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?
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.
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.
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.
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.
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.
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.
One 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.”
In 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).”
Taking 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.