I refer to the contribution Aquifer 'Makes Golf Course Impossible' (October 19).

The article, quoting hydrologist advisor Marco Cremona, puts forward arguments built on basic mistaken assumptions.

To start with, the information given by Mr Cremona about the proposed golf course at Verdala is clearly incorrect. Mr Cremona states that in the Verdala case, the hydrological discussion centred on whether the blue clay layer was cracked enough to allow the contaminants from the golf course to reach the underlying aquifer. This is not correct. Blue clay does not underlie the proposed Verdala golf course. The public may easily verify this and other related facts in the relevant environmental impact statement (EIA).

The article's reference to the project description statement (PDS) for the proposed Ix-Xaghra l-Hamra course shows that the reporter is not so conversant with the contents of the document. Moreover, the article does not make clear that the PDS is not the impact assessment report. The PDS is simply a report that describes the proposed project. Mepa uses it to determine if an EIA is required and as a consultation document for the formulation of the terms of reference.

When the PDS states that "the site may accommodate the golf course without affecting the aquifer protection zone", it is actually quoting a previous Mepa report on the proposed golf course site. This report lists the pros and cons of developing the site for golf. Issues such as whether the golf course would affect the aquifer or not have to be assessed within the ambit of the EIA itself.

As required by law, the PDS was drawn up before Mepa even formulated the terms of reference for the EIA. For this reason, the authors of the PDS would never have been in a position to make such statements as quoted above. In fact, neither the Malta Tourism Authority nor the EIA consultants have ever made such assertions.

With regard to the hydro-geological aspects of the site, the MTA's EIA consultants have of course drawn the authority's attention to these. However, in accordance with best EIA practice, it is totally inappropriate to dismiss any proposed project without first considering measures to mitigate possible impacts that may enable the golf course to be constructed and operated in accordance with the EU's Water Framework Directive 2000/60/EC and a whole range of legislation, policies, guidelines and technical issues as required by Mepa's terms of reference.

The matter is not as simple or as clear-cut as the article implies.