Hondoq project recommended for refusal by Directorate of Environment Protection

The proposed development at Hondoq ir-Rummien is being considered objectionable by the Directorate of Environment Protection and it is recommending the project for refusal.

The directorate said it reviewed and assessed the information for the development proposal, including the environment impact assessment and appropriate assessment reports.

Mepa had requested an environment impact statement to cover the applications for the construction of a destination port comprising hotel, yacht marina and tourist village and for the exploitation of mineral resources from an existing quarry at Hondoq ir-Rummien.

The project core was proposed to consist of:

a deluxe 5 star 110-bedroom hotel with all facilities;

20 self catering villas;

60 apartments serviced by the hotel;

203 permanent tourism accommodation - apartments, maisonettes and bungalows;

1,249 underground parking spaces subdivided as follows: 320 spaces under the hotel, 90 spaces reserved for the public along the foreshore, 600 spaces on the west area, 199 spaces and 40 spaces on other parts of the development;

The village centre was proposed to comprise a small church/chapel, administration offices, some shops and restaurants;Other small commercial outlets scattered through the village lanes and alleyways, providing artisans and artist studios, boutiques, local small restaurants, a newspaper shop, and other similar small scale activities.

This included:

10 Retail Units;

5 Dining Facilities;

Yacht Marina for approximately 100 to 150 berths depending on the dimensions of the vessels calling at the marina. The marina would be enclosed by an inflatable rubber dam and no dredging was proposed;

Marina foreshore of 540m accessible to the public;

Refurbishment of jetty and slipway to make the swimming area more accessible; and

Enhanced public amenities including development of a hard surface which would be lowered closer to the sea level, improved kiosk facilities, an underground car-park for around 90 cars, a public shower and toilet facilities, upgrading of the existing slipway facilities and a terraced soft and hard landscaped area.

The directorate found that:

The assessment was unduly biased towards the Hondoq ir-Rummien site.

The author clearly indicated his overt bias towards the site using expressions such as, "The site cries out to be developed" and "Developing a marina at this location offers a win-win situation";

The sites were compared on an unequal footing since the option at Qala essentially was excavated within the quarry (thus having no marine footprint) whereas all other options considered involved major works at sea. Similar alternative options in all sites should have been compared;

The proposed layouts at Mgarr harbour and Marsalforn may not represent the layouts exerting least impacts on the environment or current land-uses (such as bathing) within the area; and

Although the assessment seemed to discard the extension of the existing marina at Mgarr harbour immediately, this was proposed by the approved Gozo and Comino local plan, and should have been explored further.

The EPD concluded that having reviewed and assessed the information for the proposal, including the EIA, considered the development proposal as objectionable, on various counts.

The Alternative Site Assessment report was unduly biased in favour of Hondoq ir-Rummien. "The EPD cannot accept the results of this alternative assessment which represent a foregone conclusion and which also run counter to other nationwide studies carried out."

The Appropriate Assessment report submitted in line with the requirements of the EU Habitats Directive did not provide sufficient comfort in excluding impacts on priority habitats listed. The development would thus potentially give rise to significant impacts and could not be considered further.

The EIS had predicted a number of potential impacts on the environment as a result of the proposed development, some of which had residual impacts of major significance. The mitigation measures proposed in the EIS were aimed at minimising the impacts, however, major negative short term and residual impacts were identified in the EIS.

A number of impacts were also considered residually of major significant by the EPD, even though these were not identified in the EIS. Such impacts were either insufficiently addressed in the EIS or downplayed through unrealistic/unenforceable conditions.

These included traffic-related impacts during construction, including noise and emissions and impacts on water quality.

The directorate noted that the project could not be accommodated within the confines of the quarry and with the currently existing road network without significant impacts.

The excavation and operation of the marina were also of particular concern.

"The proposal is for a major urban-type development which is being proposed ODZ and in an area which should be kept free from even small-scale urban development.

"In the EPD's opinion, there is no overriding justification in terms of net environmental improvement or similar public benefit (rather, various negative impacts are expected, as indicated in this report)."

The directorate further noted that any claimed benefits of the project could be addressed without the need to accommodate new development, such as through simple measures aimed at improving the site's amenity, removal of alien elements namely the accumulated quarry debris, distillation plant, concrete quay and coastal debris, and regeneration of the former natural/ semi-natural habitats through afforestation or recreation of valley and improvement of amenity for informal recreational purposes.

"Accordingly, a refusal of the proposal is recommended."

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