Hondoq - Objection TO: PA 03798/02
OBJECTION TO: PA 03798/02: Construction of a destination port comprising a hotel, yacht marina and a tourist village at Qala, Gozo.
Click here to view non-technical summary.
FAA maintains that this application should be rejected based on the following points:
1) The proposed development turns an ODZ area into an urban zone, thereby going against the Structure Plan. As the current Prime Minister has stated, “ODZ is ODZ”.
2) The proposed development violates CZM 3, namely:
POLICY CZM 3: Public access around the coastline immediately adjacent to the sea or at the top of cliffs (including in bays, harbours, and creeks) will be secured. This will include taking shorelands into public ownership, Government acquisition of illegal developments and encroachments, and suitable construction works. In the few cases where this is not practical (for example where security considerations are paramount), nearby detours will be established. All the coastline will be brought into public ownership within a specified period.
Instead of bringing more of the coastline into public ownership, as happened recently with the stretch of foreshore between Fomm ir-Rih and Gnejna, this proposed development turns the public Hondoq ir-Rummien bay into a tourist ghetto. It will reduce the area available to the general public. And, as generally happens elsewhere, the presence of a yacht marina will effectively mean that quality of the bathing water and indeed of the present character of the bay will be negatively affected. This means that the general public will be deprived of another swimming area in order to serve private interests.
3) The proposed development goes against SET 11, namely:
POLICY SET 11: No form of urban development will be permitted outside existing and committed built-up areas, and primary development areas as designated in the Structure Plan even where roads and public utilities are available. Permitted forms of non urban development outside such areas are restricted to the categories referred to in Paragraph 7.6
4) In FAA’s view this project has not been properly assessed for sustainability and viability. There are currently a number of speculative projects in Gozo, such as Chambrai, Marsalforn, the Duke, Mgarr Hotel, Andar Hotel, Atalntis Hotel, etc. All these developments will place a large number of residences on the market. This one proposes to add a 170-bed hotel, 25 self-catering villas, 60 self-catering units and 200 multi-ownership residences. Given what happened to the Mgarr, Atlantis, Andar hotels part of Kempinski Hotel and other hotels in Malta (Djerma, Mistra, etc), this hotel might be also be turned into residences in the future. Is this glut of residential units really required? In my opinion this project is does not reflect an Eco-island concept currently being touted for Gozo.
5) This development will destroy more of the qualities that makes Gozo attractive and bring in visitors. Gozo’s major strength lies in it being a small rustic island. However, more areas in Gozo are being smothered in concrete, all in the name of development. I do not believe that we should continue building up Gozo until it becomes like Malta.
6) Hondoq ir-Rummien is a popular beach with the Gozitans especially as it is protected from the prevailing NW winds. There are already very few beaches in Gozo, and this proposed development will effectively remove another one. This development is therefore very much against the general public interest. As a matter of fact, when the wind blows from NW, Ramla and Marsalforn become dangerous for swimming and Hondoq is the only clean beach where one can swim and accomodate everyone.
7) In the EIS, a lot of attention is given to the degraded parts in the Hondoq ir-Rummien area. Nowadays this is becoming a favourite excuse of developers: “the area is already degraded and is an eyesore, so let’s build it up”. In our view, the mere fact that an area is degraded, to larger or lesser extent, does not constitute a good enough reason to build upon or excavate it. Rather, the area should be cleaned up and restored to its original state, wherever possible, or else converted to a wooded park or recreational area as was proposed by third year architecture university students and as is being proposed for the Maghtab landfill.
8) The EIS proposes a number of mitigation measures during the long construction phase. However, given the normal practice in Gozo (just consider the areas around the quarries at Ghar id-Dar/Ta’Klement and the quarries in Tal-Misrah and Ta’ Xrajjah), no one can seriously expect that these proposed measures will be applied in full. And even if they were, they will still generate a great inconvenience and an unhealthy and noisy atmosphere to the current residents. Given MEPA’s environmental protection brief, we expect MEPA to give due consideration to the residents.
9) MEPA should ask the developers to carry out the Traffic Impact Assessment properly with Terms of reference in places where the Qala residents are and not closer to Ghajnsielem as was done. Two traffic studies were made 1.3km and 1.8km away from the Qala centre. Another inaccuracy in the TIS is that it is listed that the streets are 7.2mts wide when in fact parts of this road is 4.2mts. The public hearing should not take place before the TIS is complete.
In conclusion, FAA hopes that MEPA will continue in its recent highly-commendable path of giving more or less equal weight to environment and development. Please refer to the MEPA PR dated 6th May 2010, entitled Landmark Decision by MEPA board, where the current Chairman stated that “the Board takes decisions based on today’s planning policies and on the principle of sustainable development while making sure that permits are granted in the public interest.” Public interest here dictates that this PA is rejected outright, and more suitable solutions are found than this proposed mega-development in this area of pristine waters and quiet beaches.
11.05.2010