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.
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.
posted by Hondoq at
2:05 PM
