Corridors of landscape at Golden Sands

"It is quite evident that the major impact of the development is on the landscape," states the Environment Impact Statement (EIS) for Golden Sands Hotel. An application was filed in March for the re-development and contended expansion of the Golden Sands and Côte D'Or hotels as a timeshare franchise in an area of coastal garigue (referred to in the EIS as "degraded steppe").

During the past four months the Malta Environment and Planning Authority and the developers have been discussing the environmental impact of the proposed project at Golden Bay. The application has been recommended for a permit and awaits the final go-ahead from the Development Control Commission.

Has the application been fast-tracked at the expense of the environment? The outline plan raises environmental issues of concern which apply to tourism developments in general.

The first issue is whether the hotel should be re-developed at all, lying outside the development zone as it does.

Green areas, as we used to call them, are now known under a new label as ODZ. Applications keep flowing in just the same with far too many being issued permits or eventually sanctioned to swallow up more countryside.

We have not learned anything from Spain's example where hotels are demolished to create open spaces after the tourism industry realised it had gone too far in over-developing the Spanish coastline to its own detriment.

What do established local planning guidelines tell us about building large hotels in our own countryside? Had the MEPA local plan for the North West of Malta been passed through Parliament (it is still waiting), the Golden Sands architects at least may have been obliged to scale it down to a less imposing dimension.

North West Local Plan Policy NWTO 4 states that the total re-development of existing tourist accommodation facilities in rural areas will only be considered "in very exceptional cases where a new proposal has a very high design quality and considerably improves the rural landscape. Even in such rare cases where permission to redevelop is granted, the increase in the number of beds and/or the intensification of the existing uses will not be permitted."

How hotel blocks can ever be said to "improve the rural landscape" is something of a mystery to me. The Environment Protection Directorate within MEPA is pressing for more emphasis on the landscape protection policies for the North West within the context of the Golden Sands application.

The proposed height at Golden Sands is to be nearly twice that of the original hotel. Three blocks have been proposed instead of one as the architects seem to go by the theory that this will tone down the impact on the view.

The gaps between the buildings are referred to endearingly as "landscape corridors". To me and you they are just gaps between buildings.

The main point of contention between MEPA and the developers is the height of the "very visible" first block on the inland side. Looking at a photomontage of the new development it is evident that the block would impinge on the view from the neighbouring bay at Gnejna.

The worst view is that projected from the Manikata road where the eastern block is judged to be "extra" when compared to what existed before.

A reduction in height has been recommended by MEPA. The developers, while claiming to be concerned about the impact on the view from Gnejna are submitting that the three blocks could be dressed up in what is called "the reversible approach".

A decision was taken at an earlier stage to move the hotel backwards from the cliff edge to reduce the towering effect when viewed from the beach, although this meant that the footprint would impinge on previously untouched land.

Coastal loopholes

As part of the EIS procedure MEPA has asked the developers to state if they think the development is in breach of structure plan policy CZM3. This policy calls for public coastal access all along the coast.

As pointed out in MEPA's own Coastal Strategy Topic Paper (seized upon by the developers) policy CZM3 is not well enough developed to be fully effective.

"The absence of an identified geographical space directing where this policy applies has led to loopholes in development control." Another set of MEPA guidelines for areas ODZ makes no reference whatsoever to the safeguarding of public coastal access.

"Public access and use of extensive coastal areas classified as ODZ have been lost to development leaving only narrow stretches for such purposes." Public access is being interpreted as a pathway while the open spaces that policy CZM3 was meant to protect are being displaced by development.

The developer makes use of every opportunity to turn a poor track record to his advantage. In correspondence with the Authority, the developer has stalled on any commitment regarding the breach-or-comply question on cliff access.

At this stage the developer will go no further than saying that only after the outline development is approved will the architect indicate in landscape drawings how the policy is to be complied with. This sounds terribly slippery and is not a satisfactory answer to instill public confidence.

The developers on their part counter that MEPA appears to have accepted the current situation of public access being provided only on the beach and suggests that government negotiate with Mellieha Local Council, Island Hotel Group and the Scouts to allow a footpath between the hotel and the scout complex ground now being developed.

This leaves no guarantee that an agreement will be reached. Why should the public tolerate having their right of access accepted in principle only to be compromised in this way?

Save the trees

While the flower beds may take up almost as much land as the buildings, the planting intinerary is exemplary. A wide range of Maltese plants are to be used to reproduce a Mediterranean orchard and watercourse. It is a pity we do not know how to look after the real thing so well.

The use of chemicals could be harmful to the organic centre lying downwind. The developers predict that pest control measures will be kept to a minimum. It is good news that no chemical weedkillers are to be used and there are plans to compost any discarded plant material.

In response to a MEPA query over whether the development conforms to the Tree and Woodland Protection Regulations the developers answer gingerly: "The proposed scheme may involve the displacement of listed trees."

The EIS notes that a number of trees and shrubs present on the site are protected, including pines, tamarisks and African wolfbane. MEPA suggests that a detailed survey of the site identifying the exact location of the listed trees be prepared and evaluated.

What chance is there that these trees will really be preserved?

Waste and water management

The demolition of the old hotel produced some hazardous waste in the form of PCBs, according to the EIS. After years of denials that PCBs had ever been used in Malta, Enemalta was forced to admit during the EU negotiation process that they were present on the island.

The corporation was unable to identify the present location of some of this hazardous waste, saying only that it had been 'lost' when some transformers were sent to a scrapyard.

Waste management obligations for the project are quite stringent even if existing enforcement on these ever more complex matters appears to be nowhere up to scratch.

Quizzed on water use, the developers state: "Given the large project footprint most of the effluent will be used for irrigation which is required all year round."

Water requirements for turfed areas alone are estimated to be 20 litres per square metre at every watering - a minimum of every ten days from April to September. This adds up to over 800 l per square metre in a year.

The figure for the entire turfed area planned should be made available to the Malta Resources Authority (MRA). Retaining or replicating natural garigue as a major feature in the landscaping would reduce water needs and make any surplus water available for local farmers.

Last summer farmers at Armier blamed the Solemar Hotel when their water supply ran dry. The MRA has informed the Golden Sands engineers that the drawing up of water for the reverse osmosis plant from a borehole cannot be permitted.

MEPA comments on the developer's suggestion that sewage sludge could be used for fertilizer. The sludge remaining after sewage treatment is "already a problem" for the treatment plant at Sant'Antnin and the future sewage treatment plants proposed for Malta and Gozo. MEPA requests that alternative disposal methods should be identified.

While the project engineers insist that both chlorination and UV treatment are necessary to disinfect water, MEPA questions whether both methods are necessary. UV treatment would not pollute the marine environment.

Required energy

The MRA asked for an estimate of energy requirements. Before going ahead with the project the developers are obliged to ask Enemalta whether as energy provider it is in a position to supply the required energy demand.

In the meantime the Energy Directorate, which forms part of the Environment Protection Directorate, has suggested the use of renewable energy in the project. The developers say that the use of solar or other renewable sources is "actively being considered". At the same time they seem more concerned about integrating this into the overall scheme "in a sensitive manner".

The project engineer is investigating the possible use of solar collectors to pre-heat hot water for the hotel bathrooms. There is also some interest in photovoltaic cells for generating clean energy to be used on site or sold back to Enemalta.

On the whole architects hate solar panels as they get in the way of their designs. They do not usually take energy-saving into account when it comes to building design. MEPA should insist on this more, especially for large developments.

Energy efficiency at the design stage does need to be looked at more carefully at Golden Sands. One architects drawing suggests the use of large glass panes to encourage the landscape to "pass through the lobby". How this will increase energy demand for heating and cooling inside the building needs to be kept in mind.

There are two main pollution worries surrounding the project. During the construction stage Nature Trust is very wary about dust reaching the marine environment and has recommended the use of a dust curtain.

The suffocating effect dust could have on the surrounding garigue habitat is a prominent point made in the ecological impact study.

Asked to indicate the impact of noise during demolition and construction, the developers quote WHO guidelines for "serious community nuisance" at 55dB(A) for daytime (7 a.m. to 11 p.m.).

They go on to add that it is difficult to make the required statement "particularly when it is well known in Malta that several contractors make use of re-conditioned second hand equipment".

Around 60 per cent of timeshare buyers prefer a location with a beach. About half as many want history and culture. The impact statement notes that marketing activities are likely to be sub-contracted to specialist time share marketing companies.

I wonder if anyone is looking at the impact of more timeshare touts on our fragile tourism industry.