensation is given as the developer would already have gained from the extraction of the resource. Setting such a precedent is dangerous. If the quarry has to be exploited further then the only project which can take place here is as per the developer’s commitment to restore the area after extraction. If the stone resource here is so precious then the revenue produced should be directed towards the proper rehabilitation of the area without the need for it to be turned into another building site.
The site will become too heavily congested with land and maritime transport and associated fumes and air/marine pollutants. This will inherently signify the loss of the true nature of the site and turn into just another resort area.

The large cave on the east side and the adjacent faultline and presence of clay all point towards possible site sensitivity which in turn can also signify site risks. Quoting from the PDS itself :
“Exposing this clay by excavating the coralline limestone could lead to structural instability of the clay and unless protected it will tend to slump down the excavation face. This formation is also protected by legislation and permission to make any intervention on it may not be easy to obtain.

The above mentioned cave should be protected as it is listed in the Habitats Directive and also because this area together with nearby Hondoq Creek near il-Barbaġann are possibly good sites for fish nurseries.

Many projects have always tried to gain support from the local population by promising many employment opportunities for the indigenous people – yet experience has shown that the reality seems to indicate otherwise.

We have heard about possible plans for a cruise liner terminal at Mgarr harbour. This will mean that more of the Southern coast will be taken up and thus no more development should spread into the Qala area.

B. Clarifications requested:
1. How will waste be dumped at ta’ Isopu Quarry when this is apparently already full?

2. The following figures do not show the Ta Isopu area but rather seem to lead to Qala area to another quarry at Għar id-Dar – “Figure 8.22 and 13.1 – Route leading construction traffic from Hondoq ir-Rummien to ta’Isopu near Nadur”

3. “…whilst not directly affecting any of the areas where existing recreational activities take place”. How has this conclusion been reached? One example: the project claims it will facilitate the use of the site for instance by divers – divers do not just use the swimming zone and the jetty – they actually snorkel or dive out away from bay – how will the safety of divers be ensured with such an increase of maritime traffic and noise?

4. Moreover many of the supposed benefits are meagre compared to the loss of tranquillity of the bay (which at present is seasonal and not permanent) and especially the very high probability of marine contamination in what is essentially one of the cleanest marine areas in Gozo? The few boats coming on site at present is nothing compared with the traffic which can be expected if this marina is to be so busy as to render high profits. Noise, fumes, oil, and other wastes are very difficult to control. In addition, another nearby bay is already affected by wave movements of increased boating activities – this can only increase with the movements in and out of the marina.

5. Site ownership – How has the foreshore been sold to private hands? And how will it be possible to access the coastal walk from Hondoq to Dahlet Qorrot if the marina will breach the land and separate the coastal area on the East from the limited public access site?

6. Remove such subjective, unfounded and unresearched comments such as “the substitution of a positive visual element in place of a negative one, is likely to result in generally beneficial effects.” Or “… with the perception that this was the work of nature itself; and that the building activity took place amorphously.”

7. “Enjoy the beach in a series of more secluded, intimate and private areas” - how should this be possible with a site which is predicting it will have up to 150 yachts and some 700 cars and people on site?

C. Studies needed for site:
Landscaping and the alteration of field terraces above the quarry should be monitored for any relevant cultural remains by a qualified archaeologist(s )

“This harbour mouth will serve as the location for the crushing plant, the batching plant and the aggregate and sand stockpile & storage area.” A detailed contingency plan would be needed to deal effectively with emergency situations in the case of heavy storms?

An appropriate Bank Guarantee must be secured for the development of the whole site in particular i.c.w the above harbour construction and operation.

Monitoring must be ongoing both during and after any development for at least a decade.
What mitigation for the dust, vibrations, noise and traffic during operation phases (60 trucks a day passing through very narrow roads)?

FULL multiseasonal Ecology study to be carried out over the full span of the seasons over one year and including faunal studies especially in areas of the quarry where temporary freshwater habitats seem to have been created.

Maritime traffic study and its impacts

Full marine study especially since the area supports protected species such as Posidonia oceanica (its meadows are protected at EU level as Priority Habitat) and Pinna nobilis.
Feasibility study to show sustainability of the whole project and its justification vis-à-vis the whole situation in Malta and Gozo

Cetacean survey is required as the channels are renowned for regular sightings. According to the ACCOBAMS agreement of which we are parties, it states that we “require impact assessments to be carried out in order to provide a basis for either allowing or prohibiting the continuation or the future development of activities that may effect cetaceans or their habitat in the Agreement area…”. Furthermore the same agreement states that “Parties shall endeavour to establish and manage specially protected areas for cetaceans corresponding to the areas which serve as habitats of cetaceans and/or which provide important food resources for them.”

Another obligation is under the EU Habitats Directive where the Tursiops truncatus is listed and this is one of the species that is normally sighted in the North and South Comino Channel.

Light Pollution – the site abuts a Dark Sky Heritage Area (as approved in the Gozo and Comino Local Plan) which is very sensitive as it is relatively free of the problem till now. The Applicant should be requested to do a qualitative and quantitative survey of the existing light pollution and night sky conditions in the affected area. A number of receptor locations should be chosen to the approval of MEPA from where such a survey will be carried out.

The Applicant should present details of all exterior lighting proposed (incl. amenity lighting in public areas). If the details of the exterior lighting scheme are not finalised by the time the EIA is completed then provisions should be in place, should a permit be granted, that one of the permit conditions will be proper vetting of the exterior lighting scheme in view of its light pollution potential.

Details of the proposed street lighting scheme along the proposed upgrading of the public thoroughfare from Qala shall be submitted together with the EIS. Such details are to include a plan showing the location of all the luminaires, as well as detailed specifications showing the luminaire type, wattage, lumen output, installed height above the ground and a polar diagram showing the distribution of the lighting from each different type of luminaire proposed. Preference to full cut off lighting systems should be given. Any floodlighting required shall consist of asymmetric fixtures mounted such that no light escapes above the horizontal. Solar powered full cut off streetlighting is also available nowadays. Non-cutoff solar powered streetlighting will not be approved, since the creation of light pollution from a renewable energy source is still a waste of energy. Special attention to the emission of light above the horizontal plane should be given in Dark-Sky Heritage Areas.

A programme of light pollution monitoring should be in place, should a permit be issued, such that it will be assured that the Applicant follows permit conditions and his claims in the EIA.

10th August 2006

Submissions by BICREF

BICREF’s considerations in connection to the
PA 3798/02 Project Description Statement (PDS)
for proposed Qala Creek Project in Gozo

The PDS already indicate some clear reasons why the area should not be developed, including:

1. Ecological importance for biodiversity conservation and protection of locally and regionally vulnerable species. As benthic surveys had already been undertaken in 1993, the PDS should have included full details rather than stating that it may still be valid in its broad detail.

2. The uniqueness of this bay is accentuated by the water quality status being described as “quite pristine and relatively free from most potential marine contaminants” it was also found to be “completely safe for bathers and free from pollution by sewage” thus making “Hondoq ir-Rummien one of the safest and cleanest for Gozo” and Malta. These points based on scientific observations should alone be strong enough to stop any considerations of developing this site as a marina that would completely change the water quality as noted in other marinas. Bathing areas are increasingly being affected by deteriorating water quality and thus protecting sites with such good sea water quality should be a priority for the Maltese Islands.

3. The geology of the area also seems to indicate problems for any marina development as indicated by the presence of various Lower Coralline Limestone members and Blue Clay formation which would all be impacted by such as development. Not to mention the natural water courses in the area and the character of this “small but picturesque sandy beach”.
Other Considerations for stopping such a development:

4. BICREF has undertaken Biodiversity SCUBA dives, boat surveys and aerial surveys in and close to the site and can highlight the presence of different marine species, including migratory species, which need full considerations for their local, regional and international protection status. Among these BICREF, through its assistance in a cetacean research project that has been running for the past ten years, can confirm that the Channels are used by cetaceans moving from one side to the other of the Maltese Islands and by resident Maltese bottlenose dolphins that make use of our territorial waters and coasts as their permanent home. Thus further disturbance and new sources of sewage, toxic and solid wastes, sound and light pollution in these narrow channels should not be allowed.

5. Malta has signed various Conventions and Agreements toward local and regional protection of habitats (including caves) and species (including migratory and vulnerable species utilizing the site seasonally). As such it is under the obligation of respecting such conservation measures and avoiding developments that may further reduce habitats quality and ecosystem health. On the contrary the Maltese Authorities should be working hard toward promoting the reduction of biodiversity loss by 2010 by allowing more sites for species to grow, feed, reproduce and reside permanently or temporarily during their movements.

6. While the area may benefit from rehabilitation and reintroduction of typical flora and fauna, so as to reduce the impacts of past neglect and exploitation of resources, it is not acceptable to take this need as the reason to completely change the area and reduce further its natural value.

7. In consideration of the statements mentioned above it is necessary to ask:
Where is the justification for this development in the light of so many Marinas and hotels already available on the Maltese islands?
Where are the compensating natural pockets for conservation and Maltese use, to pay back for the constant loss of land, coast and sea we have been witnessing.
Where are the tangible actions reflecting efforts toward Sustainable development, where priority needs to be given to development that really have no impact or on the contrary actually improves the natural environment for future generations to enjoy.

Where are citizens’ rights to the coast and to a say in local council matters if indeed referendums with 85% votes against are totally ignored.

Where are the planning and environment experts of MEPA that should be working to make sure such unworthy developments do not even disturb the peace and quite of Maltese that have already enough on their plate. Have NGOs and the public got to do the job of MEPA officials and Consultants who are paid to sieve and scrutinize all projects within the increasingly narrow set of options left for these small islands.

Where are the local economic considerations of improving local bathing beaches that has been advertised for years to Tourists as a “pretty sandy beach with lovely view of Comino Islands”.
As such BICREF feels that with the PDS issued and data already collected by various local entities it is very clear that this development is not appropriate for the site and should be changed completely to accommodate the needs of the site, Gozo and the Maltese Islands.

Submissions by Flimkien ghal Ambjent Ahjar, Ramblers Association and Friends of The Earth.

Submission re PA 3798/02 Project Description Statement (PDS)
for proposed Qala Creek Project in Gozo


Introduction

Simply stated, Hondoq ir-Rummien is far out of the Development Zone and under no imaginable pretext can MEPA even start to consider any proposal there by virtue of its own rationale. One of the main justifications of the recently ratified Rationalisation Scheme was the sealing of the development boundaries. It is therefore unthinkable that a permit should be issued for a development the size of a small village, well beyond the building scheme boundary. To the argument that this choice of site is uniquely suited to such a touristic /marina project one has to reply that there are other far more suitable marina sites.

As for making an exception for a touristic project to be built Outside the Development Zone, when this was done in Gozo, the hotels eventually dropped the touristic nature of the project and switched to pure speculation, selling off units to Maltese. We should not even be discussing the repetition of this scenario.

The dilapidated quarry at Hondoq should be no excuse to develop the area commercially. The device of allowing an area to become dilapidated and then claiming it for development would be too easy, and a precedent such as this would result in more rampant development all over Malta.

It is the responsibility of the former quarry operator to rehabilitation the quarry to its natural state, complementing the natural surroundings; a far preferable solution than inflicting more buildings and infrastructure in an area that is far out of the development zone, even as recently rationalized.

Overdevelopment in Gozo has already played havoc with the quaint rustic character that always distinguished Gozo from Malta, and the proposal will have the typical inevitable effect of destroying more of the local mores and character. The Qala village core will lose its quaintness and develop into nothing more than another route to another tourist destination, after having borne the brunt of the heavy dusty and destructive traffic of the construction stage and choked by traffic to the project once completed. No wonder the recent referendum with Qala residents an overwhelming 79% said NO to the last proposal.

Provenance:
Most of the property was formerly Church land. The Church can only sell land for social causes, which is certainly not the case at Hondoq. Is the property under review legally entitled to the land and have the contractual obligations that are usually laid down on transfer of property ever been brought to light, and those certified regarding terms, conditions, boundaries, etc?

Rights
The proposer seems to have lost sight of the truth that access to the shoreline is a birth right of every individual, and the right of access all along the foreshore is constitutionally protected. The coastline is constitutionally protected from private ownership in favour of public access; will there be public access to the marina with ongoing access to Dahlet Qorrot along the coast beyond it?

Sustainability
Sustainability and socio/economic viability should be the leading light of any project and at this stage Gozo should be apprehensive of projects of a speculative nature. The sustainability claims of this project are based on individual elements like energy conservation and sewage treatment, but do not address the larger picture of sustainable land use for Gozo.

A truly sustainable project for this area would be the one endorsed by the Local Council a few years ago which tackled the rehabilitation of the quarry in such a way as to create a massive water reservoir to collect the rainwater run-off from Qala valley, a precious resource for all the surrounding fields. The whole area was then to be converted to a national park, which would serve not only the Gozitan population, short of public open areas, but also help boost tourism.

Initially speculation may land a developer with funds to construct energetically, but what long-term studies have been made of the impact on the project as various other similar projects become operational – Chambrai, Duke, Mgarr Hotel redevelopment, Kempinski. All these developments will place so many luxury residences on the market that supply risks to outstrip demand with potentially damaging consequences. It is a common story around the Mediterranean basin where overdevelopment spelt the ruin of many little havens as their charm vanished beneath heaps of concrete.

Already Malta and Gozo are littered with the corpses of many failed tourism projects:
- Ta’ Monita
- Germa Palace
- Excelsior Hotel
- White Rocks Complex
- Mistra Village
- Festa Village Mellieha
- Fort Chambrai
- Mgarr Hotel
- Andar Hotel

Others like Ta’ Cenc are struggling, while others still, like the Atlantis and the Calypso hotel are up for sale. Many of these projects, like Hondoq, aimed for the up-market, high-spending tourist sector and had strong foreign backing and even longer experience than the Prestige Group. With Maltese tourism arrivals at a ten-year low, and no upturn in sight in the foreseeable future, we cannot continue to squander our very limited land resources in this way. The Government’s National Commission for Sustainable Development stipulates "that development must meet the needs of the present generation without compromising the ability of future generations to meet their own needs." The lack of serious and long-term feasibility studies presented in this project statement does not even guarantee the project’s survival through this generation, let alone the next, and should therefore be refused.

Beach facilities
The developers’ proposal to enhance the beach by providing a diving-board, toilets and access for the disabled rings hollow as such facilities already exist. Both the local population and tourists alike have made it clear that they do not desire ‘top-range beach facilities’ that would ruin the as-yet unspoilt character of the bay, but simply an upgrade to maintain safety and cleanliness standards that have come to be expected of a public beach. The PDS itself states: “Changing an existing relatively undeveloped (even albeit somewhat degraded) sea shore environment, where informal summer recreation takes place, into a more structured and formal recreation space, which inevitably detracts from the current attractiveness of the area.”

The upgrading of the slip-way facilities will only serve to encourage the use of the bathing area for boats, with the resultant polluting fumes and slicks. Such facilities are readily available at various points around Gozo, including nearby Mgarr harbour and replication at Hondoq can only add to the danger of mixing bathers and motor boats, while having a negative impact on the bathing water quality and its attraction to both bathers and divers.

The developers’ offer of providing 80 car spaces for public use is patently inadequate seeing that on average during the Summer 150-200 cars park by the beach. Given the total lack of public transport in the area, any development that limited to only 80 cars would be an unacceptable infringement of public access.

Scope
While lauding the developers’ attention to energy-conserving building designs, their opinions on environmental sustainability can be described as subjective at best. While properly calling for a full EIA development of the area, the PDS states that mineral extraction could commence in 2006, of which there are only 4 months left. What scope does that leave for the preparation of a professional and serious EIA as well as its assessment by competent authorities?

The Client
Such self-laudatory statements as “Gozo Prestige Holidays Ltd. enjoys a reputation of being the market leader in its sector. This it gained over 12 years of striving to be the best” have no place in a serious Project Development Statement. Ditto its self-congratulatory “commended for its innovation and boldness for going after
new markets”. Neither the creation of up-market projects nor the provision of yachting facilities are new to Gozo which has been taking initiatives in these sectors for years.

Economic
While there is no doubt that the project will seek to “secure an acceptable rate of return on investment for the Project's shareholders over the medium to long term”, the long-temp employment prospects of Gozitan employees are not substantiated by short, medium and long-term employment projections.

Employment in the Gozitan tourist industry is preponderantly seasonal and hoteliers are increasingly employing low-wage Eastern European staff. There is also the question of property being purchased by Maltese buyers, rather than foreign ones, as has happened in other supposedly ‘touristic’ projects. Local tourism generates much fewer employment opportunities than foreign, and will therefore impact the forecast. While an important addition to the skills pool, the sectors of marina management and crafts that are mentioned are not labour-intensive, and so do not add much quantative value to the employment picture.

As for gambling facilities, a Casino would hardly conform to the image of a typical Gozitan village that the developers claim they want to project. Again, a similar project in Malta, handled by mainstream foreign expertise has been dogged by problems since its inception. Given the money-laundering dangers inherent in this sector, a permit for such activity should be considered with the utmost of prudence.

Given this situation, is the net gain for Gozo worth the sacrifice of yet more Gozitan land?

Environmental
The environmental terms proposed are vague and relative. “aesthetically pleasing” “acceptable landscaping” are all terms which might attractive, but are not based on true environmental values. Furthermore, what is deemed attractive right now could seem out-dated in just a decade’s time.

Similarly technology which seems to guarantee acceptable standards now may prove wanting. For example, has the rubber-dam being proposed been proven in the sort of gale force seas that the Qala coastline is regularly exposed to?

The afforestation proposals being put forward by the developers would be better suited to the undisturbed setting of a National Park, rather that having the natural vistas spoilt by buildings. The setting out of walkways and conservation of heritage buildings by the developers do not justify the writing off of the whole area as a national resource.

In spite of yachts being berthed within the marina, the desired level of regulation enforcement is not yet available on the Maltese islands to prevent ‘accidents’ like the emptying of bilges outside marina. Apparently no provision for such waste management has been foreseen. As it is, the bathing area is already occasionally affected by the fumes and oil slicks of boats passing at a distance on the way to Comino, let alone once they start coming right into the area for berthing. What studies have been carried out to check the effect of the proposed coastal restructuring on the prevailing currents, seabed, etc?

No mention is made in this section of dust abatement measures during the quarrying period. Not only will the immediate area be covered in fine dust, but so will the village, depending on prevailing winds. This fine particulate matter has been proven to be the cause of Malta having the highest incidence of asthma in the Mediterranean. The sort of excavations being proposed in this project will only aggravate that situation in Qala.

Wind action can also blow the stone dust into the sea, choking the sea and posedonia meadows as happened at Portomaso where they were regularly choked with dust for weeks on end.

The volume of traffic being generated will have a negative effect not only on Hondoq itself but especially on the village of Qala. Heavy transport vehicles will be traversing the village during the 18-month quarrying period followed by the construction period which will continue until 2010 and very likely beyond. What environmental impact precautions and mitigation measures will be taken and maintained by the developers throughout the whole extent of the project to prevent negative impact of:
- Noise pollution, air pollution, water course and sea pollution
- Rock-blasting excavations
- Heavy vehicle excavation and construction traffic
- Spillages of spall, 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

Once operational, a 170 bedroom hotel, 25 villas and 260 units will generate a huge volume of direct transportation needs as well as a constant flow of heavy vehicles required to supply the hotel, 5 restaurants and 10 shops. Calculated as approx. 874 morning trips and 1052 evening trips at peak hour, this will not only create constant noise disturbance but also dangers to old people and children, inevitably and irreversibly changing the character of Qala village, leading to the abandonment of some of the dwellings most affected by the traffic impact, as has happened in Malta. Although the possibility of a access road which skirts Qala centre has been mooted, this has not yet been confirmed, and therefore cannot be presumed. An air quality test taken by the Police Station on the main road some time ago showed Qala to have the second most polluted air in Gozo. With the addition of one truck every 10 minutes due to the development, the air quality is bound to deteriorate even further, undermining the health of Qala residents.

Financial Sustainability and Profitability
The added spill-over revenue that the Marina will provide for the Gozitan economy would be achieved just as well with a Marina sited in a more suitable location. Although another Marina will be a further encouragement, the sailing fraternity is no newcomer to Malta and Gozo, as Malta has been competing successfully in this sector for decades. On the other hand dive tourism has been very badly impacted by Malta’s inability to maintain the clear water standards of other countries. The loss of one of Gozo’s pristine sites, which will definitely be a no-go area at least for the duration of construction and possibly longer, will be a further nail in the coffin for dive and eco tourism.

Alternative Uses
It is surprising that this section makes no mention of another option which has been broached in the past. A contractor has come forward who is ready to excavate the mineral resources in such as way as to make possible the rehabilitation of the site as a National Park. Profits from the sale of the excavated stone would go towards the landscaping, and this plan could incorporate the giant water reservoir mentioned earlier. The beach could be cleaned and upgraded and the clearing of the dumped material as well as cleaning of the guarigue would also be taken in hand.

Why Qala Creek Marina
While we agree that another marina or destination port would be beneficial to Gozo, it is fallacious to say that “boat traffic alone is not normally enough to make a marina development viable”. As attested earlier in the PDS, Maltese marinas cannot cope with demand, and yet neither the Camper and Nicholsons marina in Vittoriosa nor the Malta Maritime Authority marinas have accommodation facilities, let alone a prefabricated village! If these were not granted such permits, why should Hondoq ir-Rummien be accorded preferential treatment, especially when the Maltese experience has proven that this is not essential to the success of the project?
As for the site sieving process, this development in question does not merit a mere map sieving analysis, but a proper site selection exercise based on scientific criteria and terms of reference drawn up by MEPA. We therefore maintain:
1) That the map seiving analysis is not sufficient.
2) That a site selection exercise based upon scientific criteria drawn up by a competent body (in this case this should be MEPA) must carried out.
3) If this has not been carried out then it should be carried out prior to commissioning the EIA.
The eventual EIA should be based upon the site most suitable for the development, irrespective of what land the present developers have already purchased. The way the most suitable site was chosen leaves a lot to be desired. The sieving process loses all credibility when one reads that the two most polluted bathing areas, Xatt l-Ahmar and Mgarr Harbour are commented as follows: “The loss of the swimming area cannot be easily replaced and is likely to be lost for ever.” while Qala, whose sea is pristine, merits no comment on the project’s impact on bathing in that area.

Furthermore, the Xatt l-Ahmar site was dismissed due to the problems posed by the presence of clay, which is the very situation that Qala is likely to face once the coralline limestone has been excavated, exposing the unstable clay beneath. Several areas of the North-West including nearby Xaghra and Nadur have faced serious construction degradation due to buildings ‘slipping’ down clay slopes. As this ruled out the choice of Xatt l-Ahmar, it should also have a bearing on Qala.


Environmental Impacts due to the Qala Creek Marina
The PDS states “Looking at the Qala Creek project in more detail, it can be discerned that the biggest environmental impact is on the surrounding marine environment” and again: Any form of development anywhere along the southern shore of Gozo will impact sea grass meadows, A number of species of seaweeds of the genus Cystoseira are protected locally and internationally….. The habitats present at Hondoq ir-Rummien may potentially support a number of other locally and internationally protected species. Examples include Seahorses ….”
The presence of a number of protected forms of sea-life reinforces our call to move the Marina to a less ecologically-sensitive area, one which has already been ruined by pollution or disturbed by works etc.
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“In its current status, Hondoq ir-Rummien is quite pristine and its waters are relatively free from most potential marine contaminants. With respect to bacteriological pollution, all stations at Hondoq ir-Rummien were completely safe for bathers and free from pollution by sewage. The bathing waters of Hondoq ir-Rummien must be one of the safest and cleanest for Gozo.” The report also presents original data to suggest that although the Gozo coastline is at risk from several potential sources of oil pollution, Hondoq ir-Rummien is as yet relatively free from this type of pollution.

On the other hand, the expert who prepared this section, shared his fears: “ Particulate matter in the form of quarry dust, will be produced at a rate of approximately 5% of the daily production volume of excavation. Of this 5%, probably half will be dust and the rest too small to be of any use in construction. The dust fraction poses the largest threat to the air and marine environment, and whereas the relative remoteness of the site will make airborne dust less of a critical problem, its proximity to the coastline means that extra attention is required to prevent accidental discharge into the sea.”

This proves that in spite of all the remedial measures mentioned in the PDS, there is a very real danger from the quarry dust. Are we really ready to risk one of the safest and cleanest of waters for a Marina project that can be sited elsewhere? It would be folly.





Mineral Extraction
The prospects of dumping 90,000c.m of unusable waste and 40,000cm of clay at Ta’ Isopu are rather dubious given that the Ta’ Isopu quarry is almost full and will be closing soon.

Infrastructure
An upgraded mains water supply pipe from Mgarr may be necessary, while a new sewage pipeline would have to be laid connecting the project to the Gozitan main sewerage network. The sewage would have to be pumped up to the new rising main line, which will pass through the same narrow road used by all the heavy vehicles with the attendant risks of cracked pipes and having to sort out sewage blockages or burst pipes on Qala’s main square.

Conclusion

We feel that the Marina and the tourist village should be treated independently. Ownership of ODZ land does not automatically confer the right to exploit the nation’s limited land resources. A serious study would identify a better site for the Marina, one which is not a pristine bathing site. As for the tourist village, if this is found to be justified and viable, then past Ministry of Tourism regulations should be followed, only allowing new tourist complexes to rise on the site of old ones.

Ultimately, the greatest value of Hondoq ir-Rummien is that it is the only bay in Gozo that is relatively unspoilt and offers excellent, clean bathing protected from the prevailing NW winds. The proposed development will detract from all this. Hondoq is also very popular during other seasons for hikes and picnics not only with Gozitans but with Maltese and foreign ramblers as it offers spectacular country and sea views It forms part of the uninterrupted coastal unbuilt circuit that leads from Marsalforn to Mgarr and on to Ta’ Cenc. Hoteliers can vouch for the number of off-season tourists that visit Gozo for rambling in wonder of the panoramic views that the circuit offers.

What is required at Hondoq is a careful layout to improve the environment (terrestial and marine) of the area through forestation and beach management, and then to provide amenities to the seasonal demand in a professional manner and with least impact on the environment - organised parking and relative amenities to beach bathing and fishing in summer; picnics, hikes and rambling. Other sites are available for a Marina in Gozo, and touristic development should not be allowed to destroy the very product it seeks to sell.

The fact of the developers already having bought this site, should not render to an automatic choice for a project that clearly has no place in Hondoq ir-Rummien.

Flimkien ghal Ambjent Ahjar

Ramblers

Friends of the Earth