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

 

 

 

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Mepa and EU obligations

July 30, 2010

Friday, 30th July 2010

Mepa and EU obligations
Alfred E. Baldacchino

It seems that Mepa now acknowledges my expertise in the field of nature protection (July 21). It was also gratuitous of them to refer to me as the former Mepa assistant director for nature protection. Prior to that I was involved with the Environment Protection Department since its inception and worked under various ministers, especially in connection with EU screening and transposition of the EU biodiversity acquis. Progress during such a period was smooth and fast, with constant ministerial help, understanding and direction, despite some difficulties and lack of resources.

It was a very rewarding and satisfactory time, which I still cherish. But when Mepa was conceived and took over the responsibility of the environment (not just biodiversity), the planning mentality contributed to the dismantlement and, to some extent, the throwing overboard of established procedures and structures. Time and space do not allow me to go into detail here but should the need arise…
More surprising was the fact that Mepa, despite not wanting to fall for childish tit-for-tat, took two newspaper columns, beating about the bush and going on a wild goose chase, only to endorse all the EU Habitats Directive’s obligations outlined in my contribution (July 13). The outstanding points of Mepa’s letter are not the eulogy of what it achieved but the glaring absence of what has not been taken in hand or not done in the spirit of the obligations. To list but a few:

Article 6 of the Habitats Directive outlines what should or should not be done in Special Areas of Conservation (SAC). These, in brief, include conservation measures, management plans, steps to avoid deterioration of natural habitats and species. To use Mepa’s own words: “Obviously, projects and activities that are incompatible with the conservation of objectives of the site are prohibited.” Mepa could have explained how this was applied with regard to the permits issued for development in Baħrija, Mistra and Ramla l-Ħamra, all SACs. And it seems there are more to come!

Article 22 of the EU Habitats Directive deals with invasive alien species. To the credit of the past, now extinct, Nature Protection Unit, the hottentot fig (Carpobrutus edulis) was declared an invasive alien species, as also declared by the European Union. This species has already invaded some coastal cliffs, all SACs. Yet, public funds are being spent to plant this invasive alien species all over Malta and Gozo.  And Mepa, the Competent Authority responsible for this directive, turns a blind eye to such activities.

Buskett, another SAC and also a Special Protection Area (SPA), has become full of invasive alien species. The ongoing disturbance, deterioration and loss of habitat, decrease and disappearance of indigenous species of flora and fauna, the chopping down of protected trees and bushes is so opposed to the obligations of the Habitats Directive. Mepa, in its eulogy of achievements, completely fails to mention any actions taken or being taken in this regard.
A high Mepa official publicly stated on the national TV station that if no solution is found to eliminate the introduced alien frog in Gozo, then the water will be poisoned to eliminate it. This pool also contains, besides others, the painted frog, which is a species of EU interest in need of strict protection listed in annex IV of the Habitats Directive. Such destructive action is completely against the obligations of the directive.

Monitoring and enforcement are other obligations of the Habitats Directive which need reporting on in the six-yearly report. But no mention of these was made in the Mepa achievement list. It is no secret that Mepa is allergic to enforcement measures. When the Environment Protection Department was taken over by the Planning Authority, the former had a fully fledged environment enforcement section. Today, this section has disappeared into oblivion.

A development-driven authority can never, by any stretch of the  imagination, take responsibility and be accountable for the protection, management, monitoring and enforcement of environmental matters. The more so since the deciding bodies within Mepa do not have any inkling of environment management, conservation and EU obligations.
As publicly discussed controversial permits show, technical reports are also often ignored. The ever-increasing public discontent on how the environment in general, particularly the natural environment, is  deteriorating, blatantly abused, exploited, mismanaged and disappearing, is a very strong verdict of Mepa’s failure. A number of environmental NGOs have also publicly asked for resignations within Mepa, considering that it is the Competent Authority responsible to safeguard the environment in the name of the public, who is the main stakeholder. Sometimes, I wonder if the greatest hurdle in the way of the protection of the environment is the Competent Authority itself.

If all this is regarded by Mepa as “Malta living up to the EU Habitats Directive” then divine intervention is the only solution! I am indeed utterly worried for Mario de Marco who has now been handed environmental responsibility.

aebaldacchino@gmail.com
alfredbaldacchino.wordpress.

Link to MEPA’s letter dated 21st July 2010.

http://www.timesofmalta.com/articles/view/20100721/letters/malta-living-up-to-the-eu-habitats-directive

_________________________________________________________________
The author is a retired assistant director, Environment Protection Directorate at the Malta Environment and Planning Authority


The EU Habitats Directive

July 13, 2010
  Tuesday, 13th July 2010 

  The EU Habitats Directive 

 Alfred E. Baldacchino 

    Few, if any, have never heard of the European Union’s Council Directive on the Conservation of Natural Habitats and of Wild Fauna and Flora, better known as the Habitats Directive of May 21, 1992. But fewer know what the aims and obligations of this EU Directive are.

 

The main aim of the Habitats Directive is to promote the maintenance of biodiversity and to ensure the restoration or maintenance of natural habitats and species, that are important to the EU, at a favourable conservation status. Natural habitats and wild species of flora and fauna are under continuous threat from development and agricultural intensification. To pursue such an aim, EU member states are obliged to designate special areas of conservation (SACs) so that a coherent European ecological network known as Natura 2000 is created. These SACs support rare, endangered or vulnerable natural habitats, native plants and animals. Once a site designated by a member state is accepted by the EU Commission, it forms part of the Natura 2000 network, for which the member state has to honour the obligations incorporated in the directive. The EU has accepted as SACs 35 sites proposed by Malta, including Buskett/Girgenti area, Pembroke area, coastal cliffs from Il-Qammieħ area to Rdum tan-Nofsinhar, Wied il-Miżieb (which includes Mistra Bay and Baħrija Valley) and Ta’ Ċenċ area and Ramla area. 

Natura 2000 also incorporates special protection areas (SPAs) which support significant numbers of wild birds and their habitats and which are identified by member states according to the obligations of the EU Birds Directive. Malta has 

identified 13 SPAs which today form part of the Natura 2000 network, including Buskett/Girgenti area, Ta’ Ċenċ in Gozo and Filfla. 

  

Obligations which member states have towards such sites are: 

  

• the establishment of necessary conservation measures involving, if need be, the appropriate management plans specifically designed for the sites or integrated into other development plans; 

• appropriate statutory, administrative or contractual measures which correspond to the ecological requirements of the different natural habitat types listed in Annex I and of the species of flora and fauna listed in Annex II of the Habitats 

Directive, present in the sites; 

• appropriate steps to avoid the deterioration of natural habitats and the habitats of species as well as the disturbance of the species for which the areas have been designated by the member state; 

• an appropriate assessment of any plan or project not directly connected with, or necessary to, the management of the site but which is likely to have a significant effect thereon, either individually or in combination with other plans or projects. Such an appropriate assessment is needed to highlight the implications for the site in view of its conservation objective. The national competent authority for this directive (the Malta Environment and Planning Authority) shall endorse the plan or project only after having ascertained that the conclusions of such assessment regarding the implications for the SAC will not adversely affect the integrity of the SAC concerned. The national competent authority is also obliged, if appropriate, to obtain the opinion of the public. 

• If, in spite of a negative assessment of the implications for the SAC or SPA and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, the member state shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It has to inform the EU Commission of the compensatory measures adopted. 

• Where the site concerned hosts a priority species or a natural habitat type listed in the Habitats Directive, the only considerations which may be raised are those relating to human health or public safety, beneficial consequences of primary 

importance for the environment or further to an opinion from the EU Commission. 

• Undertake surveillance of habitats and species and ensuring strict protection of species of flora and fauna listed in Annex IV of the Habitats Directive. 

• Report to the EU Commission by the national competent authority on the implementation of the directive every six years, incorporating information on conservation measures taken, describing impacts on the conservation status of the species and natural habitats types listed in the directive, measures taken in Natura 2000 sites, besides the key findings of monitoring activities conducted to assess the conservation status of species and natural habitat types of community interest, as all outlined in the directive. The directive also places particular importance on informing the public and making such reports accessible to the public. 

• To improve the ecological coherence of the Natura 2000 network, member states are to encourage the management of landscape features that are essential for the migration, dispersal and genetic exchange of wild species and so improve the ecological coherence of the Natura 2000 network of protection areas and beyond. 

• The Habitats Directive requires member states to monitor natural habitats and species of community interest. 

• Member states must also handle communication, education and public  awareness to ensure the effective implementation of this directive. Malta had to implement the Habitats Directives from the date of accession, that is May 1, 2004. It seems that a number of ministries are among the many that are not au courant with the Habitats Directive. And I would not be surprised in the least if 

the national competent authority itself is oblivious of such obligations, being so development-oriented and judging from the number of permits issued, including some in Natura 2000 sites.  

The public officer who will be detailed to write Malta’s first six-year report on the implementation of the Habitats Directive will find it easier to paint the sky green. Unfortunately, Mario de Marco, Parliamentary Secretary for the Environment, will have to endorse the “achievements” of his predecessor. 

aebaldacchino@gmail.com


BUSKETT – a Special Area of Conservation in the EU

June 21, 2010

Sunday, March 02, 2008

Alfred E Baldacchino

Buskett is of great importance to the Maltese islands from a historical, ecological, economical, educational, and a scientific point of view. The name Buskett is derived from the Italian word Boschetto, which means a small wood.  A part of Buskett is called il-Bosk – the wood.  Buskett is the only locality for Aleppo Pine woodlands, besides having a variety of habitats ranging from maquis, forest remnants, different levels of garigue, and woods typical of watercourses. The English reference to Boschetto, Buskett Gardens, have misled many, not least some politicians lacking ecological background, to conclude that this a garden, as much a garden as San Anton Gardens.

One of Malta’s past colonisers who without doubt were the best that had environmental vision, were the Knights of St John. Without the rich heritage they left us, we would definitely be so much the poorer. Unfortunately, much of this historical heritage is abandoned, neglected and/or vandalised. Buskett is one of the heritage site left to us by the Knights of St John, and was further enhanced by the next colonisers – the British. Today Buskett is protected with a number of regulations. The first legal protection for Buskett was for avifauna and was published as far back as 1932. This was strengthened throughout the years and today Buskett is still protected under the current Conservation of Wild Birds Regulations.

In 1933 a number of trees in Buskett were protected by GN 269, as historical trees of antiquarian importance. In 1996 Buskett was scheduled under the Development Planning Act as an Area of Ecological Importance, a Site of Scientific Importance, an area of high landscape value and a scheduled woodland, by Government Notice 403 of 25 June 1996.  A site plan attached to this Government Notice showed the different levels of protection (level 1, 2, or 3) of Buskett and its surroundings.

During 2001 Buskett was also protected by the regulations for the protection of trees as a tree protected area. Buskett is also an Important Bird Area endorsed by BirdLife International.  Because of such endorsement the government declared as a Special Protection Area, in accordance with the Birds Directive. In 2003 the government proposed Buskett as a Site of Community Interest through Legal Notice 23 of 2003, with the main aim that Buskett be declared a Special Area of Conservation under the EU Habitats Directive to eventually form part of the EU Natura 2000. The Rubble Walls and Rural Structures (Conservation and Maintenance) Regulations 1997, also apply to Buskett. Now this is all very laudable, no doubt about it, but if these regulations are to be worth the paper they are written on, they have to be observed, they have to be implemented and they have to be enforced. There are a number of obligations arising out of European Union legislation, all transposed to local regulations, which have to be taken in consideration with regard to a number of activities.

From an ecological point of view, this means that one cannot bulldoze into Buskett, chainsaw in hand, “pruning” trees, clearing undergrowth, “tidying” walls from creepers, and sweeping dead leaves from beneath wild growing trees. All these activities need to have “prior” clearance from the Competent Authority, and in some cases submit an appropriate assessment of the implications of the operation or activity on the site, in view of the site’s conservation. Consent can be given to the operation or activity only after it has been ascertained that the plan or project will not adversely affect the integrity of the site concerned and if appropriate, after having obtained and taken into account the opinion of the general public and representations made within such reasonable time as the Competent Authority may specify. I remember going to Buskett in my younger days to enjoy the natural  environment surrounded by healthy trees, birds, myriads of butterflies and moths and other invertebrates enriching this unique natural environment we have, and the background sound of water trickling as it flowed through  Buskett, watering Wied il-Luq. This despite the fact that in those days there were no strict regulations for the protection of species and their habitats. When I visit Buskett today, I leave heartbroken: no butterflies, no insects, dead or dying or sawn off trees, dried up springs, and a dying woodland, despite the fact that today there are regulations drafted on international standards, which we, as Maltese, are obliged to honour, not only for our own sake and sanity, but also because of our obligations to the European Union, of which Malta is a Member State. In a statement issued by the Ministry for Rural Affairs and the Environment, (TMIS, 24 February 2008) it was stated that the “work the ministry intended to do was blocked by MEPA, which claimed the projected work could damage the ecosystem.” It is not very often that MEPA official are praised by this Ministry, especially those in the Environment Protection Directorate, or what is left of it. I would also like to extend my congratulations to such dedicated MEPA officials for their efforts because I can fully understand the difficulties they faced to achieve this.  If it weren’t for such efforts to stop such mismanagement of this EU Special Area of Conservation, today Buskett would probably be competing with San Anton Gardens.  It would be a very good idea if the Minister for Rural Affairs and the Environment were to invite the Prime Minster for a walk around this  sensitive unique ecological gem we have in our country, and the beauty nature has bestowed our tiny island. They could see for themselves the Maltese flora and fauna and what a rich heritage we are responsible for. They would also be able to see first hand what has been done and what has not be done to manage such a Special Area of Conservation, which Malta has proposed to the European Union for inclusion in the Natura 2000 network; this small wood called Buskett can contribute in many different ways for the benefit of the Maltese. It would then be easier for them to understand the need and the importance of a National Biodiversity Strategy, with its action plans and management plans – an obligation arising out of international treaties to which Malta is party. Without such a National Biodiversity Strategy, Buskett, together with other natural important habitats, would be lost forever.

aebaldacchino@gmail.com


Two EU Natura 2000 sites threatened by a TEN-T road at Ghadira

February 21, 2010

Sunday, December 07, 2008

Two EU Natura 2000 sites threatened by a TEN-T road at Ghadira

Alfred E. Baldacchino

The recent proposal to build a road at Ghadira is indeed alarming. The reasons advanced to justify such a road sound more like the environmental joke of the week, rivalled only by the same Minster’s environmental statement that the second class water produced by the drainage purification plant has no economic value. No scientific reports or studies were published with regard to the proposed road. Everyone would have loved to see these, rightly so because of other international obligations. The statement by the Minister concerned, as reported in the press, could lead one to think that the plans to build such a road were hurriedly drawn up before the deadline to apply for EU funds expired, not primarily for the sake of the road, but to obtain and utilise funds. Once this news and maps have been officially released by the DOI, one presumes that Cabinet has approved it.

The green and red arrows are inserted by the author, the former indicating the amount of sound and light pollution, disturbance and impact of the new road, and the latter indicating the area that will be at the mercy of strong easterly winds. These were inserted on the original photo montage issued by the DOI showing the new road and the removal of the existent road.

As an EU member State, Malta is bound by the EU legal obligations of the treaty it signed on 1 May 2004. One such legal instrument of this treaty is Council Directive 92/43 EEC of 21 May 1992 on the Conservation of Natural Habitats and of Wild Fauna and Flora, or as it is better known, the Habitats Directive. According to Government Notice 112 of 2007, Malta proposed the Ghadira Reserve as a Site of Community Interest (pSCI), which means a site in the biogeographic region (i.e. the Mediterranean) that contributes significantly to the maintenance or restoration, at a favourable conservation status, of a natural habitat type listed in Annex I, or of a species in Annex II of the Habitats Directive, and which may also contribute significantly to the coherence of the EU Natura 2000 network, and/or contributes significantly to the maintenance of biological diversity in the biogeographic region concerned. The Għadira Reserve, together with the other Sites of Community Interests proposed by Government Notice 112 of 2007 (among them also il-Qammieh) was approved by the EU as Special Areas of Conservation. According to the Habitats Directive, a Special Area of Conservation means a site of Community Importance designated by the member State through a statutory, administrative and/or contractual act where the necessary conservation measures are applied for the maintenance or restoration, at a favourable conservation status, of the natural habitats and/or the populations of the species for which the site is designated. Moreover, the Malta Government also declared Ghadira Reserve, through the same Government Notice 112 of 2007, as a Special Protection Area (SPA) under the Council Directive 79/409/EEC of 2 April 1979 on the Conservation of Wild Birds, better known as the Birds Directive. Today, Ghadira Reserve forms part of the EU Natura 2000 sites. According to the Habitats Directive, Natura 2000 sites are a coherent European ecological network of Special Areas of Conservation (SACs). This network enables the natural habitat types and the species’ habitats concerned, to be maintained or where appropriate, restored at a favourable conservation status in their natural range. The Natura 2000 network also includes the Special Protection Areas (SPAs) classified by the Member States according to the Birds Directive.

L-Għadira Natura 2000 site as per G.N. 112 of 2007

Il-Qammieh Natura 2000 site as per G.N. 112 of 2007

As indicated above, the boundary of the Ghadira SAC touches the boundary of another SAC – il-Qammieh, also proposed by the government through Government Notice 112 of 2007, and now endorsed by the EU. The two site plans published with the G.N. 112 of 2007 are being included. Therefore, the new road will cut through two SACs, both forming part of Natura 2000. And such a proposal for such a new road has to follow the procedure of the obligations of the Habitat Directive. Article 6 of the Habitats Directive obliges Member States to “…take appropriate steps to avoid, in the Special Areas of Conservation, the deterioration of natural habitats and the habitats of species as well as disturbance 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.”

Furthermore, Article 6 of the Habitat Directive obliges that: “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. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 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.” (my emphasis)

Malta is also a Contracting Party to the Ramsar Convention – the Convention on Wetlands, which is an intergovernmental treaty providing the framework for national action and international cooperation for the conservation and wise use of wetlands and their resources. On accession, Malta designated Ghadira as the suitable wetland in its territory for inclusion in the List of Wetlands of International Importance. As a contracting party, Malta is obliged to formulate and implement its planning to promote the conservation of the wetlands included in the List and, as far as possible, the wise use of wetlands in its territory.

A number of environmental NGOs, and a substantial number of the public who really and sincerely have the environment at heart, not for any personal gain, have expressed their concern saying that there is no need for such a road. Indeed a comment by one NGO – Din l-Art Helwa – expressed fears that this would open virgin land to speculation. I cannot for a moment imagine such a road with no adjacent “landscaping”, with bungalows and possibly a high-rise tower similar to the one at Mistra. The present four-carriageway road is quite good and adequate enough. The removal of this road would threaten and possibly eliminate the Ghadira Reserve – a Natura 2000 site.

If one were to look at old maps of the area, the present Ghadira Special Area of Conservation was once a salt pan because the sea had access to the deepest inland part of the area, which is below or at sea level. When the strong easterly winds blow, the big waves are kept at bay by the road. It would take only one such strong storm to sweep over and eliminate the Natura 2000 site, including the adjacent surrounding agricultural land. I witnessed such storms twice during the habitat engineering works at Ghadira in the early 1980s. The negative impact of the removal of the present four-carriageway road, would be augmented by those from the building of the new proposed road at the back of the Natura 2000 site, with sound and light pollution, other disturbances and the alteration of the hydrology of the area, besides obliterating pristine natural habitat. These would render the Ghadira Natura 2000 site a mere glorified duck pond, and would also negatively impact il-Qammieh Natura 2000 site too. In brief, the proposed new road does not have any economical benefits, it does not benefit the social environment and it negatively impacts the ecological environment. It is not sustainable, but is merely a “free market concept” without any social or environmental considerations. In the run up to the last general election, and in the first public meeting after the general election, the Prime Minister repeated, wrote and stressed, that the environment is one of the three pillars of his government. I have been trying hard to find a reason, following such a commitment, why the Prime Minister, who is also the Minister responsible for the Environment, as well as the chairman of the National Commission for Sustainable Development (NCSD), is finding it difficult to activate such Commission, which was set up in 2002, in terms of the Environment Protection Act (2001). The main remit of the NCSD is to advocate a national sustainable development across all sectors, to review progress in the achievement of such sustainable development and to build consensus on action needed to achieve further progress, besides being an obligation as a member of the European Union. This lack of action with regard to the NCSD is also further surprising when during a business breakfast organised by the Nationalist Party, The Times (10 September) reported that “Dr Gonzi said the time had come for the pendulum to swing towards the environment. He argued that the country is at a crossroads in terms of how it views the environment and stressed that a strategic decision on sustainable development needs to be taken now.” I am informed that during another recent business breakfast held on 20 November, a member of the NCSD Commission remarked that the Commission has not met for the last two years! The workings of such a Commission would definitely put an end to such environmental antics. It would also be of help to the Prime Minister and his government in honouring their commitments with regard to their environment pillar, both to the local community, to future generations, and also its international obligations. It would also help the people of Malta to avoid embarrassment vis-à-vis their international obligations, especially those of the European Union environment acquis. Present and future generations will doubtlessly ask why EU funds were spent in a way that threaten two Maltese EU Natura 2000 sites. They will also ask why more natural protected environment of international importance was taken to build a road when a four carriageway one existed and was adequate. They will, without doubt, ask which Minister was responsible who approved such a project when historical, archaeological sites and other roads are crying for maintenance and restoration. Certainly they will ask who the Minister was who had the responsibility to protect their environment, which they had lent us, and more so since it was one of the main pillars of his government. Those responsible may not be here to answer such questions.

aebaldacchino@gmail.com