Impact study on golf course "flawed"

www.timesofmalta.com
10 August 2002

The Front Kontra l-Golf Course said the environment impact study on the
proposed golf course at Tal-Virt� points out the impacts that the
proposal would have if the application were 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.

In its comments to the Malta Environment and Planning Authority about the
EIS, the front said that while the central benefit promoted by the EIS is
an estimate of an annual addition of Lm2.8 million to Malta's GDP, on the
basis that the proposed golf course could attract 12,000 extra five-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 or of measuring social disbenefits,
the front said.

The EIS had also failed to present a risk assessment on the earnings
figures for the proposed golf course, it added.

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 or weigh
them against any possible positive impacts.

This is a major flaw in the study and the front contends that the major
negative impacts far outweigh any possible positive impacts, the front said.

In general key economic 'forecasts' are not derived from standard
statistical procedures, but are based on speculation, the front said.

The front said it believed that the farmers have a right to continue to
farm the land in question and would like to see the site upgraded and
improved.

The economic arguments in favour of the project are not convincing and
are primarily based on an illogical premise: that if there are 44 golfers
per 1,000 Britons, then 44 per 1,000 of our tourists will play golf. This
is absurd.

The front said that the amount of water that such a golf course needs is
too high for our scarce and expensive resources.

"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 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," the
front said.
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