Published on The Times of Malta on Sunday 30th September, 2007 by Alan Deidun.Hondoq concerns
The following is a continuation of the concerns expressed by Nature Trust in connection with the Hondoq ir-Rummien project Environmental Impact Assessment. I hope that such a review is met with some constructive feedback, rather than criticism.
Employment figures projected in the Farrugia Report are highly speculative. For example, it lists 1,980 jobs for hotel operations after the 11th year, by which time the local and regional tourism scenario might have changed drastically.
Analogies with other Gozo-based hotels show that five-star accommodation is not necessarily also in demand. Also, how was it calculated that there would be 182 jobs at the commercial centre? This is detached from any major residential area; hence, it is difficult to assign such a high figure to this centre.
Excluding the 50 jobs to be generated by the marina operations (and these will be fully available only after the 11th year), all other jobs (e.g. in the construction sector) will be terminated after the fifth year.
It has been admitted that the "supply for residences is much greater than demand". So why is there a need for 200 units? Within the same section, it is 'unlikely' that manpower would need to be imported. This does not sound very convincing.
Again, by self-admission, current demand for five-star hotel accommodation is weak and the proposed development will not help in this respect (those in favour of the project rebut this by saying that the 'hotel is part of an integrated project unique to Gozo') and mentions San Lawrenz and Ta' Cenc as other five-star properties in Gozo, without saying that part of San Lawrenz has been converted into apartments.
The same section states that cash flow is expected to be positive only after the seventh year, with a negative cash flow in the first four years. This raises doubts over the feasibility of the project.Additional concerns include:
No guarantees (especially financial ones) to preclude the project's future expansion to the west and east of the delineated footprint, since this land is also owned by Gozo Prestige Holidays.
The preamble refers to the number of berths in France and Spain, two hot spots of coastal urbanisation, where a large percentage of the brown algae Cystoseira spp has been lost.
'Win-win' scenarios are frequently referred to in the report (e.g. preamble, p. 8). This would involve filling in the disused quarry and its development into an ecotourism venture (such as has been done with Limestone Heritage, Siggiewi) with no need to develop a yacht marina or other tourism development. Such infilling is no longer subject to an EIA, by virtue of recent amendments to EIA regulations.
The report claims that the swimmers' zone will be extended. There is no need for this, since a simple safeguard of the existing zone would suffice.
It also states the "bathing area will be protected from boats". Physically it will be, but how can anti-fouling paint, oil and other discharge fail to get into the bathing area? Will marina operators allow access only to boats certified to use prescribed anti-fouling paints for example?
The marina will cater for five berthing spaces for boats up to 45 metres. Their size itself would cause congestion in the immediate vicinity of the marina and their engines can churn up fine particles from the benthos in shallow areas.
Moreover, the financial feasibility is worked out on many assumptions, namely: (a) price of real estate (this might stall in the future); (b) sustained demand by locals; and (c) sustained demand from foreigners. How can one confidently state that 'the turn-over expected is adequate'?
In Chapter 4, the results of two different surveys are reported (a Three Villages survey and an All Gozo Survey) but no reference is made to the referendum held for Qala residents by the local council, despite the fact that this village has a vested interest in any decision.
It is not stated who conducted these surveys. The way survey results are reported is also flawed - e.g. "of the village residents, just 38.9 per cent said they disliked the marina". Does this mean that 61.1 per cent of respondents favour the marina? What about respondents who declined to answer or were non-committal? Such statistics are rarely provided in the report.
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