The music of the night

Satellite photos clearly indicate the extent of light pollution in Malta: it is comparable to that in most urban areas in the European continent. As a result, the music of the night is made inaudible. The night is being “impeded from unfurling its splendour”, as the Phantom of the Opera repeatedly emphasises in Andrew Lloyd Webber’s masterpiece.

Some years back, during the budget debate, a project related to intelligent street lighting was launched. When implemented, such a project would be an effective contribution to the reduction of light pollution all over the Maltese islands. Unfortunately, we have not heard of any substantial progress on the matter since late 2013, when the project was first announced.

Excessive artificial lighting used during the night is not only an inefficient use of energy, and the consequential contribution to additional carbon emissions which can be avoided, it is also a disturbance of nocturnal animal life and potentially injurious to human health.

Way back in 2007, Birdlife in Malta had published a study on the impact of night lighting on seabirds and nocturnal migrant species. The study is entitled Light Pollution and its effects on Yelkouan Shearwaters in Malta; causes and solutions. The context of the study is the EU Life project site at l-Aħrax in Mellieħa, in the area known as l-Irdum tal-Madonna, the site of a seabird colony.

The observations made and the solutions proposed in the study could easily form the basis for an action plan applicable to all of the Maltese islands to address light pollution because, in Malta, this is a serious problem not just for shearwaters but also in terms of carbon emissions and our quality of life.

As a result of Malta’s high population density, nocturnal light pollution has a considerable impact on both urban and rural areas all over the Maltese Islands. Ecologically, it has an impact on birds, moths and bats but it also has a considerable impact on animal behaviour in general. Beyond wildlife, light pollution creates glare which is a road safety issue and has an impact on drivers, pedestrians and cyclists and is known to play a considerable part in nocturnal traffic accidents.

The Dwejra light pollution case decided by the Environment and Planning Revision Tribunal on the 27 June is a rare case when a sensible decision was taken by the Planning Control Commission only for it to be reversed on appeal: normally it is the other way round! In fact, the Planning Control Commission had refused the original application on the basis that the Dwejra area is an area of ecological importance. Unfortunately, the Tribunal treated the issue of light pollution very lightly and was insensitive to its ecological impacts.

The coming together of fifteen environmental NGOs to crowd-fund the fight on appeal in Court is a good step forward. Protecting Natura 2000 sites is a tough fight but it needs to go on. Appealing against the scandalous decision of the Environment and Planning Revision Tribunal should, however, only be a first step. It should be realised that the Environment and Resources Authority (ERA) has powers and authority under the provisions of the EU Habitats Directive that it does not make sufficient use of. The ERA should assert itself and enforce the rules, bulldozing through the Planning Authority whenever this is necessary.

It would be much better if the Hon. Minister for the Environment insists that the ERA manages areas of ecological importance appropriately. Obviously, he must ensure that adequate resources are provided.

This Dwejra case is a specific example of where the ERA can have the final word. Will it?

published in The Malta Independent on Sunday : 7 July 2019

L-appell dwar il-permess tad-dB f’Pembroke

 

L-appell kontra l-permess tad-dB biex iħarbat is-sit tal-ITS ġie sottomess.
Ir-raġunijiet għall-appell, fil-qosor huma s-segwenti:

1) Il-kunflitt ta’ interess ta’ Matthew Pace, membru tal-Bord tal-Awtoritá tal-Ippjanar u fl-istess ħin b’interess f’aġenzija tal-propjetá,
2) Il-kunflitt ta’ interess tal-Membru Parlamentari Clayton Bartolo, membru tal-Bord tal-Awtoritá tal-Ippjanar,
3) In-nuqqas ta’ skrutinju tal-presentazzjoni sħiħa minn Jacqueline Gili li twasslet għal-laqgħa tal-Bord bil-jet,
4) Nuqqas ta’ konformitá tal-proposta ta’ żvilupp mal-Height Limitation Adjustment Policy for Hotels,
5) Nuqqas ta’ konformitá tal-proposta ta’ żvilupp mal-Planning Policy Guide on the use and applicability of the Floor Area Ratio (FAR), artiklu 5.9 dwar l-ispejjes konnessi mal-iżvilupp tal-infrastruttura,
6) Nuqqas ta’ konformitá tal-proposta ta’ żvilupp mal-Planning Policy Guide on the use and applicability of the Floor Area Ratio (FAR), u dan dwar diversi dettalji tal-policy kif imfissra dettaljatament fid-dokument tal-appell,
7) Nuqqas ta’ konformitá dwar policies li jikkonċernaw l-impatt viżiv,
8) Hemm appartamenti li huma inqas fid-daqs minn dak stabilit mill-policies tal-ippjanar,
9) is-Social Impact Assessment ma sarx sewwa,
10) L-iżvilupp propost ma jikkonformax ma policies, liġijiet u obbligi internazzjonali dwar il-ħarsien tal-wirt storiku,
11) L-iżvilupp propost jikser diversi policies u liġijiet dwar il-ħarsien tal-kosta,
12) L-iżvilupp propost ma jsegwix policies intenzjonati biex iħarsu l-ispazji miftuħa,
13) L-impatt tat-traffiku mhux ikkunsidrat b’mod adegwat; ma sarux studji neċessarji u kien hemm nuqqas ta’ konsultazzjoni bi ksur tal-Konvenzjoni ta’ Aarhus,
14) Ma ġietx osservata l-liġi tad-Dimanju Pubbliku u dan dwar il-ħarsien tal-kosta,
15) Nuqqas ta’ konsiderazzjoni u piz mogħti lil materji diversi relevanti dwar ambjent, estetika u sanitá,
16) Nuqqas ta’ development brief u Master Plan,
17) Nuqqas ta’ ħarsien ambjentali dwar protezzjoni ta’ bijodiversitá, flora u fawna fuq l-art u fil-baħar, siti Natura 2000 u Għarq Ħammiem
18) Nuqqas ta’ osservanza ta’ liġijiet diversi dwar tniġġiż u emmissjonijiet kif ukoll dwar skart riżultanti mill-proġett.

Il-mina bejn Malta u Għawdex: il-qerda finali t’Għawdex wara l-bieb

Nhar l-Erbgħa festa pubblika. Hi ukoll id-data tal-egħluq għall-konsultazzjoni pubblika li qed tagħmel l-Awtoritá tal-Ambjent u r-Riżorsi (ERA) fuq it-termini ta’ referenza għall-istudju dwar l-impatt ambjentali (EIA) tal-mina proposta bejn Malta u Għawdex.

Is-sit elettroniku tal-ERA jippreżenta żewġ dokumenti sabiex jassistu lil dawk li qed jipparteċipaw f’din il-konsultazzjoni pubblika. Dawn id-dokumenti jispjegaw il-proposta u jidentifikaw numru ta’ fatturi li jistgħu jkunu jeħtieġu investigazzjoni, u dan biex dawk li jieħdu d-deċiżjoni jkunu megħjuna jagħmlu l-“aħjar” għażla.

F’dawn id-dokumenti hemm numru ta’ nuqqasijiet li jistunaw u juru kemm Transport Malta tiġi taqa’ u tqum mill-wirt ambjentali tagħna.

Transport Malta tibbaża l-proposti tagħha fuq ir-rapport ta’ Mott MacDonald, datat Marzu 2012 u intitolat: Preliminary Analysis: Assessment of Road Tunnel Options between Malta and Gozo. Wara li kkunsidrat erba’ proposti differenti għall-mina kif imfisser fir-rapport ta’ Mott MacDonald, Transport Malta ddeċidiet li tagħżel il-proposta numru 4 b’emenda: hi proposta li tkun tikkonsisti f’mina waħda b’żewġ karreġjati u tibda mill-inħawi taħt Ta’ Kenuna fin-Nadur Għawdex u tispiċċa fl-Imbordin biswit il-Wied tal-Pwales f’San Pawl il-Baħar.

Fid-dokumenti jgħidulna li l-ewwel tliet proposti kienu skartati għax setgħu jikkawżaw ħsara ambjentali sostanzjali, f’qiegħ il-baħar jew lir-riżerva naturali tal-Għadira. Imma la Transport Malta u l-anqas l-ERA ma ħassew il-ħtieġa li jgħidulna fid-dokumenti li ippubblikaw li meta ntagħżlet il-proposta numru 4 u ġġebbdet sal-Imbordin biswit il-Wied tal-Pwales din ġiet viċin wisq tar-riżerva naturali l-oħra, tas-Simar, u tgħaddi dritt mill-Miżieb, mal-pjan tal-ilma.

Ir-riżerva naturali tas-Simar hi sit ikklassifikat bħala Natura 2000 tal-UE, u l-pjan tal-ilma tal-Miżieb hu l-unika wieħed sura li fadlilna. Allura hemm il-possibilitá kbira li din il-proposta għal mina tmur kontra żewġ direttivi importanti tal-Unjoni Ewropea: id-Direttiva Qafas dwar l-Ilma u d-Direttiva dwar il-Abitat.

Fl-2015 il-medja ta’ movimenti ta’ karozzi bejn Malta u Għawdex, kif jirriżulta mill-istatistika uffiċjali, hi ta’ madwar 3000 kuljum. Id-diversi studji u rapporti ppubblikati sal-lum jikkalkulaw li l-mina, meta tkun lesta, tista’ twassal sabiex in-numru ta’ karozzi li jaqsmu bejn iż-żewġ gżejjer jitla’ bejn 9000 u 10000 kuljum. Gordon Cordina minn Ecubed fir-rapport tiegħu kkummissjonat minn Transport Malta u l-Kamra tal-Kummerċ Għawdxija jindika li ser tintlaħaq iċ-ċifra ta’ 9000 karozza kuljum, fil-waqt li r-rapport Mott MacDonald jipponta lejn l-10,000 karozza kuljum.

Din iż-żieda konsiderevoli fil-moviment ta’ karozzi teħtieġ li tkun analizzata fil-kuntest tal-politika kurrenti dwar it-trasport. Il-master plan dwar it-trasport addottat mill-Gvern preżenti u ffinanzjat mill-Fond Ewropew għall-Iżvilupp Reġjonali hu ċar. Dan il-pjan jgħid li matul l-għaxar snin li fih ser ikun effettiv (2016-25), wieħed mill-oġġettivi ewlenin tal-politika tat-trasport f’Malta hi emfasi fuq l-użu ta’ mezzi alternattivi għall-karozzi privati u li fil-gżejjer Maltin jonqos l-użu tal-karozza privata.

Mela Transport Malta, għan-nom tal-Gvern Malti fl-2016, tistabilixxi politika dwar it-trasport biex tkun indirizzata l-konġestjoni tat-traffiku billi tinkoraġixxi bdil fl-imġieba favur mobilitá sostenibbli, u mbagħad toħroġ bi proposti bħal dawn tal-mina bejn Malta u Għawdex, li biex jagħmlu sens, jirrikjedu żieda enormi fit-traffiku.

Id-dokumenti fuq is-sit elettroniku tal-ERA għall-informazzjoni ta’ dawk li jridu jipparteċipaw f’din il-konsultazzjoni pubblika dwar il-mina bejn Malta u Għawdex jinjoraw kompletament il-politika dwar it-trasport.

Din hi s-sitwazzjoni li għandna illum. Drajna b’awtoritá tal-ippjanar sinkronizzata mal-lobby favur l-iżvilupp. Sfortunatament jidher li l-Awtoritá dwar l-Ambjent u r-Riżorsi miexja fuq l-istess passi. Il-jiem huma magħduda. Bla dubju dan ser iwassal għall-qerda ta’ Għawdex ukoll.

 

Ippubblikat fuq Illum : Il-Ħadd 12 t’Awwissu 2018

The Malta-Gozo tunnel: the final countdown to Gozo’s plunder starts now

Next Wednesday is a public holiday. It is also the closing date of the public consultation being carried out by the Environment and Resources Authority (ERA) on the terms of reference for the Environmental Impact Assessment (EIA) to be carried out on the proposed Malta-Gozo tunnel.

The ERA website presents two documents to assist those participating in the public consultation. These documents explain the proposal and highlight a number of issues that will require further investigation in order to assist the decision-takers in choosing for the “optimum” solution.

There is a number of glaring deficiencies in these documents which indicate the contempt that Transport Malta has for our environmental heritage.

Transport Malta bases its proposals on the Mott MacDonald Report of March 2012 entitled: Preliminary Analysis: Assessment of Road Tunnel Options between Malta and Gozo. After considering the four options for a tunnel as resulting from the Mott MacDonald report, Transport Malta opted for an amended version of option number 4 which is proposed as consisting of a single bore two lane tunnel between the area below Ta’ Kenuna in Nadur, Gozo and L-Imbordin along the Pwales Valley in St Paul’s Bay in Malta.

We are told in the published documentation that the first three options were discarded because they could be the cause of considerable environmental damage to the seabed, as well as to the Għadira Nature Reserve. However, neither Transport Malta nor the ERA considered it appropriate to mention that the selected option, an amended option 4, stretches the Malta portal of the proposed tunnel to the Pwales valley very close to the Simar Nature Reserve and right through the Miżieb perched aquifer.

The Simar Nature Reserve is an EU Natura 2000 site, while the Miżieb perched aquifer is the only part of our water table that is still in a relatively good state. Consequently, two important EU Directives will most probably be infringed: The Water Framework Directive and the Habitats Directive.

Based on NSO statistics, in 2015 average number of daily vehicular crossings between Malta and Gozo was around 3,000. The various studies and reports published to date indicate that it is estimated that a tunnel between the two islands would trigger an increase to between 9,000 and 10,000 vehicle crossings daily. Gordon Cordina of Ecubed in his report commissioned by Transport Malta and the Gozo Business Chamber indicates a 9,000-daily mark, while Mott MacDonald points towards the 10,000 mark.

This considerable increase in vehicular movements needs to be analysed in terms of current transport policy. The Transport Master Plan, adopted by the current government and funded by the European Regional Development Fund, is very clear. It lays down that during its 10-year lifespan (2016-25) it will be an operational objective of transport policy in Malta to aim to provide alternatives to the use of private vehicles and to reduce the role of the private car as a means of transport in the Maltese Islands.

So, Transport Malta, on behalf of the Maltese government, spells out transport policy in 2016 aimed at addressing traffic congestion in Malta by encouraging a modal shift towards sustainable mobility. Yet it then comes out with proposals such as the Malta-Gozo Tunnel, which can only be feasible if there is an astronomical increase in vehicular traffic on our roads.

The documents placed by the ERA on its website to feed the public consultation process on the proposed Malta-Gozo tunnel ignore transport policy altogether.

This is the current state of affairs. By now we are accustomed to having a Planning Authority acting in synch with the development lobby. Unfortunately, it seems that the Environment and Resources Authority is closely following in its footsteps. The final countdown is on. It will inevitably lead to the plunder of Gozo as well.

Published in The Malta Independent on Sunday : 12 August 2018

Comino: beyond sun-block and deckchairs

During the past weeks, the island of Comino has been in the news. The controversy surrounding the deckchair/umbrella hawkers free-for-all at the Blue Lagoon focused on overcharging, breaching of permit conditions and the resulting lack of space for the public making use of public facilities at the beach.

Fines were imposed by the Malta Tourism Authority. This is fine (pun intended) in the short term. However, we need to plan for the long term, keeping in mind  that the island of Comino, is first and foremost a Natura 2000 site and a touristic destination second. Sites forming part of the Natura 2000 network are designated as Special Areas of Conservation (SAC) and Special Protection Areas (SPA) according to the Habitats and Birds Directives of the European Union, where habitats and species are listed. The Directives are designated to provide protection to the most vulnerable of the species listed.

It has been stated that every day, at the peak of the summer season, as many as 5,000 visitors land on Comino, most of whom remain in the Blue Lagoon and its environs .

The Natura 2000 Management Plan for Comino published recently, considers that tourism at the Blue Lagoon needs to be controlled efficiently in order to ensure that it is “in harmony with the site’s conservation needs”. One of the measures which the Comino Management Plan establishes as an operational objective is “to plan and implement a tourism carrying capacity assessment of the Blue Lagoon”.

The Management Plan believes that the tourism carrying capacity assessment should be carried out within the first year of the plan’s implementation, which means pretty soon! The issue is of fundamental importance in ensuring that the activity permitted on the island of Comino is compatible with its ecological requirements.

It is not known whether this carrying capacity assessment has been carried out yet. If not it should be done at the earliest.

This is not the first time that Maltese authorities have been asked to consider a proposal to study the possibility of limiting access to a specific site for protection purposes. Around 12 years ago, after rehabilitation work carried out at the Hypogeum in Ħal-Salfieni was concluded, it was decided that there was an urgent need to control its microclimate in order to better protect this archeological jewel so a maximum limit of 80 visitors per day was established.

Various other countries place limits on tourism in order to better control its environmental impacts. There are various examples, but permit me to point to the Brazilian archipelago of Fernando de Noronha, 545 kilometres off the coastal city of Recife. The archipelago is a UNESCO World Heritage site and the number of visitors is restricted in order  to adequately protect its environmental patrimony. The environmental protection rules of the Brazilian archipelago of Fernando de Noronha go into such detail as to even forbid the use of sunprotection lotions/creams or even the use of footwear on the beach, as well as curtailing various other activities incompatible with the archipelago’s ecological characteristics!

It is a path we should consider following for Comino, if we are serious about protecting the little that we still have.

It is welcome news earlier this week as three of Malta’s environmental NGOs, Din l-Art Ħelwa, Friends of the Earth and Nature Trust, have endorsed the proposal for carrying out the capacity assessment of the Blue Lagoon at Comino. Comino deserves our protection. Implementing the Natura 2000 Management Plan for Comino would be a suitable first step.

And the sooner, the better.

published in The Malta Independent on Sunday: 11 September 2016

Barely scratching the surface

The Noise White Paper, just published for public consultation, identifies the need to coordinate the existing fragmented administrative structures as its first target. This is being done in the belief that it will eventually lead to a smoothening out of administrative inconsistencies. Better coordination could also ensure that, in the long term, issues in respect of which the authorities have, to date, been reluctant to act upon can be addressed in an appropriate manner. Hopefully.

The White Paper deals with the abatement of neighbourhood noise. Its reach should have been much wider. It postpones dealing with the noise generated by fireworks and village feasts to some future date. Cultural aspects and tradition are reasons used to justify this postponement. In reality, the government at this time cannot withstand the anticipated reaction of the fireworks lobby, which has yet to come to terms with restrictions based on safety as is evidenced by reactions to the findings and recommendations of the November 2011 inquiry report on accidents in fireworks factories. Clearly, the government considers that now is not the time to regulate excessive fireworks noise. On the eve of a general election, votes are considered to be a more important consideration.

We have been informed (correctly) that the EU Environmental Noise Directive is not applicable to our airport because the traffic it handles is below the established threshold.

The White Paper does not address the issue of noise generated by aircraft approaching or taking off from Malta’s only airport when flying over residential areas. In particular, the impact of approaching aircraft on Birżebbuġa’s residential area at all times of the day (including during the night) comes to mind.

Now, to be fair, one must state that the airport cannot be transferred to any other site. The flight paths leading to the airport are fixed and their use is determined by the prevalent winds. Malta needs its only airport to be operational. Yet, its operation must be such that it does not cause unnecessary hardship to residential areas along the approaches to and around the airport.

This leaves only one option: regulating the airport’s operating times to restrict aircraft movements during the silent hours as is done at Heathrow, Brussels and Fiumicinio, to mention three airports with which readers are familiar.

The airport authorities need to encourage the use of less noisy aircraft through the determination of differentiated aircraft landing charges dependent on the noise generated by the aircraft. It is about time that the airport authorities start respecting the surrounding communities. This is a missing but essential element of the airport’s sustainable development strategy.

The Noise White Paper draws up a list of those authorities that are empowered to regulate some aspect of noise control. One would expect that the police, the Malta Tourism Authority, the health authorities and the Malta Environment and Planning Authority coordinated by the Noise Control Board to now be in a better position to ensure that commercial outlets (particularly those in a mixed use area) are no longer a nuisance to residents in the vicinity.

It should also be less problematic to deal with nuisance caused by air conditioners fixed in the most awkward places.

But noise does not only impact the health of human beings. It also has a health impact on flora and fauna. This is partly regulated through the Habitats Directive of the EU, which is an integral part of Maltese law.

It is positive that the Noise White Paper recognises this and emphasises the need to ensure its implementation. This should now place more onus on Mepa to ascertain that open-air activities generating excessive noise are immediately brought to order. Examples that come to mind are open air discos at Buskett, Paradise Bay and Ta’ Qali. The first two impact biodiversity in Natura 2000 sites and the last is too close to residential areas, particularly Attard. The aborted Mistra “Spin Valley Disco”, which the Nationalist Party and its stooges at Mepa defended before the 2008 election, would also fall foul of these provisions as it was sited right in the middle of a special area of conservation.

Excessive noise also has a damaging impact on the welfare of animals, both farm animals and pets. The impact of noise on farms and agriculture is completely ignored by the White Paper.

Fireworks regulations, for example, are only concerned with residential areas and the distances to be observed from areas that serve as a residence for more than 100 humans.

Excessive noise in agricultural areas severely impacts agricultural production (like milk, poultry, eggs, rabbits…) and can have a considerable economic impact.

It is up to the minister in question to decide whether to prefer the fireworks at the expense of negative impacts on animal husbandry. He may not worry unnecessarily as animals do not vote!

While the White Paper on Noise Prevention is welcome, it barely scratches the surface. We need to go deeper and tackle areas ignored by the White Paper because noise pollution is an issue that has been neglected for far too long.

 

This article was published in The Times of Malta , April 14, 2012

 

on the same subject on this blog :

7th February 2009 : The value of silence

7th November 2009 : When pigs are able to vote

Mental Gymnastics at MEPA

Over the past two years, three special areas of conservation were in the news: Mistra (Spin Valley disco), Baħrija Valley and, now, Dwejra. Next in the news will be the White Rocks sports development, bordering Pembroke.

The Director for Environment Protection at the Malta Environment and Planning Authority is on record as saying that an SAC should not be “a keep-out zone”. To my knowledge, no one has made such an assertion. It is, however, to be underlined that permissible activities in and around SACs are limited in terms of the EU Habitats Directive.

Decisions of the Environment Protection Directorate relative to SACs need to be adequately motivated. This is unfortunately not always apparent. What is also very clear at this stage is that the Environment Protection Directorate seems to have been kept out of the process leading to the original decision on the use of the Dwejra site, only to be pushed onto the frontline at the eleventh hour when a damage limitation exercise was embarked upon.

The Habitats Directive is very clear. As a rule, it permits activities on and in the vicinity of SACs only if these activities are required for the purpose of managing the site. Other activities may also be permitted but when this is the case they are subject to stringent procedures and conditions.

The Habitats Directive (transposed into Maltese legislation by Legal Notice 311 of 2006) may permit an activity in or in the vicinity of an SAC provided the Environment Protection Directorate determines it is not detrimental to the site either on its own or cumulatively with other activities.

However, in so determining, the Environment Protection Directorate has to carefully consider the proposed activity and correlate it to all the characteristics of the SAC. In particular, it should also consider what is known as the “corridor effect”. That is, whether an activity in or outside an SAC is likely to have an impact on any area of the SAC or another protected area in the vicinity, say a marine conservation area as is the case in Dwejra.

An SAC should be considered as a whole and should not be parcelled into areas where activity is permissible and others where it is not, as Mepa seems to be suggesting. Malta cannot go on with declaring areas to be SACs only to subsequently commence mental gymnastics in order to invent exceptions whenever the need to justify something crops up.

Analysing statements made after the Dwejra saga, it is clear Mepa failed to do the above. By stating the site was “bare rock”, worse still, by stating there is no eco-system to protect (even if this absurd statement was later retracted), Mepa in my view abdicated its responsibilities as the competent authority entrusted by the EU to act on its behalf to manage SACs, which are today part of an EU Natura 2000 network.

At least two parallel investigations are under way. One by the Mepa audit officer, the other by independent experts to scientifically examine and report on any impacts on the site as a result of the permit issued by Mepa.

So far, the applicant (Fire and Blood Productions) and the sub-contractor have been censured for not observing the permit conditions imposed by Mepa. However, no official comment as to whether Mepa overstepped its brief in issuing the Dwejra permit has yet been made. This I submit is the primary pending matter as, in my view, Mepa should never have authorised the placing of sand at Dwejra.

Earlier this year, in an article entitled Land Speculation At White Rocks (July 7) I had written about another SAC, that at Pembroke. The proposal there does not involve the temporary placing of sand but the development of a sports complex in an area which is very close to the Pembroke SAC. In view of conflicting information it is not yet clear how and to what extent this proposal impacts the Pembroke SAC.

After considering the manner in which SACs have been mismanaged by Mepa in Mistra, Baħrija, Dwejra and, now, possibly Pembroke it is legitimate to ask why the government has bothered to declare them as areas worthy of protection.

It is clear so far the government is only interested in paying lip service to such issues and, subsequently, to engage in mental gymnastics to justify anything.

As stated by Parliamentary Secretary Mario de Marco (The Cost Of Decisions That Count, The Times, November 27) one should not use this serious incident to discount the validity of a number of environmental initiatives. However, if the government wants to be taken seriously on environmental issues it must put its house in order. Unfortunately, this does not seem to be a priority.

 

Published in The Times of Malta, Saturday December 4, 2010

AD demands Mepa information on Dwejra ‘mauling’

 

Carmel Cacopardo, AD’s spokesman on Sustainable Development has asked MEPA in terms of the Freedom of Access to Information on the Environment Regulations of 2005 to release a copy of the permit (including the relative conditions) which it has issued for filming in the Natura 2000 site of Dwejra Gozo.

“The mauling of the Natura 2000 site at Dwejra Gozo in the year 2010, is further proof that MEPA is either incompetent, oblivious of its responsibilities, or else it is unwilling to administer such EU Natura 2000 sites in terms of its responsibilities as the Competent Authority for Malta an EU Member State,” Mr Cacopardo said. “The Dwejra debacle follows the obscene development permits issued by MEPA in Mistra, Baħrija valley, Ramla l-Ħamra Gozo, all Natura 2000 sites. Furthermore it is to be underlined that Malta has received substantial financial aid under the EU Life Project in connection with the management of the Dwejra Natura 2000 site.”

The latest incident at Dwejra raised a number of questions in respect of which answers were expected, he said.

“1. Why was this permit not monitored when it is well known that filming companies tend to ignore limitations imposed by regulatory authorities ?

“2. Why did MEPA not send any of its inspectors at Dwejra, a Natura 2000 site, to monitor adherence to the conditions of the issued permit as is usually done in such cases, thereby ensuring that no damaging actions are taken in hand?

“3. Where was the sand used at Dwejra transported from?

“4. Did the Works Division in the Ministry of Resources and Rural Affairs issue a permit for the transportation of sand as is required by article 3 of the Sand Preservation Act ?

“5. How can MEPA be sure of the origin of the sand used if it did not carry out adequate monitoring? In particular can it 100% exclude that the sand used was not transported from Ramla l-Ħamra, another Natura 2000 site?

“6. What legal action will be taken in connection with what has happened?”

The AD spokesman said the government through its agencies was not only paying lip service towards the protection of the environment, but to date all it had done had proven to one and all that it did not have an inkling of what environment protection was all about.

as published in timesofmalta.com 4th November 2010

also on maltastar.com 5th November 2010

The White Rocks Project

Dirk Urpani, AD Spokesman on Sports and Youths stated that AD appreciates that at last Government has produced a plan to utilise the abandoned White Rocks site for sports. Dirk Urpani expressed the hope that this project may further enhance a sporting mentality into the minds of the Maltese, all of which stand to gain only if it is properly implemented.

Carmel Cacopardo AD spokesman on Sustainable Development added that
government’s enthusiasm would only be justified if the proposed development is sustainable and consistent with government’s declared policy on the inauguration of the current session of Parliament in 2008. It was then solemnly declared that the Gonzi government would be guided and inspired by the principles of sustainable development. It is now time for Government to show one and all what it has learned from its environmental blunders, including those of the recent past, as was most recently observed in the press by the Parliamentary Secretary responsible for Tourism and the Environment.

AD, added Cacopardo, assumes that since it has been declared by Government that the environment is one of its policy pillars it has already taken into consideration the fact that the White Rocks Area borders a Special Area of Conservation which of its very nature limits the type of development and activities permissible. This is one of the duties which Malta has assumed through EU membership as it was this same government which identified this area (adjacent to the White Rocks area) to form part of EU’s Natura 2000 sites subject to the regulations detailed in the Habitats Directive.

In view of the above, Michael Briguglio, AD Chairperson, concluded that it would be appreciated that the Prime Minister, even as Minister responsible for the Environment, puts everyone’s mind at rest how these responsibilities will be honoured now that detailed plans appear to have been finalised.

AD will be able to comment further about the project when the detailed plans are published.

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Dirk Urpani, kelliemi ta’ Alternattiva Demokratika (AD) dwar iż-Żgħażagħ u l-Isports jgħid li AD tapprezza li fl-aħħar tfaċċa pjan biex iż-żona mitluqa magħrufa bħala White Rocks tintuża għal attivita sportiva. Dirk Urpani esprima t-tama illi dan il-proġett jista’ jgħin l-iżvilupp sportiv fil-Maltin. Dan iżda jseħħ biss kemm-il darba l-proġett ikun implimentat sewwa.

Carmel Cacopardo kelliemi ta’ AD ghall-Iżvilupp Sostenibbli kompla li l-ħeġġa li qed tintwera tkun ġustifikata biss jekk l-iżvilupp propost ikun wieħed
sostenibbli u konsistenti mad-diskors programmatiku tal-Gvern fil-ftuħ tal-Parlament fl-2008 fejn gie dikjarat solennement li l-Gvern Gonzi ser ikun illuminat mill-prinċipji ta’ żvilupp sostenibbli. Huwa l-mument li l-Gvern juri jekk tgħallimx mill-iżbalji ambjentali li għamel anke’ fil-passat riċenti, u dan kif osserva tant tajjeb reċentement f’ġurnal lokali s-Segretarju Parlamentari responsabbli mit-Turiżmu u l-Ambjent.

AD, żied jgħid Cacopardo tassumi li billi l-ambjent illum huwa pilastru ewlieni tal-politika dikjarata tal-Gvern dan diġa ħa in konsiderazzjoni il-fatt li
l-area tal-White Rocks tmiss ma’ Żona Speċjali ta’ Konservazzjoni (Special Area of Conservation) li allura minna nnifisha tillimita x’tip ta’ żvilupp u attivita’ tista’ issir fl-inħawi. Dan huwa wieħed mill-obbligi li Malta daħlet għalihom bis-sħubija fl-Unjoni Ewropea meta kien il-Gvern innifsu li identifika ż-żona biex tagħmel parti min-Natura 2000 tal-Unjoni Ewropea. L-obbligi kollha dwar dan joħorġu mid-Direttiva tal-Habitats.

Għaldaqstant temm jghid Michael Briguglio, Chairperson ta’ AD,  AD tapprezza jekk l-Prim Ministru jserraħ ras kulhadd u jekk issa li jidher li hemm pjani dettaljati dwar il-progett jinforma lill-pubbliku kif dawn l-obbligi ser ikunu onorati.

AD tkun tista’ tikkummenta fid-dettall dwar il-proġett meta l-pjanijiet kollha
dettaljati jkunu pubbliċi.

TEN-T : The Għadira Nodes

published Saturday 27 December 2008

by Carmel Cacopardo

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Two important points have to be borne in mind while searching for a solution to upgrade the Ten-T (Trans-European Transport Network) road link at Ghadira Bay, Mellieha.

Firstly, all identified solutions will have an environmental impact. Secondly, in order that the public discussion be fruitful all information must be freely available.

The stakeholders are not just NGOs and specific economic operators. The whole community is the stakeholder. Stakeholders require information not just from the perceived interested parties but more so from the public authorities that are vested with authority to defend the community’s interests.

A number of reports have been made public. Some have been quoted selectively. Others are still under wraps.

BCEOM (French engineering consultants), in its 2004 report entitled Feasibility And Environmental Impact Studies For Transport Infrastructure Projects In Malta – Final Feasibility Study Report and AIS Environmental Limited, in its 2005 report entitled Proposed Review Of Ghadira Road Options, identify the upgrading of the existing road along the beach as the preferred option.[vide also 1 and 2]

Since then a number of proposals have been publicised. These revolve around two possibilities: the retention of the existing road with modifications or the construction of an alternative road to the south of the Nature Reserve and the Danish Village.

Preliminary appraisal of environmental impacts has been drawn up and on its basis the authorities have issued opinions that have not yet been made public. These indicate the detailed studies that have yet to be carried out in order to arrive at a definite decision.

In particular, it is to be noted that the AIS report dated November 2005 states (pages 2 and 3) that BCEOM had rejected the tunnel design beyond the Danish Village, which would have reclassified the beach front route as a local road.

These proposals were rejected by BCEOM on the basis of “excessive and unpredictable costs”. In addition, the AIS report emphasises that “Mepa had rejected the tunnel options on environmental grounds because the area in question is classified as a Special Area of Conservation (SAC)”.

The AIS report further states that subsequent to the above-indicated Mepa rejection, ADT reassessed the situation and proposed three options, two focusing on the existing road and the third being a new road incorporating a tunnel and bridge through the garigue (an SAC) south of the Danish Village, which, like the SAC-protected Nature Reserve, has been officially approved by the EU and forms part of Natura 2000.

It is within this context that Mepa has requested a “holistic preliminary assessment of the impacts arising from the various options that ADT is now considering”. Mepa has requested a number of studies related to beach dynamics, ecology, agriculture, geology, geomorphology and hydrology, archaeology and others. These studies were requested way back in 2005 and none has to date seen the light of day, notwithstanding that everyone seems to be in a hurry! These studies, if properly carried out, are of fundamental importance in determining the manner in which the Ghadira Ten-T link is to proceed, if at all!

Various statements have been made in the past weeks. The most conspicuous were those related to the sandy beach. It is by now clear that these have originated (without scientific justification) from a consultant commissioned by one of the economic operators in Ghadira Bay and were intended to reinforce his proposal for a beach concession as a result of a possible re-routing of the Ghadira road.

Within this context it was highly unethical for the Ministry of Transport to invite the said consultant to sit alongside the ministry’s officials in a recent meeting with NGOs and the press. The ministry’s subsequent declaration that it would oppose proposals for beach concessions in the area can only be interpreted as an attempt to correct its ethical short-sightedness!

A further important statement was made last week by nature itself. The sea level temporarily rose to the road level, thereby reinforcing arguments already brought forward that the existing road during the winter months is doubling up as a coastal defence to the Nature Reserve, which, being sited on former salt pans is partly below sea-level.

At this point in the debate, matters are slightly less nebulous than they were in the beginning. The declaration by the Minister for the Environment that all the required studies will be carried out is welcome.

However, such a declaration risks being viewed as a cheap attempt at damage control unless an explanation is forthcoming as to why these studies have not yet been finalised notwithstanding that they were requested by Mepa way back in 2005!

It is clear that, until recently, some thought that these studies could be dispensed with only to realise at the 11th hour that the environmental lobby is vigilant and will keep insisting that the government, through its various agencies, should shoulder its responsibilities!