| Comments on Verdala Golf Course and Country Club Environmental Impact Statement PA 4179/99 Front Kontra l-golf Kors July 2002 Executive Summary: Introduction: The EIS points out the impacts that the proposal will have if the application is approved, but no attempt is made to measure these impacts and compare positive against negative ones or arrive at an overall cost-benefit result which covers economic, social and environmental aspects. Whilst the central benefit promoted by the EIS is an estimate of an annual addition of Lm2.8 million to Malta�s GDP is put forward on the basis that the proposed golf course could attract 12,000 extra 5 star tourists (derived from the Deloitte and Touche study on the Verdala Hotel 1999), no comparative assessment is made of the costs to the Maltese economy nor the social and environmental costs of the project. The EIS has therefore omitted to use standard techniques of cost benefit analysis, of environmental valuation (willingness to pay etc) or of measuring social disbenefits. The EIS has failed to present a risk assessment on the earnings figures for the proposed golf club. The EIS admits major negative impacts on the farming community; agricultural land; archaeological features; landscape and visual amenity; ecology � but no attempt is made to give value to these impacts (as suggested above) or weigh them against any possible positive impacts. This is a major flaw in the study and the Front Kontra l-Golf Kors contends that the major negative impacts far outweigh any possible positive impacts. In general key economic �forecasts� are not derived from standard statistical procedures, but are based on speculation. We show below in these comments how overstated the expected economic benefits as put forward in the EIS are. Some things cannot be measured in financial terms. We say they are priceless. What the golf proposal intends to do is remove from certain people what to them is priceless. We find that immoral and unacceptable from any point of view. Moreover the project is predicated on the disavowal by the Malta government of an international treaty signed in 1991 with the Holy See. For a country that is 99% Catholic, such as disavowal would go against the religious affiliation of the Maltese People. Policy: The Malta Environment and Planning Authority Board is meant to assess applications in line with Structure Plan Policy. The Structure Plan policy relevant to golf courses specifically excludes golf courses from good quality agricultural land. The land under consideration is good quality agricultural land. POLICY TOU 12 of the Structure Plan indicates as follows: "Any golf courses should be located where: 1. It can be accommodated without adverse environmental impact or loss of good quality agricultural land��. �..Potentially suitable locations are those where positive environmental benefits can be achieved by utilising derelict land or land requiring major environmental improvements." The land in question is not derelict or requiring major environmental improvements. This fact was not properly considered in the EIS. The fact that the proposal is so clearly against both the words and the intentions of Structure Plan policy should be enough to convince the MEPA board to refuse the project, but there are several other important reasons why this should be done. Social: The EIS does not contain the contribution of a sociologist or an anthropologist. We find this to be a major defect. The major negative impact of the proposed golf course will be the displacement of farmers from the land that their families have worked for generation. The value of their attachment to that land cannot be easily estimated, but their feelings emerge clearly enough in the EIA and were certainly evident at the EIS public hearing in Rabat on 23 July. For a variety of reasons we consider that value to be �priceless�. The farmers oppose the project very strongly and the impacts on their lives should they be removed from the land have not been properly looked into. To approve the golf course would be socially unjust since it would gravely damage the social fabric of the area and the lives of Maltese farmers. It is not only the farmers that work the site that will be affected, but all Maltese farmers. If this application is approved that will put each and every farmer on edge, for what they knew to be solid security for life would be turned into jelly. No Maltese farmer will sleep comfortably knowing that the land where they work could be taken away from them by people who do not own, have no feeling for, and no legal right, to that land. Socio-economics: The gain to Maltese society from the project has been over estimated. The feasibility of the project remains very much in doubt. The economist who prepared that part of the study has based his calculations on statistics and logic that leave much to be desired in terms of standard statistical analysis and forecasting techniques. According to the Federation Francaise de Golf, 44 of every 1,000 UK residents are registered golf players. It is then assumed that if Malta attracts 448,000 tourists from the UK then 19,712 or 44 per 1,000 will constitute the �latent� demand for the proposed golf course. This is completely absurd and an indication of lack of scientific background. Even if it is true that 44 from every 1,000 British residents are golfers there is no proof nor statistical evidence based on a sampling survey to indicate that these are coming or will come to Malta. By that same reasoning 20,000 British visitors must already be playing golf at the Marsa club. We know that this is not correct. The only way to find out how many potential golfers are coming to Malta would be to ask the tourists that come here. One high standard golf course in Malta will not make these islands a golf destination (this is admitted in the EIS), and neither will they become a five star destination, especially in our one (if that?) star environment. According to the ministry of Tourism�s Conference and Incentive Tourism Report, 1999, obstacles to increased C&I tourism based on a survey of Maltese Destination Management Companies, were not the absence of a world class golf course (not mentioned), but bad roads, rude and inefficient service by hotel staff, overpricing of conference equipment, lack of VIP arrival and check in at the airport, poor air communications with many European centres and the lack of access to historic and public sites for organising events. The cost of to government of the proposed development including the subsidised water that would be provided has not been considered in the estimates. Legal: The legal basis for the Planning Authority's request for the preparation of an Environmental Impact Assessment is disputed. The EIA and in particular the document under review, confirm the obvious flaws of the application and its fundamental violation of structure plan policies, the GCDM-PP and the spirit and letter of the Ecclesiastical Entities Act. In entertaining the application and in requesting the preparation of an EIA, the Planning Authority has subjected the applicant to considerable delay and expense and has provoked a similar expense of resources by the objectors. The irremediable flaws in the application were obvious prima facie and the further processing of the application is unjustified by any means. Sustainability The project does not fit into any sustainability scenario. The MEPA and the consultants have not tried to include a measure of the project proposal in terms of sustainability targets. The MEPA does not plan according to any recognised sustainability targets or concepts. Each application is studied on its own merits and the big picture of our small islands is forgotten. Malta has lost and continues to lose its long-term assets: natural countryside and landscape, agricultural land and coast at rates that can only be described as alarming. The area of agricultural land being lost to development is not sustainable. This project certainly cannot be considered to be sustainable development. Agriculture: There is no doubt that among the major negative impacts of this proposed development would be the loss of 7.2sq km agricultural land as well as off-site impacts on surrounding agricultural areas viz. due to impacts on ground water flows and their contamination by agro chemicals, soil quality and biota, pesticide/herbicide drift, resident wildlife. This loss goes against Structure Plan policy and the objectives of the Ministry for Agriculture which both indicate the duty to protect and improve agricultural land. The land in question is large and the agriculture of high quality and the EIS considers a �zero option� but does not consider soil restoration and upgrading of agricultural activities which would take place as a result of possible EU Membership, nor the area�s potential as a centre for high value, environmentally beneficial organic farming whether Malta joins the EU or not. From the agricultural point of view if the project is approved it would be a major step backwards. Ecology: On the brink of Malta�s possible accession to the EU it is hard to understand how any authority could approve of a project which will be so destructive from the social, ecological, hydrological and agricultural point of view. There is no doubt that the proposed golf course will have major negative impacts on the fauna and flora in the area. There is no doubt that such a proposal will have a negative impact on the ecosystems on a large area of land which will stretch beyond the perimeter of the proposed golf course. An ecosystem that has developed over thousands of years and one that is appreciated by the farming community and all others that have an emotional attachment to that land. Water: We find it unacceptable that such large volumes of scarce good quality water will be offered to the developer. It is also shocking to learn that the WSC is prepared to offer such water when it never came to the assistance of farmers who have needed more water for generations. We are also unconvinced that the main sea aquifer will not be affected by pesticides and fertilisers from the golf course. Our arguments are set out in more detail in the appendix. The EIS does not contemplate the impact of climate change on rainfall patterns and soil moisture content. Climate change has already started (Intergovernmental Panel on Climate Change, 2000) and highly water-intensive ventures are totally at odds with what the Mediterranean region needs to do in order to prepare for an mitigate climate change impacts. Health Working as a Golf Course Superintendent has been found to significantly increase the risk of dying of four cancer types including - brain cancer, lymphoma (non-Hodgkin's lymphoma, NHL), prostate and large intestine cancer. A study was conducted of 686 deceased members of the Golf Course Superintendents Association of America from all U.S. states who died between 1970 and 1992. Brain cancer rates for the Superintendents was found to occur at over twice the national average, while non-Hodgkin's lymphoma also occurred at over twice the national average. Prostate cancer occurred at nearly 3 times the national average and large intestinal cancer occurred at 1.75 times the national average. The researchers stated that a similar pattern of elevated NHL, brain and prostate cancer mortality along with excess deaths from diseases of the nervous system has been noted previously among other occupational groups exposed to pesticides. Alternative sites: No proper scientific study has ever been carried out to ascertain the best site on the island, and the studies carried out were based on choices made by the developer and not those "that utilise derelict land or land requiring major environmental improvements" as is suggested in the Structure Plan. Transport There is no doubt that approving this project will have significant negative impacts on motor vehicle transport in the area. If the project is rejected, the same mitigating measures that are suggested could still be put in place to counteract increases in motor vehicle use that are occurring anyway. Air Quality The authors of the EIS have chosen to purposely ignore what is expected to be a major change in agricultural practices in the coming years. The switch to organic farming free from toxic pesticides etc is already sweeping through Europe and in Malta, on the golf course site, a centre for the promotion of organic farming was set up recently with the farmers who work the land in the area as main promoters. Indeed, several of the farmers are moving in the direction of organic farming and an association to assist such farmers, "Malta Organic Agriculture Movement" (MOAM) was set up not long ago. Cultural Heritage On the cultural level, this proposed development is definitely not reversible. Paragraph 15.80 is particularly unrealistic and/or evasive: the farmers and their families cannot just return to the land they had been uprooted from (possibly) years before. Human beings and their cultures simply don�t work that way: if the land and the whole atmosphere have been changed in their absence, the farming community�s relation with that land and the cultural heritage that developed from that centuries-old relationship will be lost forever, both for the community itself and for the nation as a whole. 3 Conclusion: We must point out that this report may not have covered all the important points about the EIA and we protest at the short time that we were given to prepare our positions. The consultants, who were paid to write the report, took several years to produce something acceptable to MEPA we expect that we should be given more than a mere two months. The report prepared by the consultants included enough reasons as to why the project proposal should be rejected and we have added some of our own. We believe that the farmers have a right to continue to farm the land in question and would like to see the site upgraded and improved, as is the duty of the government. Improving our agricultural produce is a priority of the government even if this would seem not to be the case. The economic arguments in favour of the project are not convincing and are primary based on an illogical premise: that if there are 44 golfers per 1,000 Britains, then 44 per 1,000 of our tourists will play golf. This is absurd. Since we have not been allowed to see other reports used in the study and are unaware of the terms of reference, we find it difficult to comment much further. Suffice to say that we do not find the arguments brought forward convincing. From a social and environmental point of view we feel there is much more to be said than has been written in this draft EIA. We feel that the amount of water that such a golf course needs is too high for our scarce and expensive resources. We feel that the impacts of the golf course would be worse, for the reasons we have outlined above (and in the appendixes), than is being suggested in the report. We also must point out that we are not happy with the social scientist chosen for the sociological study, and we are not happy with his study. We did not find a good evaluation of the advantages and disadvantages of having the proposed golf course. We found much wrong in many of the chapters (as explained above) and the conclusions reached are often not satisfactory. We totally reject the idea that the site will not improve without the golf course on site. However, even without all the arguments that we have brought the golf course should not be approved because it would be in breach of the Structure Plan, and not only in a minor way as is suggested in the report. The proposal would also breach the international agreement between the government and the Holy See. The EIA should never have been prepared as it is clear in the PA�s guidelines to EIAs that the project should have been rejected outright as it goes against Structure Plan policy. This report was prepared with contributions by: Michael Briguglio B.A. Hons, M.A. Harry Vassallo L.L.D Adrian Grima B.A Gen., B.A. Hons., M.A Noel Agius BA Hons, M.A David Pisani AA&D Martin Galea De Giovanni I.D.C.S., IAD, (Manchester) Elisabeth Fiteni - M.S.E.L (Vermont), B.A., Environmental Studies (Connecticut) Julian Manduca B.A. Hons Front economists' advisory group FRONT KONTRA L-GOLF COURSE 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, Inizjamed, Move! Organisation, International Animal Rescue SUPPORTERS: University Chaplaincy, Malta Organic Agriculture Movement, Kopin, Farmers' Central Co-Operative Society http://nogolfmalta.cjb.net |
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