MANOEL ISLAND PRESS CONFERENCE

In June 2020 the Environment and Planning Review Tribunal (EPRT) upheld an appeal by Flimkien għal Ambjent Aħjar against Outline Development Permit PA 9407/17 for the development of Manoel Island.

This was on the grounds that one of the consultants engaged by MIDI plc to conduct the project’s Environmental Impact Assessment (EIA) had been engaged repeatedly by MIDI plc on its Manoel Island projects which constitutes a major conflict of interest.

As a consequence of this conflict of interest the tribunal declared the EIA report to be null and void (null fl-intier tiegħu) and demanded that the EIA report had to be submitted afresh (mill-ġdid):

The Archaeological Society Malta, BirdLife Malta, Din l-Art Ħelwa, Flimkien għal Ambjent Aħjar, Friends of the Earth Malta, Grow 10 Trees, Inħobbu l-Gżira, Isles of the Left, Moviment Graffitti, ORCA, Ramblers Association of Malta, ROTA, Tuna Artna Lura, highlight the importance of ERA respecting the EPRT’s call for a fresh EIA report to tackle the shortcomings noted in the annulled report.

Among the shortcomings there were the following:

Lack of a Health Impact Assessment. The proposed project will increase traffic congestion along the Strand exacerbating the serious traffic problem. Additionally, reclamation of land for the Yacht yard will bring the toxic materials of its industrial area much closer to people’s homes;
The traffic count was not carried out, yet estimates were presented for the years 2025 – 2030. These traffic generation estimates were calculated at 80% below the standard recommended by the PA circular 1/15, therefore traffic at the junction has not been correctly estimated and an air quality report cannot be drawn up accurately.
No study was made on the impact of expected 20,000 trips of heavily laden trucks passing through Gzira transporting excavation rubble. MIDI themselves admit that the trucks to be used are old and heavily polluting; while this is ‘temporary’ the medical problems triggered by pollution are life-long and life-threatening.
Lack of a Social Impact Assessment. SIAs are now recommended by the Planning Authority guidelines. It is to be pointed out that Foster + Partners, MIDI’s architects, stated that the project will bring gentrification to Gzira, driving up property prices;
The flawed visual impact assessment did not assess the huge impact on the Gzira waterfront by the proposed land reclamation, the new larger and higher bridge, the large roundabout to be built at ix-Xatt and the destruction of the widest part of the Gzira promenade – the only open space for social gatherings in Gzira;
The views across the harbour from Gzira towards Valletta and the Floriana bastions will be blocked, yet while the lesser impact on Valletta views from Sliema and Ta’ Xbiex was shown, the Visual Impact Assessment ignored the significant impact on views from Gżira to Valletta;
The removal of the only slipway in the whole of Sliema and Lazzaretto creek: the facilities for yacht owners are being expanded at the expense of small boat owners and amateur fishermen;
The land reclamation and the construction of a breakwater are expected to increase wave activity in Sliema creek and especially in Gżira.
Archaeological deposits and features, particularly ancient underwater rock-cut features that are also significant indicators of sea-level change, are threatened by the proposed works and have not been properly evaluated. Additionally, the seabed along the Lazzaretto is characterized by a long history of dumping of cultural material, reflecting the lifespan of the Lazzaretto. Systematic surveying and excavation PRIOR to granting any permit is the only way to safeguard the archaeological potential there and around the entire island and offshore areas. Simply monitoring underwater dredging works would be completely inadequate, and would risk losing a huge amount of archaeological evidence.

The environment and heritage groups note that the revised outline planning permission PA 9407/17 that was approved on the basis of the nullified EIA is also null, and so are the full development permits* that were granted by virtue of the same outline permit, as well as any procedures regarding other pending full development applications conducted to date for the same site. The eNGOs call upon the Planning Authority to reassure the public that, in light of the Tribunal’s ruling, all these permits and applications pursuant to the nullified EIA have also been nullified, and that the respective applications will need to be subjected afresh to the full scrutiny of the planning process, including the public consultation periods established at law.

The groups reiterate that this is not a choice between the 1999 and the 2019 Masterplan. Both plans are detrimental to the heritage and environment of the whole North Harbour Area as well as to the well-being of residents living there, also due to cementification of Malta’s scant unbuilt land and the destruction of trees which has already begun.

This campaign is about retaining Manoel Island as a green oasis of peace and tranquillity in the centre of Malta’s overdeveloped and overpopulated area of Msida, Gzira, Ta’ Xbiex, Sliema, St Julian’s,San Gwann and Swieqi. A parliamentary petition promoted by Inħobbu l-Gżira gathered almost 10,000 signatures in a short period of time, both online and on paper.

We say yes to a Manoel Island Heritage Park for the enjoyment and benefit of all.

– The Archaeological Society Malta – BirdLife Malta

– Din l-Art Ħelwa – Flimkien għal Ambjent Aħjar

– Friends of the Earth Malta – Grow 10 Trees

– Inħobbu l-Gżira – Isles of the Left

– Moviment Graffitti – ORCA

– Ramblers Association of Malta – ROTA

– Tuna Artna Lura

Excerpts from the EPRT decision:

“Apparti li jkun doveruż fis-sodisfaċiment tat-Terms of Reference tal-Awtoritá, il-Perit … kellu primarjament ikun doveruż fis-sodisfaċiment tal-prinċipju li jevita kull dehra ta’ bias, iktar u iktar meta dan il-prinċipju huwa espressament stabbilit fir-regolament 36(1) tal-L.S. 549.46 ċitat supra.

Izda minflok ma osserva dan il-principju, l-Perit għażel li jiddikjara illi:

“I, ______, hereby declare that, I have no personal or financial interest in the proposed development. Moreover, I declare that I am not in any way associated with any individual, company, association or grouping that has any direct or indirect, personal, professional or financial interest in the proposed development.”

It-Tribunal irid joqgħod kawt illi ma jaqbiżx dawk li huma l-kompetenzi tiegħu, iżda jibbastalu jgħid illi dik id-dikjarazzjoni kienet waħda li ma għandiex mis-sewwa”

In consequence to this the EPRT declared: –

“l-istess rapport tal-EIA huwa null fl-intier tiegħu stante li ma twettaqx kif suppost u b’mod konformi mar-regolamenti u l-liġijiet suċitati. In vista ta’ dan, it-Tribunal sejjer jibgħat l-atti lura mill-ġdid lill-Awtoritá sabiex jiġi sottomess ir-rapport ta’ l-EIA mil-ġdid.”

* PA 9407/17: Amendments to PA 02135/94 for the Manoel Island Master Plan, including: Change in building configuration and increase in open spaces to achieve a better balance between built-up and open area, Reduction of 8,000 sq.m floor area of already approved development resulting from a decrease in massing, increase in residential component, decrease in commercial component and removal of offices, Re-design of access to Manoel Island and re-organisation of parking areas and berthing facilities, Alterations to breakwater and Restoration of the existing Pay Office and relocation of the Guard House, previously marked for demolition. PA decision reviewed by Appeals Board / EPRT.

7781/18: Clearing of site including uprooting of trees, demolishing of existing buildings whilst retaining St George’s chapel and customs house. This application has been approved by Planning Board / Commission.

PA 8373 / 18: Formation of containment along new quay line and reclamation within the contained area using inert material from nearby excavations (Currently ‘suspended’, but past public consultation stage)

PA 8605/18: Excavation of site to level +0.50m as per approved outline application PA 9407/17 Planning Authority decision reviewed by Appeals Board / EPRT

PA 8773/18: Proposed football pitch, underlying sport facilities and reservoir, clubhouse, parking and access roads as per approved outline application PA 9407/17. This application has been approved by Planning Board / Commission.

PA 9942 / 18: Excavation of land area, dredging works and construction of new quay walls as per approved outline application PA 9407/17 (this would have a very severe impact on the submerged features. Currently ‘suspended’, but on 20 Feb 2020 applicant asked SCH to approve extent of dredging)

PA 10840/18: Upgrading of current quay and marina facilities with an increase in the number of berths. This application has been approved by Planning Board / Commission.

PA 09941 / 18: Formation of breakwater 100m long (currently ‘suspended’. Likely to have a significant impact on underwater deposits along Lazzaretto that were overlooked in EIA)

Date: 15 October 2018 Our Ref: PA/07781/18 DAC Meeting No 132 – 10/10/2018

The Committee considered architect’s response at doc. 51 in view of which it is amending its previous minute (46) as follows: “The Committee considered drawings 1 & 21 and before giving its opinion would like an extension of the photographic survey to show in the interiors of the buildings being demolished. It is also suggested that the existing vegetation should be retained until a comprehensive project is drawn up to avoid needless uprooting and replanting.”