An objective evaluation of the worst case scenario

Surely, by declaring themselves adamantly against a golf course at Ix-Xaghra l-Hamra without considering the findings of an environmental impact assessment, environment NGOs and other vociferous critics have compromised their integrity for the debate which must follow the EIA's publication.

What these are saying is that no matter what the EIA finds, they cannot accept a golf course at Ix-Xaghra. They really do not want a golf course anywhere, but especially they do not want it at Ix-Xaghra.

Whatever they say when the EIA about the proposed Xaghra golf course is published, their statement of obdurate opposition will taint their arguments. If they make a case against the golf course's viability, their case will be taken with a pinch of salt. People will doubt the integrity of their arguments now.

It is a pity. The farmers who may be affected if the development takes place have shown better sense. They, and residents of Manikata, have been co-operating fully with the experts conducting the EIA. They have, for instance, taken various consultants around to show them features of the area which are not widely known about.

An eviction notice was issued to the farmers tilling the land in the area. It does not mean the eviction will be implemented, but the farmers knew that under the terms of the lease such a notice was possible, and the government was within its rights to give it. The eviction notice was issued at the particular time because apparently the farmers could be given notice only in a particular period, before the feast of Santa Marija, and at least a year ahead.

In major developments an EIA is necessary because that is what the law lays down, in line with EU requirements. When MEPA asks a developer to produce an EIA, it does so as the regulator. It does not recommend consultants. The promoter at the moment is the Malta Tourism Authority, which at present is wearing two hats: that of the authority overseeing tourism, and its development, and the other hat, of the project manager.

According to the regulations, an environmental impact statement is the result of a full environmental impact assessment study presented as a report which describes a development listed in Category I of Schedule I to the EIA regulations and its effects on the environment, indicating how these effects have been taken into account.

An environmental planning statement is the result of a limited environmental impact assessment study presented as a report which describes a development listed in Category II of Schedule I to the regulations and its effects on the environment indicating how these effects have been taken into account.

MEPA's terms of reference for the golf course have not been publicly criticised. Unless they kept mum about them, the NGOs and others who are making such a noise about the proposal, accepted them.

An EIA is not something taken lightly, or to be done in a matter of hours or days. Nor, obviously, does it look at the same aspects no matter what the project is. For an EIA about a development in an urban area, for example, agriculture may not be relevant but noise disturbance and visual impact may be. The terms of reference are tailored specifically to a particular situation.

In the golf course project the terms of reference are exhaustive. The first part looks at the socio-economic objectives of the proposal. The EIA has to look at the demand for golf - the current and expected demand for the sport in Malta. The demand data are fed into the economic aspect of the studies. What is the demand for golf, what are its financial feasibility and its economic viability?

What it could boil down to is that the situation could be that a golf course would be financially not viable by itself, but because of the spin offs arising from it, it could be economically viable. Which means that the developer could lose money on it, but the country could gain. The entire golf idea could stand or fall on that particular report.

Another section of the terms of reference requires minute details on the construction of the course and related buildings, all of which have to be costed and fed into the financial feasibility aspect. In order to produce the financial feasibility report the costings will have to be considered, right down to the price of the lawn mower. And then the EIA will have to say what it is going to cost to operate the golf course.

The EIA also has to consider how much and what material is to be used, how the water problems can be handled, the type of grass that can be used, and so on. Design changes may be asked, to take consideration of particular features which need to be protected in order to minimise the impact.

Once the course is described, a description follows of the existing state of the environment on the site and around it.

The terms of reference have asked for reports on the ecology in the dry and wet seasons and about orchid prevalence in the area. There will also be an agricultural survey, to determine for instance, what is grown in each field, use of the land in the past, soil quality and type. There will be extensive soil testing.

The landscape will be considered, examining its quality, character and visual aspects. Other studies take in the geology, geomorphology, hydrology, and palaeontology of the site. The cultural heritage is another subject for study, and that includes archaeology and the rural environment, taking in rubble walls, old structures, and military architecture.

The air quality has to be studied, along with noise. A social assessment must also be conducted, to establish the use of the area, to find out how many people use the area, and for what purpose they use it. What is it that makes a person go there, and would that change as a result of the golf course?

Once the EIA has been drafted, MEPA will circulate it to government departments and NGOs, among others, for their comment. The public will also be invited to comment and put their views at a public hearing. After that the planning application for the golf course would be considered by the MEPA board for a decision.

Because of the caution with which the government is proceeding with this project it has to date not yet filed an outline development application with MEPA, let alone a development application!