SOS Hondoq - Submissions

Sunday, September 24, 2006

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


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.

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?

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 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.

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.

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?

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.
“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.

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.


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


Friends of the Earth