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Press Release 6/9/04

Planning Directorate gives thumbs down to Verdala golf proposal

MEPA's Planning Directorate is recommending refusal of the proposed golf course at Verdala, the Front Kontra l-Golf Kors said today.

"The Planning Directorate is MEPA's official body that gives expert recommendations to the MEPA Board. The environmental, social, economic and planning experts within the Planning Directorate have set out their recommendation for the refusal of the massive development proposal citing 32 planning reasons covering two separate applications, with some reasons repeated.

In DPA Report for Case Number : PA 02871/04 (Ref www.mepa.org.mt ), the Directorate concludes:

" on balance the proposed development is not considered to uphold the principles of sustainable development enunciated in the development planning act, since the negative impacts including amongst others the disbenefits to the farming community by displacement of current farming activities; the high demand for water resources, the significant disturbance to ecological habitats and archaeological remains; are not considered to be balanced by the economic benefits of the proposal."

"The Front Kontra l-Golf Kors welcomes the defence of the principle of sustainable development, and has always maintained that the economic benefits claimed for the project in no way compensate for its many negative environmental and social impacts."

"The first draft of the Environment Impact Statement was rejected by the UK Institute of Environmental Management & Assessment, because it did not agree how the conclusion was reached that advantages outweigh disadvantages. This conclusion was removed from second draft."

"Prime Minister Lawrence Gonzi has been careful to clarify that it should be the experts that decide which sites are suitable for golf and the experts have now decided. We are confident that the MEPA Board will follow the Prime Minister�s train of thought and likewise reject the proposal, which it will consider on Thursday 9th September."

"The Front would also like to clarify that contrary to the claims being made by Angelo Xuereb, almost all the farmers that till the land on the Verdala site have no intention of passing land over to him whether the golf course application is accepted or not. Xuereb has often used tactics in the past to win public support, and we challenge him to publish the names of any farmers he believes will agree to pass on the land they work to him. Xuereb seems to be ignoring the fact that almost all the farmers working land at Verdala had petitioned the Prime Minister, MEPA and the Vatican, stating clearly that they are opposing the golf course proposal."

"The Front would also like to point out that the environment impact assessment that has been presented to the public and upon which people based their support or criticism for the golf course proposal does not cover the entire development that AX Holdings is proposing. The EIA does not cover the proposed high rise business centre with a footprint of 1,080 square metres for example, an apartment block with a footprint of 4,230 square metres, an underground car park and tennis courts. All these were never mentioned in
the public meeting held in Rabat to explain the project to the farmers. Should the MEPA Board approve the project Thursday, the Front will object the decision also on the basis that the public has been misled."

"On Thursday it will be the MEPA�s Board�s duty to decide on a project that the developer himself opposed. Way back in 1991 Angelo Xuereb told the then planning authority that a golf course at Verdala was not possible because: most of the land is privately owned, the land is arable and should be conserved and the buildings will spoil the environment."

"The Planning Directorate, MEPA's experts have spoken and among the reasons for refusal are the following, according to DPA Report for case number : PA 04179/99:

1) The proposed development of the hotel site as a whole, in terms of the scale and nature of the facilities offered, is of an excessive scale and would lead to an overdevelopment of the site. This would not be in the interests of the amenity of immediate and surrounding area. The proposal is therefore unacceptable and runs counter to Structure Plan policy BEN 1.

2) The proposed replacement apartment building and proposed business centre do not relate in scale with its surroundings and would adversely affect the long distance views of this Area of High Landscape Value. The proposal is therefore contrary to Structure Plan policy RCO 4.

3) The site of the proposed business centre and the extension of apartment block lies in a Rural Conservation Area (as designated by the Structure Plan and indicated on the Key Diagram). The proposal does not comply with Structure Plan policy RCO 2 which clearly states that no form of urban development will be permitted within Rural Conservation Areas.

4) The site of the proposed business centre and extension to apartment block lies outside the limits for development defined in the Temporary Provisions scheme for Rabat and so it is located in an area which it is proposed should remain undeveloped and open. The proposed development would run counter to this scheme and would represent unacceptable urban development in the countryside.

5) The proposed development of the business centre and extension of the apartment block conflicts with Structure Plan Policy SET 11, which does not permit urban development outside existing and committed built-up areas. The development does not fall into a category of non urban development which may be permitted outside existing or committed built-up areas in accordance with Paragraph 7.6 of the Structure Plan. The proposed development also therefore runs counter to policy BEN 5.

6) There is no justification for the development of the business centre and the extension of the apartment block as required by Structure Plan policy SET 12. It is apparent that there are no reasons from a planning point of view why the proposed development can not be located in an area designated for development or in an existing built up area.

7) The proposed business centre and extension of the apartment block run counter to Policy PLP 20: (Development Control Guidance-Developments outside built up areas) in which the Structure Plan strategy comprises a blanket prohibition of any form of urbanisation outside areas specifically designated for urban uses in the Plan - ie : existing and committed built up areas and primary development areas.

8) The proposal as a whole would generate a considerable volume of vehicular movements which would have a significant and unacceptable impact on the road network in the immediate area, as well as the arterial road network.

9) The proposal as a whole runs counter to Structure Plan policy TRA 4 and the car parking standards set out in Table A2.5 in the Structure Plan Explanatory Memorandum in that it fails to provide the required car parking spaces. It will give rise to unacceptable additional on-street car parking which would not be in the interests of the amenity of the area and which would exacerbate existing problems of congestion, potential highway danger and vehicular and pedestrian conflict.

10) The height of the proposed buildings exceeds the maximum height limitation
for Rabat. It is therefore incompatible with the characteristics of the area and with the Temporary Provisions Scheme for the area, which seeks to limit height in order to safeguard the general amenity of the area. The proposed development runs counter to Structure Plan Policy SET 8, which requires that the layouts and other provisions of the Schemes will only be reviewed as part of the Local Plans to be prepared for the areas in which the schemes are located.

11) The proposed development runs counter to Structure Plan policy UCO10 in that
it would adversely affect views of the Urban Conservation Area and detract from the traditional urban skyline.

12) The proposed development of a golf course conflicts with Structure Plan Policy TOU 12, which identifies potentially suitable locations for golf courses as derelict land or other land requiring major environmental improvements and which stipulates that such developments be located where they can be accommodated without adverse environmental impact or loss of good quality agricultural land. The site of the proposed golf course is located within an Area of Agricultural Value, as well as an Area of High
Landscape Value. Furthermore, the site lies on the side of a valley and overlies the upper 'perched' aquifer of central Malta. Therefore, the location of the golf course on this site does not comply with the main locational criteria for such development set out in the Structure Plan.

13) The proposed development of a golf course conflicts with the approved Policy Paper 'Golf Course Development in Malta' which endorses the Structure Plan locational criteria for golf courses.

14) The proposed golf course does not fall within one of the categories of development, namely structures or facilities essential to agricultural, ecological or scenic interests, which may be permitted in Rural Conservation Areas where they meet the principles and criteria set out in Structure Plan policy RCO 4. The proposal is not essential to, nor does it enhance agricultural, ecological, or scenic interests.

15) The proposed development of a golf course on this site is contrary to Structure Plan policy AHF 1 which seeks to safeguard good quality agricultural land so as to encourage the agricultural industry, as well as conserve the countryside land resource for the benefit of future generations. The Department of Agriculture considers the land on which it is
proposed to locate the golf course to be good quality agricultural land. The land is fertile, naturally irrigated and still under cultivation.

16) The proposed development of a golf course conflicts with the emerging Draft North West Local Plan which prohibits the development of any building/activity within Areas of Agricultural Value which is not essential to the needs of agriculture and any building/activity, even that related to agricultural practice, which would adversely affect water supplies, soil and/or landscape. The proposed golf course is not related to agricultural practice. Furthermore, the remodification of the terrain of the site, the
clearing, relocation and new planting of vegetation, the infrastructural arrangements necessary to operate the golf course, etc. will affect the water supplies, the soil profile and the landscape within the site, as well as a considerable area of land outside the site boundary. Mepa's own Nature Protection Unit cited the action of alien grass on biodiversity and potential harm to the nearby eco-systems.

17) The proposed development of a golf course is contrary to Structure Plan policy RCO 27 which prohibits the excavation of significant amounts of Blue Clays given the serious adverse effects this will have on groundwater systems and valley side landscapes. The proposed remodelling of the terrain of a valley side for the golf course involves modification of the existing soil profile on a scale which may be potentially detrimental to the features described above.

18) The site of the proposed golf course is located on the side of a valley and a golf course does not fall into one of those categories of development permitted in this type of location. The proposed golf course is therefore contrary to Structure Plan policy RCO29, which seeks to prevent soil erosion and encourage the conservation and management of water resources. The Department of Agriculture has pointed out that the trampling of golfers would lead to soil compaction - another impact that would be very difficult
to reverse.

19) The site of the proposed golf course overlies the upper perched aquifer of central Malta. The development of this site as a golf course may lead to the contamination of the aquifer and so the proposal does not comply with Structure Plan policy RCO 28, which provides for the protection of important water catchment areas. Moreover Malta Resources Authority does not accept the developer's claim that pollution of the mean Sea Level Aquifer would be reversible.

20) Structure Plan policy RCO 4 provides that, particularly within Rural Conservation Areas, areas of scenic value will be protected and enhanced. The site of the proposed golf course lies within an Area of High Landscape Value, as defined in the approved North West Malta Landscape Assessment Survey. The proposed golf course would detract from this, and so it would conflict with Structure Plan policy RCO 4.

21) The proposal would result in the demolition/significant alteration of rubble walls and so runs counter to Legal Notice 160 of 1997 - Rubble Walls and Rural Structures (Conservation and Maintenance) Regulations, which declares rubble walls and non-habitable structures as protected, in view of their historical and architectural importance, their contribution to the character of rural areas, their affording a habitat for flora and fauna, and their vital importance in the conservation of the soil and of water.

(The full report is available at www.mepa.org.mt)

Mike Briguglio
f/ Front Kontra l-Golf Kors