Rhyme and reason on the Xaghri

Submitting objections at an early stage in the planning process carries more weight with MEPA than showing up with placards to protest when the bulldozers have already started digging. A busy month for Environmental Impact Assessments (EIAs), August brings a series of closing dates for public comments on various development proposals. Now is the time to speak out.

As we wait for the outcome of MEPA's soul-searching over the Ramla l-Hamra villas, with permit withdrawal a possible outcome, the government is on standby for the EU verdict on Fort Cambridge on whether or not this development will have to be pulled up short until a proper EIA can be done as required - waivers apart.

One of the EIAs up for scrutiny on the MEPA Website is the proposed multi-ownership tourist hotel development at Ta' Cenc (Home page - Public consultation).

The disputed villas next to the Mgarr ix-Xini inlet, which run contrary to the local plan, are still being proposed by the developer's Environmental Impact Statement (EIS). Despite being shot down by the ministry in a clarification sent to MEPA's chairman nearly a year ago, the contentious villas have only been scaled down in the second EIS draft, not removed completely.

Limiting development means exactly that. If the authors of the local plan for Gozo had intended to encourage development on the plateau above Mgarr ix-Xini then they would have said so in no uncertain terms. They did not. Despite all attempts to contort words, the developers fail to convince us, or the ministry, that their own interpretation is anything but wishful greed peppered with audacity.

The battle to save Ta' Cenc has been raging on and off since the project was first proposed ten years ago, and objectors are worn out. Gearing up for yet another consultation over the rehashed EIS in Gozo to be held this month, environment NGOs have little left to say that hasn't been said before.

A recent post in a news forum on Minister Pullicino's stand over the developers' persistence to deliberately misinterpret planning obligations for the area reads: "People continue to shoot at the project but it never gets shot down!"

Limiting factor

It is clear that the proposed villas in Zone 4 defy both the Structure Plan and the Local Plan which set out to "limit development" near Mgarr ix-Xini. The minister has dispelled any delusions the developer may have been labouring under to the contrary. Development must be limited to what is already exisiting.

No new development can be permitted near the existing villas on the lower part of the Ta' Cenc plateau as was made clear by the minister to the MEPA chairman in a move to prevent the possible risk of going soft on the villas at board decision level.

The wording at the centre of the controversy is worked to maximum advantage in the EIS. Oblivious to the correct interpretation of national and local plans for the area, the developers minimise the damage in a plea that "additional buildings" shall be taking up a "small" proportion of the whole Ta' Cenc area.

It is claimed that development shall be "limited" to the hotel vicinity, park interpretation centre and villas. Yet the development of 38 villas overlooking the sea inlet is deemed by the same EIS to be "irreversible" and therefore of highly significant impact.

Schizophrenic landscapes

The EIS on Ta' Cenc commissioned by the developers attempts to persuade the reader that the negative visual impact of the planned buildings on the Ta' Cenc landscape can be sufficiently mitigated. This pronouncement is made even though the impact on existing landscape is significantly high by admission of the same document. Several areas within the proposal are noted to be "particularly sensitive to development".

In an endeavour to justify more buildings on top of the existing ones, the EIS offers two, apparently alternative, (neither one hostile) viewpoints. In a hat-trick of phraseology, a clear and major negative impact is made to appear positive: As long as the villas are well built and any new rubble walls constructed "bis-sengha" (using traditional skills) then it results that "existing morphology is respected".

For those holding the other viewpoint, "physical intervention" in an area like Ta' Cenc is presented as little more than "an interesting challenge for the architect".

Without further discussion of viewpoints other than the two presented by the EIS, the assumption is made that the Zone 4 valley edge villas are justified as "the logical conclusion of what is essentially an unfinished (1960s) project".

Plumping for the developers, the author signs off on the debate with the parting shot that good quality architectural design of a contemporary style weighs in as a sufficient mitigation measure "even if the impact of the intervention in question is significant".

If this were true we could build pretty buildings on every remaining inch of protected green land. If this is accepted as sound reasoning then it could well happen, as what grounds would the MEPA board have for turning down future applications based on the same warped reasoning?

Thankfully, neither the architects nor landscape conservationists are too fond of the confessed structure plan dream of faking it when it comes to traditional style windmills, church domes or lookout towers. Such features, tacked onto projects as a modern afterthought in a bid to attract planners' sympathy, would only devalue the landscape while alienating the community from meaningless token landscapes.

The proposed villas overlooking Mgarr ix-Xini are high impact no matter how well cloaked in foliage or sympathetic wording. If mistakes have been made in the past this hardly qualifies as a reason to inflict further damage through extending the building footprint à la Ramla.

In terms of the same EIS this would lead to a major impact of the development on landscape character and visual amenity range.

Despite strong indications that this part of the plan must be ditched, the new amended plan has villas crammed in to fill the gaps between existing villas in a repeat of the same error committed at the Ulysses Lodge site, rightly condemned by the Environment Minister as "too high density". Here again, greed consumes all reason.

The gap-filler villas all but risk morphing into a single form as the EIS smooth-talks its way through their major impact on existing rubble walls and terracing in the area. Going to great lengths, the author shamelessly promotes the architect's view above the viewpoint of "persons who attach a high value to the Ta' Cenc area as a rural landscape".

Since Ta' Cenc is documented as an area of particularly high landscape value one would hope that these persons would not be missing on MEPA's development board. Perceptions may be conflicting and the EIS dwells on this point. However, none will dispute the fact and content of an underlying MEPA study* which identifies landscape sensitivity at Ta' Cenc as ranging from high (AHLV) to very high (AHVLV).

As the EIS looks into the cultural impact of human intervention in the form of more buildings at Ta' Cenc, the question is raised whether such development is really necessary.

Blend or bend

The EIS presents the hotel block in gift wrapping. Whereas the vast rural landscapes of France can be expected to feature the occasional mediaeval castle or manor house, the pseudo-romantic vision put forward by the developers of a "small country chateau" is not at all in keeping with the Ta' Cenc landscape.

Developers have become very adept at trying to find a way to stretch the rules. The most unscrupulous ones aim to slip through the planning process unchallenged by those charged with ensuring that benchmark planning guidelines are not swept so deftly aside. The chances of this happening are even higher when advice from the general public, or from heritage experts, is not given its due weight.

A specific policy in MEPA's Structure Plan for the Maltese Islands speaks of the importance of blending the Ta' Cenc hotel into the landscape.

This policy would best be met by making use of the existing low-level one-storey footprint for "central recreational and other hotel facilities" specified in policy TOU 10. Rather than construct a whole new complex, this should serve any condominium apartment/villas which should also be limited to the footprint presently existing for villas or bungalows at the site.

Presenting the proposed new Sannat Hotel as two storeys with a third recessed floor was a feeble trick on the part of the developers. On this, they have been pulled up and made to shave off the top floor in the amended plan.

The policy governing tourism for the area between Mgarr ix-Xini inlet and the village of Sannat clearly states: "The height of buildings will be restricted to one or two storeys" A one storey development contained within the existing footprint would be the only appropriate solution for Ta' Cenc.

So far the three-storey hotel proposed in 2004, in defiance of the building height regulation in the policy regulating Ta' Cenc, has been downscaled. In the 2007 version of the EIS, the third floor has been removed but what will prevent the developers filing a future application for an additional level in the abusive vein of the washroom/penthouse ruse?

Come to that, what will prevent them applying for a permit to build a golf course just as Hondoq ir-Rummien developers are expected to apply for an artificial beach permit if the main development goes through?

Park consultations

The primary aim of policy TOU 10 was to create "Malta's first" nature park at Ta' Cenc. After Xaghra l-Hamra Nature and Heritage Park and parts of Dwejra Park further extended as protected areas it will have to wait in line.

If the developer's bid to spill outside the existing development boundaries onto open land at Ta' Cenc fails, then management plans for the park area will come up for fresh discussion.

Meanwhile, plans for the Xaghra l-Hamra Park are pressing ahead with stakeholders giving their views. A pre-draft plan consultation exercise was open to all at the Gaia Foundation last Friday. Members of the public were given the chance to put forward their ideas on the Nature and Heritage Park for the area after the golf course plan was discarded. The Forward Planning Unit of MEPA is open to comments from the public until Tuesday before drawing up a draft plan to be presented for further comments.

A final meeting to discuss the outcome of the second draft following public input will see the plan finalised. The consultation process as regulated by law is being followed to the letter on the design and management of the park.

This sets a good public relations model for all other types of large scale developments inside and outside the building zone. The rest is up to the public, to participate and make its voice heard at the earliest possible opportunity in the planning stage.

* A Landscape Assessment Study of the Maltese Islands 2004