THE AX HOLDINGS GOLF COURSE REPORT

By Mr. Joe Farrugia and members and supporters of the Front kontra l-Golf
Course.

The Front Kontra l-Golf Course is made up of the following members:  Progressive
Farmers Union, Alternattiva Demokratika - The Green Party, Friends of the Earth
(Malta), Nature Trust, Eco - The Ecological Foundation, Moviment Graffitti, Vegetarian
Society, Pembroke Residents Association, Zminijietna, Alternattiva Demokratika
Studenti and Inizjamed.  It is supported by the University Chaplaincy, the Malta Organic
Agriculture Movement and Kopin.
__________________________________________________________

On 1st October, immediately after media reports of the presentation of a petition to the
Vatican signed by 92 farmers at Tal Virtu, the Planning Authority gave authorisation to
AX Holdings (AXH) to publish a summary of its Environmental Impact Statement for a
golf course at Rabat - ahead of any public hearing. The 15 page document was
submitted to the Church, the government, and MPs  two weeks later, and then
presented to some  journalists - but the most affected parties, the farmers, were not sent
a copy.

A request published in the letters column of last week's Sunday Times to AXH to send a
copy of its document to the farmers has not been met.  The Front has nevertheless
obtained a copy from other sources, and responds to the key points below.  The report
is very long and detailed and it is very difficult to respond to each point in this article: a
structured, paragraph-by-paragraph response will also be submitted to the Church and
the government.

The Front concludes from this document that AX H is insisting that Malta must forego
5.6  square kilometres of its remaining agricultural land, an area  the size of Sliema,
permanently  defacing the approaches to Malta's unique  heritage  -  the city of  Mdina  -
in  the  hope  of attracting  an
additional 10,400 five star  tourists, and 21,600 'average tourists' to play golf at some
unspecified  future date - an increase of respectively of 0.86% and  1.8%,  totaling
2.66%  over  present  annual tourist  arrivals of  1.2million.

The projected additions to tourist flows and expenditures, which depend on factors
beyond Malta's control (world tourism developments, competitive strength of other
golfing areas etc.) are negligible in percentage terms, so that the projected 'economic
benefits' in no way outweigh the environmental and social costs of the proposed golf
course.
On the contrary, the support to Tal-Virtu farmers to develop grape and organic produce
in the area - which face a secure and growing market - will bring certain net economic,
social and benefits to the nation.
The 'contribution' of the project is TRULY MINIMAL in statistical terms.

Whilst recognising the suitability of 15.3ha for vineyards, it fails to make the case against
the entire golf course perimeter of 72 ha becoming a premier vine growing area, although
the document states that "local grape supply does not satisfy demand Local wineries
import over LM 1.5 million of grapes a year".

AXH continues to ignore both the existence of the Church-State agreement, the
provisions of the Structure Plan, the recommendation against this project made by the
Planning Authority Directorate, the farmers' declared refusal to give up their legal
tenancies, as well as alternative pathways to attracting tourists to Malta, or potential
high-value alternative uses for the Tal-Virtu� farmland.

ECONOMIC ISSUES

The document does not state under what financial conditions AXH intends to acquire the
land from the State.  Maybe AXH expects a free donation, as compared to purchase at
the commercial market price of land in the area?

The document does not explain how a single golf course in Malta could successfully
outcompete dozens of golf resorts around the Mediterranean, offering a selection of
courses within easy reach (there are 50 within two hours' drive of Marbella, southern
Spain); competing locations identified being Spain, Italy, Greece, Rhodes, Corfu,
Cyprus, Tunisia, Gran Canaria.

The Front adds that the following Mediterranean locations also offer winter golfing:
Morocco, Sardinia, Turkey, Egypt, Israel and that some 15 new courses are being
planned for Sicily, many near or by the sea.

The 1997 Golf Course Report states that " the development of a golf course may attract
tourists seeking to play golf during the winter and shoulder months". In contrast,  the
AXH document's figures are presented as inevitable facts, when they are no more than
forecasts based on unstated assumptions which do not appear to have been corrected to
reflect present market trends, in particular after 11th September.

The AXH document claims that 735 jobs could be created as a result of the golf course,
compared to the 1997 Golf Report's more modest 100 to 125. How many jobs and
livelihoods would be destroyed by removing 5.6 square kilometres from possible very
high value agriculture (grapes and organic products)
and related processing industries and services in the future?
Moreover, these forecasts are not compared to what alternative tourist developments
could generate for the Maltese economy, whether in terms of numbers, investments or
expenditures - water sports, heritage and nature tourism, pony trekking , short 'city
breaks', etc

Moreover , Mr. Xuereb has told  the media that the golf course would be open to all
residents of Malta as well as to hotel guests, thus undermining the exclusive character
and uncluttered fairways and clubhouses which 5* golfers and time pressed conference
and incentive tourists will pay high sums for.

Finally, the AXH represents the golf course as the 'only' alternative for the Tal-Virtu
perimeter on the basis of the questionable assumption that at no time in the future will
there be investments to upgrade the areas' s agricultural potential - thus ignoring both
present and foreseeable incentives to increase vineyard acreage.

FARMERS' COMPENSATION

AXH states that LM 500,000 has been 'budgeted' for farmers' compensation. Since the
project requires 56.7 hectares, this amounts to LM 8818 per hectare or LM 979 per
tumulo. The yardstick used is AXH's estimates of present farmer incomes.  The return
on a bank deposit would be (at 4%) LM352 on LM8818, LM39.16 on LM 979.

Yet farmers to be 'allowed' to cultivate vines on an area of 15.3 ha (on condition their
plots are merged into 1 ha. Fields) under AXH management are 'guaranteed' a 'gross
income of over LM 3000', once AXH has invested 230,000 LM in the area. Who
would give such a guarantee is not stated.

The only fair yardstick for compensation is that of  'foregone future earnings' viz a capital
sum, which could generate the same net income to farmers irreversibly deprived of their
land, as 'guaranteed' to those allowed to grow vines. (the net income after costs and
taxes from the guaranteed gross income of LM 3000 per Ha.)

The government has launched a programme known as AgriPlus to increase land under
viticultutre from the 280 hectares it now covers up to 1000 hectares.  The plan consists
of lending each farmer up to LM6000  (interest free) to those who would utilize these for
projects which include viticulture. Every hectare would be costing about LM9000 to
plant and fully rig with drip irrigation and trellising (LM1000 per tumulo).  Each tumulo
could yield up to 3000 kilos of grapes or up to LM900 per tumulo or LM8100 per
hectare. If the pruning is forced to lower production and enhance quality the price would
have to go up accordingly. Now for the farmers to do this they simply do not need
AXH. Indeed AXH wants to hold the tenancy in its name.  It knows very well that its
tenancy is protected by law but so do the farmers. It denigrates the part-time farmer and
wants to deprive him or her of the possibility of supplementing his or her income by
several hundreds of LIRI per year. This upgrading of the potentiality of the land vis a vis
the tenants has only transpired this year. The project that applies to viticulture has been
launched this year. Any calculations in the EIA on the potential income of the tenants
involved have now been rendered useless and invalid.   Readers have to remember that
over LM2million worth of grapes are imported yearly. Why not encourage our farmers
part-time or not, to substitute the imported grapes with a locally grown crop. The
Government should be doing a huge publicity exercise to promote such an initiative
amongst farmers.

AGRICULTURAL USE

The AXH document states that 22.2 hectares will be used for fairways, 15. 3 ha for
vineyards, "which could still be cultivated by the existing tenants " whilst the rest (34.5
hectares) will consist of open spaces, rubble walls, and areas retained for ecological
reasons.  The document claims that a survey carried out by the farmers shows that most
of the land is not being intensively farmed, with some 60 per cent being used for fodder
production, generating an income of less than LM 400 a year compared to an average
gross income of Lm3,000 a year for grapes. The critical importance of this fodder
production to the livestock industry as shown during the foot and mouth crisis is thus
ignored.

If indeed, upgrading of agricultural land requires investment of LM 15,032 per hectare,
(the document's figures for the vineyard segment) then the upgrading of the entire
perimeter for vineyards would cost  LM1,082, 352 - a sum way below what AXH
owes to the state (debts to state owned entities etc)

While the document states that biological wine would be produced (a very questionable
assumption) on the 15.3 ha. perimeter of the golf course, yet measures to prevent
pesticide drift and fertiliser leachate into groundwater from the golf course into the
vineyard area should be described. The competence of the developer, or the need to
experiment with 'new varieties' or mount a gene pool within the proposed vineyards are
assumed as given. Surely these functions are already being/could be carried out by the
Government Farm and/or local vintners

In conclusion, the Front urges the immediate withdrawal of this project, and its
replacement by a 10-year agricultural development plan to upgrade the area
concerned into a site for organic, sustainable agriculture producing high quality
grapes and other products.
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