Dwejra: Tribunal dazzled by delight

July 8, 2019

 

Monday, 8th July 2019

Alfred Baldacchino

A recent decision by the Environment and Planning Review Tribunal has overturned a Planning Authority decision, ordering it to approve a permit for the extension of a restaurant, the installation of light and increasing the number of tables and chairs in an EU Natura 2000 site in Dwejra.

Without any doubt, this throws a lot of light on the official political disrespect, disinterest, exploitation and disregard for the environment as well as national and international legislation.

Dwejra is a Special Protection Area and a Special Area of Conservation with regard to biodiversity, in line with the Birds and Habitat Directives. It is part of the EU Natura 2000 network because of its importance to the EU.

The Malta Environment and Resources Authority is the responsible competent authority recognised by the EU. Competent national authorities are those entitled to give authorisation or consent to a plan or project in Natura 2000 sites.

 

Dwejra is the best remaining site on the islands for astronomical observations. Photo provided by the Physics Department and the Institute for Astronomy and Space Sciences

Dwejra is also designated as a ‘dark sky heritage area’ in the Gozo and Comino Local Plan.

Article 6 of the EU Habitat Directive can be regarded as a key framework for giving effect to the principle of integration with regard to the management of the protected areas in a sustainable way and sets the limits of activities that can impact negatively on protected areas.

In an international context, Article 6 also helps to achieve the aims of relevant international nature conservation conventions such as the Berne Convention and the Biodiversity Convention (Malta is a party to both), while at the same time creating a more detailed framework for site conservation and protection than these conventions themselves do.

Where assessment is required by Article 6 (3) it takes the form of an assessment under Directive 85/337/EEC (on the assessment of the effects of certain public and private projects on the environment), where public consultation is necessary.

In this context, it is worth mentioning the possible longer-term implications of the Aarhus Convention, which emphasises the importance of public consultation in relation to environmental decision-making.

According to Habitat Directive’s article 6 (2) “any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site’s conservation objectives”.

The Environment and Planning Review Tribunal has completely undermined Malta’s obligations at EU level

“In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of the Habitat Directive (para 4), the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.”

An EU Commission publication dated 2000, Managing Natura 2000 Sites – The provisions of Article 6 of the Habitats Directive 92/43/CEE, explains that “member states shall take appropriate steps to avoid, in the special areas of conservation, (like Dwejra) the deterioration of natural habitats and the habitats of species as well as disturbances of the species for which the areas have been designated, in so far as such disturbance could be significant in relation to the objectives of this directive”.

The article also states that “member states shall take appropriate steps to avoid, in the special areas of conservation, the deterioration… as well as disturbances…” of species and habitats for which the sites have been designated and should also be implemented if necessary outside the sites. (Article 6 (2)).

Disturbances include, among others, noise and source of light.

The intensity, duration and frequency of repetition of disturbance are, therefore, important parameters and can be regarded as a significant disturbance.

Even a plan or project that includes conservation management among its objectives may still require assessment.

Although the management plan for Dwejra has long been drawn up with the help of EU funds, and approved by the EU, it is still gathering dust on the ministry’s bookshelf.

There is still no administrative set-up for its implementation, enforcement, management, administration, education and no stakeholders are involved, as obliged by the management plan.

The Environment and Planning Review Tribunal has completely undermined Malta’s obligations at EU level. Can the ERA contest such a decision in court, especially when the Minister for the Environment has publicly stated that he does not agree with this permit? If not, does this decision mean the ERA is impotent as a competent authority responsible for EU obligations when confronted by such a tribunal?

Do the citizens have to refer the matter to the EU to achieve what the ERA should be on the front line defending on their behalf?

This is definitely another decision reached by hand-picked political academics,whose short-sighted decision embarrassed Malta with regard to its international obligations.

If such a tribunal is independent, then the responsibility has to be carried by those people involved in such a decision and who have completely ignored and defied the decision made by two national competent authorities and also the public with great political and environmental consequences.

It is high time the EU DG Environment investigates how Natura 2000 sites in Malta are being brought to disrepute.

aebaldacchino@gmail.com

alfredbaldacchino.wordpress.com

Alfred Baldacchino is a former assistant director of the Malta Environment and Planning Authority’s environment directorate.

related articles:

Dwejra: Gone with the wind

A window pain for sure

Sifting solidified sand at Dwejra

 

aebaldacchino@gmail.com

alfredbaldacchino.wordpress.com


More biodiversity destruction with EU funds – confirmed

March 10, 2019

Alfred E. Baldacchino

Sunday, 10th March, 2019

Following my latest blog of 4th March 2019, regarding the destruction of Maltese biodiversity by the Ministry for Transport, with the use of EU funds,  Infrastructure Malta, in the portfolio of Dr Ian Borg, the Minister for Transport and Infrastructure, have issued a statement saying that the works being carried out are being done “within existing road footprint” and ” “in line with applicable road works permits”.

On the other hand, the Environment and Resource Authority in its press statement  dated Tuesday 5th March, 2019, confirmed that the government road agency’s work had been carried out without the necessary permits, resulting in “environmental destruction”.

ERA’s press release confirmed that: Because of these works, it resulted that there is the destruction of the natural habitat suffered from the laying of construction material on the land which before was colonised by natural vegetation; leading to a physical change of the valley and the water course’s profile.

Besides, these works are all taking place without the necessary permits from the Authority (ERA).

For ease of reference to those who want to see for themselves, this is the link of the ERA press release.

I am sure that the Ministry for Transport officials have brought this ERA statement to their Minster.

Minister Ian Borg knows the site very well because it is in his constituency. A visit to the site, would at once reveal that the Ministry for Transport agency Infrastructure Malta’s press-release is totally incorrect, not only scientifically, factually, but also politically.

The gutter on the right shows to what extent the rich valley bed has been reduced to. And according to Ministry for Transport, this is a footprint of the once farmer’s country path. 

By all means let the farmers be given a helping hand, but not by widening a country path to two or three lanes. And certainly not by obliterating a valley bed, so rich in indigenous Maltese biodiversity, and disrupting the hydrology of the area, impeding the contribution to the water table and the farmers’ wells, if this is of any importance to the Minster’s experts in road widening.

Neither is it in the farmers’ interest in having their rubble walls destabilised, which eventually will be so detrimental to them.

Which professional architect, (unless of course over-ruled), would plan, and approve such damaging works which will lead to the eventual destruction of the rubble wall, and say it is in the interest of the farmers.

Renowned botanists friends of mine have confirmed that a rare indigenous protected tree was destroyed and annihilated, in the parts where the works were carried out by the Ministry for Transport.

A number of environmental NGOs and individuals have also all expressed their concern, dismay and anger against such damaging works by this Ministry.

I am sure Minister’s Borg ‘experts’ have drawn his attention to a number of EU Directives all of which have obligations, even with regards to the works in valleys. Just in case they did not, I would like to draw the Minster’s attention to the following:

  • Valleys are all subject to the EU Water Framework Directive. The local Competent Authority recognised by the EU for surface water in the Maltese Islands is The Energy and Water Agency, in the portfolio of the Ministry for Energy and Water Management, Joe Mizzi. Has the Ministry for Transport discussed the hydrological impacts of their works with this Ministry?
  • Biodiversity management, protection and enforcement is under the responsibility of the Environment and Resources Authority – ERA, in the portfolio of the Minister for Environment, Dr José Herrera, mainly through the EU Habitat Directive, and other International Conventions. Has the Ministry for Transport discussed the impact of their works with this Ministry. Definitely not, according to ERA itself.
  • Wied l-isqof is adjacent to the Natura 2000 site of Buskett and Girgenti. This means, according to the EU Habitats Directive, that any works even outside the boundary of the Natura 2000 site which can have an impact on the Natura 2000 site has to be discussed with the Competent Authority recognised by the EU, that is, ERA. Has Transport Malta discussed the negative biodiversity impacts of their works with this Ministry? Definitely not.
  • The newly appointed AmbjentMalta, is also responsible for valley management. It is also in the portfolio of the Minister for the Environment. Has Transport Malta discussed the impact of their works with this Ministry. Again definitely not as also confirmed by The Ministry for the Environment itself.
  • I would not like to mention the Planning Authority because as far as I am concerned, this authority, coincidentally in the portfolio of Dr Ian Borg Ministry, is more of a rubber stamp than anything else, with only paper professionalism not reflected in decisions taken.
  • The question is: from whom did the Ministry for Transport obtain the necessary permits as stated in their press statement?

I cannot image that the Energy and Water Agency responsible in Malta for honouring the obligations of the EU Water Framework Directive, agreed to render the valley at Wied l-Isqof to a gutter. Perhaps the Ministry for Transport can explain.

I have known Dr Ian Borg since he was a Mayor at Dingli Local Council. We had long discussions regarding the environment. I was convinced that he would be in the front line to protect our natural and international heritage for the good of our country Malta. I still do believe this, unless of course I am corrected by Dr Borg himself.

That is why I ask myself, how is it possible that such biodiversity damaging works are being carried out under his political responsibility, which are far from being environmental friendly in any way.

This make me think that the Minster is not being kept up to date and made aware of the damages being done by his Ministry’s, funded  by the EU.

I am sure that his biodiversity ‘experts’ cannot distinguish between a Sonchus and a Sambucus, and are completely unaware of environmental obligations Malta has, both nationally and internationally.

The damages being done is not just environmentally. It also reflects lack of good governance. It highlights the degradation of the biodiversity of Malta, who as a member of the EU, is obliged to safeguard biodiversity by 2020, according to the EU biodiversity Strategy 2020, This is not done by using EU funds to destroy biodiversity in the name of ‘help to farmers’.

Such works are also embarrassing those Ministries responsible for EU Directives above mentioned, who were not even consulted, not to include the whole country vis-a-vis the EU, if this is of any concern to the Ministry for Transport.

Infrastructure Malta has issued tenders for resurfacing works of various rural roads (IM001/2019). Can the Minister, who has the ultimate responsibility, ensure the Maltese people that such works will not continue to destroy more biodiversity with EU funds, but will be undertaken in line with Malta’s national and international obligations? Can he also take action to restore the damages done in country paths by his Ministry?

Photos have already appeared on the social media with regards to biological diversity massacre at il-Lunzjata.

More biodiversity destruction in il-Lunzjata Malta (subject to correction this is also in the Minister for Transport constituency). One can see the old footprint, and the additional widening resulting in the destruction of biodiversity, presumably with EU funds also. One can also see the butchering of trees undertaken. Can ERA please note and take necessary action. (photos Courtesy of V Abela Facebook/09.03.2019)

https://www.etenders.gov.mt/epps/cft/viewContractNotices.do?resourceId=5258763&fbclid=IwAR2YqL7wX72IATtkm_AVXFwVR0ik-heisQtCZ45fbTzjdAQ6WIYZdFboVgA

If the Minister can bring this electoral poster to the attention of his officials, perhaps they can remember this electoral promise.

One thing is very very obvious. Infrastructure Malta are carrying out works in the name of the Minister, without any professional expertise in biodiversity, or hydrology, no awareness of national and international obligations, and no consultations whatsoever, either with official entities, like ERA, and the Energy and Water Agency, or with individuals and NGOs. The fact that they are undertaking road works with EU funds, does not justify the bulldozing of biodiversity as is being done.

I will still be following the development of such works, not only in the farmers’ interest, but also in the interest of the protection of our national natural heritage, in line with national and international obligations, for the benefit of this and future generations who have lent it to us. And knowing Dr Ian Borg, I do expect his help in achieving this.

aebaldacchino@gmail.com

related article:

EU funds destroy Maltese biodiversity


EU funds destroy Maltese biodiversity

March 4, 2019

Alfred E Baldacchino

Monday, 4th March, 2019

Having received a number of photos from many environmental friends, I paid a visit to Wied l-Isqof, yesterday, Sunday 3rd March 2019 to see for myself what is being done.

The photos taken shows the great irresponsibility in the work being supported, and financed by the Ministry for Transport. To the extent that now I regard biodiversity destruction in the Maltese Islands as synonymous with the works undertaken by this Ministry (also keeping in mind that the Planning Authority is also in the portfolio of this Minsiter)

Following a lengthy exchange of emails with officials of the Ministry for Transport, all I could get from them is an apologetic reply:

Grazzi hafna tal-email tieghek u kif ghidtlek f’korrospondenza precedenti u anki meta ltqajna fil-passat, it-tnejn li ahna nixtiequ l-gid tal-bdiewa taghna li b’tant dedikazzjoni jiehdu hsieb l-ucuh tal-ghelieqi fil-pajjiz, xi haga li hija mportanti ghal biodiversità. 

Fuq sigar, sfortunatament dawn tqacctu bil-maltemp imma ser inkunu qed inhawlu sigar indigeni kid tajjeb irtakomandajtilna int f’rapporti li kkumissjonajnik biex taghmel ghalina.

 Meaning: Many thanks for your email and as I told you before in previous correspondence, even when we met in the past, both of us have the interest of  our farmers, who with so much dedication cultivate their fields in the country, something, which is important for biodiversity.

With regards to trees, unfortunately these were damaged by the storm, but we are going to plant indigenous trees as you so rightly recommended in your reports which we have commissioned you to compile for us.

NO,  definitely not, this is not in the interest of the farmers. They will have to pay a heavy price because of such works. And there were other suggestions in the reports mention. Works being undertaken are diametrically opposite to the recommendations made.

 Furthermore information forwarded by me to the Ministry for Transport, and others, have all been ignored, , which leads me to conclude that they are reluctant to stop the destruction being done:

  • the country paths in valleys are being turned into highways ;
  • some areas in the valleys seem more like urban squares – big enough to hold political or public meetings.
  • the complete destruction of vegetation and other fauna in the pathways have all been destroyed;
  • the concrete paths made are, in some places, lower than the foundation of the rubble walls. These will eventually all collapse;
  • The valley bed has been reduced to a gutter, with a four-lane concrete road taking its place;
  • European Union money is being used for this destruction of biodiversity. Something which the EU is, not only against, but has a program to conserve biodiversity by 2020.
  • It is not true that the trees at Wied l-Isqof were damaged by the latest strong winds, but by the irresistible chainsaws paid for by the Ministry for Transport.

All these are, according to the Ministry for Transport, in ‘the interest of our farmers’. NO this is not in the interest of our farmers as far as I am concerned. They will have to pay dearly for such mismanagement of the environment.  Most of the works can be done with more thought, more professionalism, and more attention to local and international obligations. But it seems this is not in the interest of the Ministry for Transport. It seems that they are having more fun in such destruction, and how they are spending the EU money, despite the public outcry and criticism of such destruction so loud on social media.

I believe that this follows the complete failure in managing transport by the Ministry for Transport who are now turning to exploit every country path, in ’the name of farmers’ to widen and give it a fresh covering of concrete so that it can be used as a by-pass for traffic. Naturally with a little bit of help from their Planning Authority.

This is being done in a number of valleys both in Malta and in Gozo.

Hope I won’t be disturbing the Environment and Resources Authority, but can they intervene please to stop such destruction of our biodiversity?

Some of the photos taken yesterday, of the works blessed, authorised and paid for by the Ministry of Transport, from public and EU funds, naturally for the ‘benefit of farmers’

rubble wall foundation exposed – naturally in the farmers’ interests

Valley bed filled in. No problem it is only destroying biodiversity.

 

 

 

 

 

 

More effects of the strong winds? Why not tell this to the marines?

 

 

 

 

 

 

For the benefit of our farmers: a four-lane concrete road in the valley bottom!

 

The valley bed reduced to a gutter to make way for a four-lanes concrete road.

More destruction of the valley bed, naturally ‘for the benefit of farmers’ too.

 

 

 

 

 

 

 

 

 

 

Rejoice farmers, rejoice. This is all being done in your name. You can now also race your pickup trucks without any fear of having them scratched. Rejoice.

Future Ministers will have to apply for EU funds to restore collapsed rubble walls which collapsed through the help of EU funds.

 

 

 

 

 

 

 

 

 

A country path for the benefit of our farmers! It has to be the Ministry for Transport to come up with such a vision, naturally with a little bit of help from their Planning Authority.

 

Will we be having horse racing in this country path built for the benefit of farmers, and also to accommodate the former too?

Ministry officials ‘experts’ say that this tree was damaged by the strong winds. The winds must have been carrying chainsaws to achieve this. And the winds must have been God sent to eliminate the tree which was obstructing the country path!


Effects of Ta’ Ċenċ development on Flora and Fauna

March 1, 2016

interview

http://www.independent.com.mt/img/logo.jpg

Effects of Ta’ Ċenċ development on Flora and Fauna

ALFRED E. BALDACCHINO, a noted environmental lobbyist and keen writer has been working hard on the envronmental protection front since the early 1970s. Following the proposed Ta’ Ċenċ development The Malta Independent contacted Mr Baldacchino to see what the avid blogger and environmentalist had to say about the new proposal, the effects it will have on the flora and fauna of the area, and the role of NGOs.                 ___________________________________________________

Q. What flora will be affected by the development?

natura-2000-logo_2_fs.jpeg (800×600)Ta’ Ċenċ is an EU Natura 2000 site. This embraces a Special Area of Conservation with regards to flora and fauna (except birds) according to the Habitats Directive and also a Special Protection Area with regards to birds according to the Birds Directive.

Ta’ Ċenċ was accepted by the EU Commission after Malta forwarded a list of flora and fauna which were of importance to the EU according to the habitat types and species listed in the Habitats and Birds Directives. This was accepted by the EU Commission, and these NATURA 2000 Standard Data Forms (MT0000034) are referred to in the report on an appropriate assessment based on terrestrial ecological resources and on avifauna published by Ecoserve in December 2015.

These EU Directives do not only protect the species per se but also protect the habitats important for certain species within the delineated boundary. The site is important as one holistic ecosystem. These EU Directives oblige Member States to see that all activities, within the delineated boundary, are to be either aimed towards the management of the site or else they, and even those immediately outside, do not impact any habitats and any species of the Natura 2000 site.

endemic-sub endemic flowers

Photos courtesy of Stephen Mifsud

The proposed development, will have a negative impact on most of the flora, whether  common, vulnerable, endemic or endangered. These will be somehow affected both during and after works, and also during the increased human activities, mainly commercial, subsequent to the works not relevant to the management of the site. Some of the important flora found in this EU Natura 2000 are the sub endemic Maltese waterwort, the sub endemic Maltese toadflax, the endemic Maltese cliff orache, the endemic Maltese hyoseris, and the endemic Maltese rock centaury. These besides other important threatened vegetative communities such a those dominated by the endemic Maltese salt tree, and others including garigue and rock pools all of EU Community Importance.

The Appropriate Assessment 2015, besides highlighting the above, also states that: “More accurate prediction of environmental impact would necessitate extensive experimental work on the ecological responses of the species concerned and establishment of a mathematical model linking cause with effect.” A proper Environment Impact Assessment as obliged by the Directive, will have to be undertaken if the development is to proceed.

Q. What fauna will be affected by the development?

All the fauna will also be affected both during and also after the completion of the works. The proposed development will greatly affect and damage the ecological set-up and the conservation of this EU Natura 2000 Site.

short toed lark - michael sammut

Ta’ Ċenċ is the stronghold of the short-toed lark, which is a summer resident to the Maltese Islands where it nests.

The Appropriate Assessment 2015 states that not only the sedentary fauna within this EU Natura 2000 will be affected, but also those which can visit and can leave the area. All the breeding birds in this EU Natura 2000 site will be affected, not only the sea birds colonies breeding on the cliffs but also those which breed or use the plateau for foraging, whether residents or migratory.

blue rock thrush - michael sammut

The blue rock thrush (the national bird of Malta) also breeds at Ta’ Ċenċ and besides the sea cliffs it uses the garigue plateau as its feeding grounds.

The Appropriate Assessment 2015 mentions 24 species of breeding or potential breeding birds recorded at Ta’ Ċenċ. These are either species of global conservation concern, or unfavourable conservation status whether concentrated or not in Europe. Eleven of these are all protected and either vulnerable or endangered and listed in the Maltese Red Data Book such as the corn bunting the short-toed lark, the blue rock thrush, and the barn owl, among others.  This is also confirmed in the Appropriate Assessment 2015.

Short-toed Lark nest at Ta' Ċenċ - Michael Sammut May 2015

The nest of the short-toed lark at Ta’ Ċenċ.  

The Appropriate Assessment 2015 stresses that “Development within these two zones (the hotel area including the interpretation centre, and the villa area) is likely to generate environmental impact that may affect significant resources within Ta’ Ċenċ SAC and this assessment accordingly focuses on processes in these zones.”

Q. How valid are the impact assessments which have been performed and what could they have done better?

The assessment which has been published in 2015 is just an Appropriate Assessment. It is not a proper Environment Impact Assessment which is required before every development in an EU Natura 2000 site, as obliged by the Habitats Directive and as also indicated in the Appropriate Assessment.

The Appropriate Assessment also states that the proposed footprints of the Hotel area, the villa area and the interpretation centre “will obliterate plant assemblages and sedentary or slow moving fauna, and displace more vagile (free moving) fauna from the habitat”.

An earlier Environment Impact Assessment on Ta’ Ċenċ was by made by John Azzopardi in 2005. John Azzopardi is a past Assistant Secretary of the then Malta Ornithological Society with over 35 years experience in field ornithology, and also a past chairman of the International Council for Bird Preservation (Malta Section) – today Birdlife International. In his study John Azzopardi  elaborates “that nocturnal seabirds may be disoriented by artificial lighting whilst travelling from feeding grounds to nesting sites. Possible effects of artificial lighting on nocturnal seabirds, include abandonment of nest sites and burrows (with subsequent vulnerability of chick to starvation or depredation), collision with structures during flight, reduction of reproductive rate and of recruitment rate, interference with navigation and direction-finding and interference with the food sources of the birds.”

According to the EU Habitats Directive, each EU Natura 2000 site has to have a management plan not later than six years after accession, in our case, 2004. Malta did not reach this deadline and was given additional time up to December 2015. By that time, the management plans for all EU Natura 2000 sites were finalised by Epsilon-Adi Consortium, and discussed at public meetings. These had to be approved by Government and sent by MEPA to be approved by the EU Commission.

The Appropriate Assessment 2015 mentions these EU obligatory Management Plans for the EU Natura 2000 sites, but indicates that no reference was made to them despite that these are public. One can either conclude that these have not been sent to the EU, or else that they have not been approved by the EU Commisison. I just cannot image how such a development can be considered by MEPA, when it failed to consolidate and get EU approval for the management plans, now overdue as obliged by the EU Commission. But MEPA is MEPA – no real concern for biodiversity and no interest in EU environmental obligations despite being the official Competent Authority for environmental matters.

Q. What is the role of the NGOs in all of this, and do you think they are acting accordingly?

I believe that every NGO convinced and proud of its statuary aims for the protection of biodiversity, in whole or in part, have to make its stand publicly known on this unique important EU Natura 2000 site. To the time of writing, only Din l-Art Ħelwa has publicly declared its disagreement with this proposed development so damaging to this EU Natura 2000 site.

http://www.independent.com.mt/articles/2016-02-29/local-news/Din-l-Art-Helwa-hits-out-at-Ta-Cenc-proposal-building-in-ODZ-land-unacceptable-6736154093

Sometimes environmental NGOs do surprise me by the stand they take or by their complete silence. The Malta Independent (25.02.16) carried a back page article with a declaration that “Proposed Ta’ Ċenċ development will not interfere with nesting habits – BirdLife Malta”.

Having been the Hon. General Secretary of the MOS (now BirdLife Malta) from 1974 to 1986 when bird protection principles were established with great sacrifices by many, I find it very difficult to believe this. IF this is correct, this is a stab in the back to all those who have and are still contributing to biodiversity and bird protection in Malta, and an insult to all the personal sacrifices by  many who contributed or are contributing, in one way or other towards bird protection.

GuideOne has only to take in consideration the various official publication of BirdLife Malta on the area. Ta’ Ċenc is regarded as the stronghold of the breeding Short-toed Lark, and important for a number of potential breeding species referred to in the Appropriate Assessment 2015, all listed as vulnerable or endangered in the Malta Red Data Book.

An international seabird conference was hosted by BirdLife Malta on 22 November, 2015, and attended by an international delegation of marine scientists, government authorities, and the European Commission representatives, (incidentally, though not much publicised, held at the Hotel Ta’ Ċenċ, Gozo). There it was agreed that “Important Bird Areas (IBAs) (such as Ta’ Ċenċ) represent the largest global network of important sites for biodiversity”.

The Maltese Environment EU Commissioner, Karmenu Vella who addressed the conference by video link is reported as having said that: “Natura 2000 sites (such as Ta’ Ċenċ) are the centrepiece of European nature legislation, helping in our efforts to halt biodiversity loss.

IBA booklet2In July 2004, Birdlife Malta produced a booklet, printed by the Royal Society for the Protection of Birds (RSPB): Important Bird Areas of EU Importance in Malta. This is compiled by John J Borg and Joe Sultana, (the former one of the authors of the Appropriate Assessment 2015). Under the Important Bird Area of Ta’ Ċenċ, the authors list the following as threats for this IBA, now an EU Natura 2000 site: “A tourist complex is situated about 100 m from the cliffs with plans of extension. Uncontrolled recreation, mainly trekking and rock climbing, unsustainable exploitation (e.g. illegal bird shooting and trapping).”

RDBTaking the above, besides many others, in consideration, I find it very very difficult to believe Birdlife Malta statement regarding the non negative impact of development at Ta’ Ċenċ. Of course, one expects an official declaration by Birdlife Malta if this is not correct and is contrary to what Birdlife Malta have been working for, through popular and scientific literature, and publicly campaigning for bird protection since the birth of the society’s in 1962 when it was the Malta Ornithological Society –  MOS.

If such an official declaration is not forthcoming, then I have to regrettably believe it. However, I would then also expect a clarification by Birdlife International for this change of position regarding bird protection in Malta from their local partner, whom they support morally and financially.

I have to strongly disassociate myself from this declaration from Birdlife Malta that the proposed Ta’ Ċenċ development will not interfere with nesting habits, as reported in your paper, and hope that this is a very grave lapsus.

Do you think it is possible to have any sort of compromise with the developers where they can go ahead with development while safeguarding the natural surroundings?

Compromise is not a word in my vocabulary, especially when it comes to eliminating ecosystems, the more so when there are international obligations with regards to the protection of biodiversity of an EU Natura 2000 site. As stated in the Appropriate Assessment 2015 with regards to the obliteration of habitats: “No mitigation measures can be proposed for the actual area obliterated, since this impact is irreversible.”

Where biodiversity is concerned, there can be no compromises: in an EU Natura 2000 site, impacts are either wrong or not wrong. Compromises are reached only by those who have a pro-business vision willing and ready to accept the elimination of a living ecosystems, which after all also sustain us all. And such a compromise is reached only for commercial personal gain, naturally at the expense of society and the living environment.

scientific names

aebaldacchino@gmail.com