SOS Hondoq - Submissions

Sunday, September 24, 2006

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