The Birkirkara to Ta’ Xbiex section of the national flood relief project channels water from as far away as Wied Incita on the outskirts of Attard. The relevant environment impact assessment (EIA) prepared at project proposal stage anticipated the release of particulate material, such as silt, in the coastal waters, during both the construction and operational phase.
In order to mitigate the environmental impacts of this discharge, the EIA recommended a number of measures. These include the installation of a boon in the form of a silt curtain to prevent the dissipation of the milky white, turbid plume into the surrounding waters. But as can be seen from the accompanying aerial photo, these boons have completely failed as they lie like tattered rags close to shore rather than being in the water to act as a bulwark against marine pollution.
The EIA was optimistic in its forecast regarding some of the environmental impacts anticipated for the storm water discharge points. It said: “During construction within the proposed location, the total amount of rock that will be ‘pushed out’ onto the shore in the breaching operation is small (circa 10m3), so no major impacts are envisaged even in the worst-case scenario.”
With hindsight – now that the project is nearing completion – the “no major impacts” forecast can be seen as having sugared the pill somewhat excessively.
Through a baseline environmental survey conducted a few years ago, by scuba diving in the sea just off the Ta’ Xbiex discharge point, a number of protected marine species were recorded, including the stony madreporan and the Noble Pen Shell, which against all odds still thrived in the area. I wonder whether these survey findings were taken into consideration when implementing the mitigation measures for the storm water relief at Ta’ Xbiex and whether these protected species still survive in the area.
No one contests the national importance of the flood relief project but the environmental impact mitigation measures the operator was supposed to undertake as part of the development permit conditions should be fully implemented. Otherwise, why go through the motions and effort of conducting an EIA if the developer is then not made to abide by its recommendations?
Proposed development at Xagħra Valley
At face value, planning application PA 1822/14, proposing to build a dwelling along Marsalforn Road, Xagħra, is legitimate enough. But upon closer scrutiny, one realises that the proposed development is unacceptable, for a number of reasons, which have been diligently laid to bare by the Malta Environment and Planning Authority case officer and also by the group of residents formally objecting to the development.
Perhaps the most glaring aspect of the proposal, as aptly underscored in the case officer’s report, is that policy GZ-EDGE-2 of the Gozo and Comino local plan prohibits the development of swimming pools in ODZs and on ridges, unless the proposed development is within an existing, permitted garden and complements the sensitive characteristics of the ridge edge. This is certainly not the case with this proposal, with the case officer making this observation at both screening and processing stages, to no avail.
Other red flags raised by the proposed development include the fact that given its ridge positioning it lies in an Area of High Landscape Value. In this regard the Gozo and Comino local plan states that: “In instances where the development zone boundary coincides with a ridge edge, the resulting development has a very strong impact on the visual amenity of the urban edge as seen from the surrounding countryside. Development proposed at the edge of ridges shall therefore be given even greater attention in view of the fact that these areas are scenically very conspicuous and are strategically and visually sensitive from a landscape point of view.”
Why go through the motions and effort of conducting an EIA if the developer is then not made to abide by its recommendations?
The site also lies partly on an Aquifer Protection Zone and in the upper reaches of a Category B valley (Xagħra Valley). The following provisions apply to this category of valleys: “Category B valleys shall also be generally subject to the provisions of RCO 29 but some flexibility in terms of road upgrading, services upgrading, wind-pumps, small stores (subject to policy GZ-AGRI-3), reservoirs and other limited facilities which are deemed necessary for the continuation of traditional agricultural practices, may be considered. In all such cases, special consideration shall be given to mitigation measures so that the intervention blends well in the rural landscape. The strong presumption against the construction of new structures (including greenhouses) shall be also applicable to Category B valleys.”
For these legitimate reasons, the development proposed through PA1822/14 should be refused, in line with a similar decision taken in the case of PA 4076/09 for a site along Triq Ġnien Imrik Street, Xagħra. The latter proposal had been refused by the Mepa board, with the subsequent appeal also being thrown out, mainly on the grounds that the proposed swimming pool was located in an ODZ and on a ridge.
Unless the goalposts have been moved since then, the same rationale should also apply in the case of the pending planning proposal.
Further pearls of wisdom on ODZ from developers
Last week, I took part in a radio programme to discuss the proposal to develop three hotels in the Outside Development Zone in the coastal stretch between Xgħajra and Marsascala. The discussion panel also featured Sandro Chetcuti, president of the Malta Developers’ Association (MDA), Ralph Cassar from Alternattiva Demokratika and John Paul Cauchi, a Marsascala resident which has been vociferous in his opposition to the proposal.
Some of Chetcuti’s arguments merit further analysis as they reflect the mindset of some developers. For instance, Chetcuti asserted that one should not treat all ODZ areas the same; he said: “there are ODZ and there are ODZ”, referring to ODZs that are hemmed in by two built-up areas to validate his point.
This is effectively a retraction on the view expressed by the MDA some months ago, both by its former president, Michael Falzon, and also by Chetcuti himself, who stated that ODZ areas are cast in stone and should not be encroached upon. And the example touted by Chetcuti hardly holds any water in the case of the Xgħajra-Żonqor Point coastline under discussion.
Secondly, it is self-evident that proponents of this project are wheeling out the much-needed rehabilitation of San Leonard Fort, and its subsequent conversion into a boutique hotel, as their trump card, to give the proposal a air of legitimacy. This is because there is consensus about the need for this rehabilitation.
Chetcuti asserted that one should not treat all ODZ areas the same, referring to ODZs that are hemmed in by two built-up areas to validate his point
However, this should not be used a ruse to usher in development of the site. For instance, the envisaged boutique hotel would need parking and other ancillary facilities, resulting in more uptake of land. Other large-scale development projects in Malta, approved on the back of their pledge to restore historical monuments and buildings, obviously gave precedence to their profit-making aspects, with the completion of the rehabilitation pledge dragging on for years.
Thirdly, Chetcuti repeatedly advocated the ‘need’ for five-star hotels in the ‘south’ of the island and that these didn’t necessarily have to be located along the coast and could be ‘spread out’ in various locations in the ‘south’.
I pointed out that only one five-star hotel in Malta is actually located inland, adding that what the south needs is not more concrete white elephants but high-quality public recreational areas. I also referred to the Sliema coastline, hemmed in between Tigné Point and Qui-si-sana, blighted by the concrete of one abandoned lido after another.
According to Chetcuti, clearing the considerable and various types of waste marring the Xgħajra-Żonqor Point stretch of coastline was impossible without private intervention.
This underscored the sorry predicament we are in, whereby the government is unable or unwilling to finance the rehabilitation of a natural area for public enjoyment, providing developers even more leverage to make their case that development on such sites is ‘necessary.’
I reiterate my call for the government to rehabilitate the Xgħajra-Żonqor Point coastline, mainly by clearing waste and closing the temporary road after works have been completed, to prove once and for all that development is not necessary to give a facelift to a site but that the government, using public funds, can do it.
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