From the Sunday Times
Sunday, 13th June 2010
A litmus test for eco-Gozo
The Ħondoq ir-Rummien saga has been hogging the headlines for some time now. Many will be vaguely familiar with the issue but few had the privilege to witness the charade that unfolded during the first public hearing for the application.
As has become the norm in recent years, dubious techniques were utilised by the developer to gain ascendency at the hearing. Most notably, those sympathetic to the developer's cause packed the small hall quite some before the hearing was meant to start.
The grapevine has it that a notorious developer from Malta happened to visit Gozo the day before the hearing, presumably to whip up support mainly among construction workers to turn up in numbers for the hearing - a typical 'bring-your-own-crowd' stunt. A close associate of the developer was present at the hearing, giving credence to such hearsay.
The hearing was mismanaged from the very beginning, with the Malta Environment and Planning Authority officials who were meant to regulate proceedings completely hapless to prevent the degeneration and mayhem which ensued.
The proposed development seeks to attract investment in local properties by foreigners, and a considerable number of Qala residents are foreign. Despite this, translation of the hearing proceedings for the benefit of foreigners was not permitted, and all attempts at even a partial translation were shouted down.
GRTU director general Vince Farrugia resorted to histrionics and tenuous arguments to prop up the development. For instance, he said the developer had already commissioned one million euros' worth of reports and studies, as if financial prowess and commissioned reports can buy permits.
Mr Farrugia also said the area around Ħondoq was a shambles and that refusing such a development would scare off further investment in the island. Perhaps he regards the more opulent surroundings he is accustomed to, to be more civilised, but many Qala residents and Maltese and Gozitan families regard the simple beach and concrete jetty at Ħondoq as their home.
Developing a yacht marina there would be setting a dangerous precedent. So far, yacht marinas such as those at Msida Creek, Vittoriosa and Portomaso have been developed at sites where bathing water quality is far inferior to that in Ħondoq. Sacrificing a spot which consistently ranks at the top of bathing water quality charts would be clearly communicating the message that no place is too sacred for development.
The developer's architect, Edward Bencini, and the Environmental Impact Study (EIS) coordinator, Mariello Spiteri, made some far-fetched assertions at the hearing, which merit comment. At the hearing I attempted to rebut their claims but to no avail, since the public hearing system only allows the developer's representatives to reply to statements made by registered objectors, Qala council in this case.
Bencini claimed he has seen amberjacks swimming within yacht marinas. He even showed a photo of people diving into the sea from the concrete seawall around the Portomaso yacht marina. It is beyond me how Bencini can so confidently comment on matters outside his area of competence - namely marine biology - and how the presence of isolated fish can imply that the environmental impact of yacht marinas is insignificant.
At the hearing I also pointed out that the coordinated EIS report fails to refer to the Marine Strategy Framework Directive, which stipulates that all member states should achieve good quality status of their waters by 2021, to Mepa's Coastal Strategy Topic Paper (CSTP), and to the 2009 report by the Malta Maritime Authority report (downloadable from the OPM site) on the development of yachting facilities in Malta. The developers' technical representatives did not react at all. Tacit acknowledgement?
The latter report, which is the most recent on the current state of play of yacht marinas, clearly states that the CSTP provides the most up-to-date policy on coastal development. Yet the EIS coordinator failed to even mention it, despite having referred to at least two other Mepa topic papers.
The same MMA report includes a very telling flow diagram of the hierarchical criteria which should be used to assess potential sites for yacht marinas. The flow diagram, conveniently shunned by the project proponents, explictly recommends the discarding of sites where there is a high impact on the natural coastline and where there is a significant conflict with other users and a loss of amenity. Ħondoq fits both bills. It would be very sad indeed if we have reached the stage where concrete jetties and sea walls are considered on a par with natural rocky coastlines.
Incidentally, at the hearing, Spiteri asserted that environmental monitoring at Portomaso yacht marina was abruptly halted after three years in view of the improving water quality on site - this is incorrect, as revealed in communications I have had with Mepa officials acquainted with the case.
But perhaps the social impacts are as profound as the environmental ones. The eminent anthropologist Prof. Jeremy Boissevain made mincemeat of the social impact report within the EIS. In particular, Boissevain took exception to the bold assertions made in the report that the overall social impact of the project would definitely be positive and that the project was bound to be a win-win project for all Gozitans.
The only snag in the glamorous scenario depicted in the EIS social study is that an overwhelming majority of Qala residents (85 per cent) think otherwise and would not think twice about ditching the project. According to the author of the EIS social study, the Qala residents' opposition could be pinned down to lack of proper information and to an element of herd instinct typical of small societies.
Boissevain rightly quashes such hackneyed conclusions by pointing out that as more detail about the project was provided to Qala residents, the number of those against the development mushroomed.
As is customary for all Environmental Impact Assessments, Mepa submits its own comments on aspects of the reports submitted by the developer that need to be addressed. A total of 235 such comments were submitted by Mepa.
The first deserves specific mention in view of its relevance.
"Reference is made to the various instances whereby bias in favour of the project is indicated (such as the concluding chapter of the Non-Technical Summary). In this respect, I would bring to your attention Provision 24 (2) of the Environmental Impact Assessment regulations, 2007 (LN 114 of 2007), which states that the Director of Environment Protection shall consider whether the statement has been satisfactorily compiled, prepared in a professional manner, is without bias and adequately meets the terms of reference, following which, if he is satisfied, he shall certify it. Bias also goes contrary to Provision 29 (1) of LN 114/07 and contrary to EIA best practice. You are therefore required to remove all reference to the acceptability of the project as well as other bias in favour of the project."
Parliamentary Secretary Mario de Marco should be praised for his courageous stand on the issue a few weeks ago, whereby, in an indirect call to preserve Gozo's unique coastline, he questioned the proposed development's environmental credentials. His reasoning is all the more sound when making a few simple calculations.
For instance, Sicily and Tunisia currently host 14,000 and 3,000 yacht berths respectively, or a berth per 0.54 and 0.018 square kilometres, respectively. The corresponding figure for Malta, with its current total of about 1,500 berths, is a berth per 5.71 square kilometres.
In the end, it all boils down to a simple decision, one that either further desecrates Gozo's coastal resources and its unique tranquillity, or one that gives much-needed credence to the eco-Gozo concept. The Ħondoq issue is well and truly a litmus test for eco-Gozo, which can either soar or plummet.