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PA 00720/05 EXTENSION TO EXISTING SEABANK HOTEL AND EXTENSION OF FACILITIES TRIQ IL-MARFA MELLIEHA

ENVIRONMENTAL IMPACT STATEMENT

Version 3: September 2009

Report Reference:

Adi Associates Environmental Consultants Ltd, 2009. Extension to existing Seabank Hotel and extension of facilities, Triq il-Marfa, Mellieha. Environmental Impact Statement prepared in support of development permit application No. PA 00720/05, Version 3. San Gwann, September 2009; xvi + 294pp + Appendix.

This is a digital copy of the Report.

Respect the Environment – Keep it Digital

PA 00720/05: Extension to the Seabank Hotel: Environmental Impact Statement

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PA 00720/05

Extension to existing Seabank Hotel and extension of facilities

Mellieha Bay Mellieha

ENVIRONMENTAL IMPACT STATEMENT

Prepared for the Applicant by

Adi Associates Environmental Consultants Ltd September 2009

Adi Associates Environmental Consultants Ltd 2nd Floor, BSL Centre B’kara Road San Gwann SGN 4197 Tel / Fax: 2137 8172 – 21378177 - 21378180 Email: [email protected] Web: www.adi-associates.com

This report has been prepared by Adi Associates Environmental Consultants Ltd with all reasonable skill, care and diligence within the terms of the Contract with

the client, incorporating our Standard Terms and Conditions and taking account of the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters

outside the scope of the above.

This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is

made known. Any such party relies upon the report at their own risk.

mailto:[email protected]

http://www.adi-associates.com


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CONTRIBUTORS

Adi Associates Environmental Consultants Ltd prepared this Environmental Impact Statement in association with the specialist consultants listed below:

• Agriculture and Land Cover Dr Joseph Buhagiar

• Geology & Hydrology Dr Aaron Micallef

• Archaeology and Cultural Heritage Ms Marlene Borg Mr Kurt Balzan Mr Daniel Borg Mr Joseph Calleja Mr Ernest Vella

• Noise and Vibration Mr John Demanuele

Adi Associates staff was involved in the following parts of this EIS:

Adrian Mallia Coordination Waste Management Appropriate Assessment Ecology Climate Change

Kevin Morris Visual and landscape assessment Air Quality Noise

Rachel Xuereb Coordination Waste Management Air Quality Climate Change

Krista Farrugia Coordination Land Uses Ecology Visual and landscape assessment Climate Change

Aaron Micallef Hydrogeology baseline report

Yury Zammit Land Uses Climate change


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CONSULTANTS’ DECLARATION Adi Associates Environmental Consultants Ltd, Malta, prepared this Environmental Impact Statement. The Environmental Impact Assessment Regulations, 2007 Sections 28(3) and 29(1) require each of the Consultants to declare that they carried out the study or part thereof, that they take responsibility for statements and conclusions contained in their reports or part thereof, and that they have no personal or financial interest in the proposed development. We declare that Adi Associates Environmental Consultants Ltd has no personal or financial interest in the proposed development. Adi Associates has coordinated this EIS and has provided technical input to specific parts of the Statement as identified in the previous page. Adi Associates Environmental Consultants Ltd takes overall responsibility for statements and conclusions contained in the parts of the report prepared directly by its staff. However, statements made and conclusions drawn by the independent sub-consultants who prepared the Technical Appendices and informed the Environmental Statement remain the responsibility of the individual sub-consultants.

Kevin Morris Rachel Xuereb Adrian Mallia Director, Adi Associates Director, Adi Associates Director, Adi Associates


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The undersigned hereby declare that they carried out the study or part thereof, for which they take responsibility, and that they have no personal or financial interest in the proposed development. Mr Joseph Buhagiar

Dr Aaron Micallef

Mr John Demanuele

Ms Marlene Borg

Mr Ernest Vella

Mr Joseph Calleja

Mr Daniel Borg

Mr Kurt Balzan

Mr Adrian Mallia


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Mr Kevin Morris

Ms Rachel Xuereb

Ms Krista Farrugia

Mr Yury Zammit


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QUALITY ASSURANCE

Report for: Seabank Group Mellieha Bay Mellieha Issued by:

…………………………………. Adrian Mallia Adi Associates Checked by:

…………………………………. Rachel Xuereb Adi Associates September 2009

PA 00720/05

Environmental Impact Statement

2nd Floor, BSL Centre B’kara Road

San Gwann SGN 4197

Tel/Fax: 21378172 – 21378177 - 21378180 Email: [email protected] Web: www.adi-associates.com

mailto:[email protected]

http://www.adi-associates.com

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CONTENTS

1. INTRODUCTION.............................................................................. 1 Summary of Scheme Proposal.................................................................................................................. 1 Purpose of the EIS....................................................................................................................................... 1 Background to the scheme....................................................................................................................... 1 Structure of the EIS .................................................................................................................................... 2

2. EIA METHODOLOGY ...................................................................... 5 Introduction ................................................................................................................................................. 5 The EIA Process .......................................................................................................................................... 5 Terms of Reference.................................................................................................................................... 5 Baseline Studies ........................................................................................................................................... 5 Air Quality and Climate Change.............................................................................................................. 5 Appropriate Assessment ........................................................................................................................... 6 Economics..................................................................................................................................................... 6 Social Impacts............................................................................................................................................... 6 Method Statements..................................................................................................................................... 6 EIA Approach............................................................................................................................................... 7 Significance of Impacts ............................................................................................................................... 7 Uncertainty................................................................................................................................................... 9 Presentation of the Environmental Impact Statement........................................................................ 9

3. JUSTIFICATION.............................................................................. 11 Introduction ...............................................................................................................................................11 Objectives of Development....................................................................................................................11 Policy Justification for the Scheme........................................................................................................11 Planning Policy ...........................................................................................................................................12 Demand for the Scheme..........................................................................................................................15 The RIU Brand...........................................................................................................................................15 Current Trends in Resort Accommodation.......................................................................................15 Lack of Beds ...............................................................................................................................................16 Improving and Diversifying the Product ..............................................................................................16 The All Inclusive Concept.......................................................................................................................17

4. DESCRIPTION OF SITE AND SCHEME ...................................... 19 Introduction ...............................................................................................................................................19 Purpose of the Scheme............................................................................................................................19 Background to the Project......................................................................................................................19 Objectives of the Scheme .......................................................................................................................20 Site Description and Location................................................................................................................21 Location.......................................................................................................................................................21 Zoning..........................................................................................................................................................22 Access..........................................................................................................................................................23

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Site Topography ........................................................................................................................................23 Surrounding Land Uses............................................................................................................................26 Description of the Scheme .....................................................................................................................32 Alternatives Considered..........................................................................................................................32 The Scheme................................................................................................................................................41 Floorspace Allocation ..............................................................................................................................41 Access and Parking ...................................................................................................................................43 Construction..............................................................................................................................................43 Timing ..........................................................................................................................................................43 Site Operations..........................................................................................................................................43 Landscaping.................................................................................................................................................46 Excavation...................................................................................................................................................48 Construction works .................................................................................................................................49 Project Management.................................................................................................................................52 Scheme Operation....................................................................................................................................56 Employment................................................................................................................................................56 Hours of Operation..................................................................................................................................56 Services and Utilities ................................................................................................................................56 Equipment Needed to Provide the Identified Services.....................................................................60 Other ...........................................................................................................................................................65

5. WASTE MANAGEMENT ............................................................... 67 Introduction ...............................................................................................................................................67 Terms of Reference..................................................................................................................................67 Waste Streams ..........................................................................................................................................69 Excavation and Construction Waste....................................................................................................69 Operational Waste ...................................................................................................................................74 Policy & Legislative Context...................................................................................................................80 Solid Waste Management Strategy........................................................................................................80 Structure Plan for the Maltese Islands..................................................................................................80 Space for Waste: the Waste Management Subject Plan ..................................................................81 Legal Notice 139 of 2002: Sewage Discharge Regulations, 2002...................................................82 Legal Notice 337 of 2001: Waste Management (Permit and Control) Regulations, 2001.......82 Monitoring ..................................................................................................................................................84

6. POLICIES & LEGISLATION........................................................... 85 Introduction ...............................................................................................................................................85 International Legislation...........................................................................................................................85 European Legislation ................................................................................................................................88 National Legislation ..................................................................................................................................89 The Constitution of Malta.......................................................................................................................89 The Development Planning Act, 1992..................................................................................................89 Environment Protection Act, 2001.......................................................................................................92 Fertile Soil (Preservation) Act, 1973 ....................................................................................................95 Legal Notice 160 of 1997 (Rubble Walls and Rural Structures (Conservation and Maintenance) Regulations........................................................................................................................96 Cultural Heritage Act, 2002 ...................................................................................................................96

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Malta Resources Authority Act, 2001..................................................................................................97 The Water Services Corporation Act, 1991......................................................................................97 Solid Waste Management Strategy........................................................................................................98 Planning Policy ...........................................................................................................................................98 Relevant Structure Plan Policies ............................................................................................................98 Space for Waste: the Waste Management Subject Plan ................................................................107 The North West Local Plan .................................................................................................................107 Minerals Subject Plan Policies...............................................................................................................108 Policy & Design Guidance 2007...........................................................................................................108 Other Standards......................................................................................................................................109 British Standards Institute .....................................................................................................................109

7. GEO-ENVIRONMENTAL RESOURCES ..................................... 111 Introduction .............................................................................................................................................111 Terms of Reference................................................................................................................................111 Objectives of Assessment .....................................................................................................................114 Assessment Methodology .....................................................................................................................114 Standards and Guidance ........................................................................................................................114 Area of Influence.....................................................................................................................................115 Methodology ............................................................................................................................................118 Competence of Surveyor......................................................................................................................118 Field Survey – Geology and Palaeontology .......................................................................................118 Field Survey - Hydrology and Hydrogeology ....................................................................................118 Policy Context.........................................................................................................................................121 General Overview ..................................................................................................................................121 European Union Directives ..................................................................................................................121 Guidance ...................................................................................................................................................122 Geo-environmental characteristics.....................................................................................................123 Geology .....................................................................................................................................................123 Stratigraphy ..............................................................................................................................................123 Upper Coralline Limestone Formation..............................................................................................123 Faulting ......................................................................................................................................................126 Site Investigations....................................................................................................................................126 Geomorphology ......................................................................................................................................127 Shore Platform.........................................................................................................................................127 Sandy Beach..............................................................................................................................................127 Valleys ........................................................................................................................................................127 Quaternary Valley Deposits .................................................................................................................128 Soil ..............................................................................................................................................................128 Hydrology and Hydrogeology ..............................................................................................................130 Perched Aquifers.....................................................................................................................................130 Wied Gnien Ingraw ................................................................................................................................132 Il-Hofra Saline Marshland ......................................................................................................................132 Water Catchments.................................................................................................................................132 Surface Water Flow and Water Balance Estimations.....................................................................133 Mineral Resource Assessment .............................................................................................................138

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Quality .......................................................................................................................................................138 Assessment of Impacts...........................................................................................................................139 Prediction and Significance of Impacts................................................................................................140 Mitigation ..................................................................................................................................................141 Residual Impacts ......................................................................................................................................142

8. AGRICULTURE ............................................................................. 145 Introduction .............................................................................................................................................145 Terms of Reference................................................................................................................................145 Assessment Methodology .....................................................................................................................148 Desk Study................................................................................................................................................148 Area of Influence.....................................................................................................................................148 Mapping of Field Structures, Crops, and Trees................................................................................148 Field Survey Results................................................................................................................................150 The Application Site and A of I............................................................................................................150 Assessment of Impacts...........................................................................................................................158 Determining Impact Significance..........................................................................................................158 Potential Impacts.....................................................................................................................................158 Loss of Agricultural Land.......................................................................................................................158 Dust Impacts on Agriculture in the Area of Influence....................................................................158 Loss of Protected Trees........................................................................................................................159 Loss of Agricultural Land: Social Impact ............................................................................................159 Mitigation Measures................................................................................................................................159 Residual Impacts ......................................................................................................................................159

9. ECOLOGY...................................................................................... 161 Introduction .............................................................................................................................................161 Terms of Reference................................................................................................................................161 Objectives of the Assessment..............................................................................................................163 Legislation, Policies and Guidance.......................................................................................................164 Baseline Survey Methodology...............................................................................................................167 Data Sources............................................................................................................................................167 Desk Study Methodology ......................................................................................................................167 Field Survey Methodology.....................................................................................................................167 Assessment Methodology .....................................................................................................................171 Determining Impact Significance..........................................................................................................171 Baseline Survey Results: A Summary..................................................................................................172 Habitats within the A of I......................................................................................................................175 Il-Hofra Saline Marshland: Vegetation Assemblages........................................................................175 Il-Hofra Saline Marshland: Avifauna.....................................................................................................176 Other Habitats within the Area of Influence....................................................................................177 Agricultural Land: Tree Survey ............................................................................................................178 Impact assessment ..................................................................................................................................180 Potential Impacts.....................................................................................................................................180 Prediction and Significance of Impacts................................................................................................180 Restoration of the marshland...............................................................................................................186

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Mitigation ..................................................................................................................................................186

10. CULTURAL HERITAGE ............................................................... 191 Introduction .............................................................................................................................................191 Terms of Reference................................................................................................................................191 Assessment Methodology .....................................................................................................................193 Area of Influence.....................................................................................................................................193 Objectives of the Study .........................................................................................................................196 Survey Methodology...............................................................................................................................196 Evaluation..................................................................................................................................................197 Determining Impact Significance..........................................................................................................202 The Baseline Survey Results .................................................................................................................203 Study Limitations.....................................................................................................................................203 Scheduling .................................................................................................................................................203 Historical Importance of the Area......................................................................................................206 Cultural Features.....................................................................................................................................206 Archaeology .............................................................................................................................................211 Cultural Landscape .................................................................................................................................211 Assessment of Impacts...........................................................................................................................213 Prediction and Significance of Impacts................................................................................................213 Proposed Mitigation Measures.............................................................................................................213 Residual Impacts ......................................................................................................................................214 Monitoring Requirements .....................................................................................................................214

11. LANDSCAPE & VISUAL AMENITY............................................ 217 Introduction .............................................................................................................................................217 Terms of Reference................................................................................................................................217 Objectives of the Assessment..............................................................................................................220 Legislation and Policies ..........................................................................................................................220 Standards and Guidelines ......................................................................................................................223 Assessment Methodology .....................................................................................................................224 Desk Study Methodology ......................................................................................................................224 Field Survey Methodology.....................................................................................................................225 Determining Impact Significance..........................................................................................................229 Landscape Assessment...........................................................................................................................229 Visual Amenity .........................................................................................................................................229 Existing Conditions: Desk Study..........................................................................................................230 Landscape..................................................................................................................................................230 Landscape Character Assessment.......................................................................................................230 The Zone of Visual Influence................................................................................................................233 Existing Conditions – Field Survey......................................................................................................233 Scheme Landscape ..................................................................................................................................233 Landscape Character..............................................................................................................................234 Visibility and Visual Amenity.................................................................................................................235 Sensitivity of visual receptors...............................................................................................................236 Changes in the Landscape and Visual Amenity.................................................................................237

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Changes in the Landscape and their Significance .............................................................................237 Changes in Visual Amenity and their Significance............................................................................238 Proposed Mitigation Measures.............................................................................................................245 Residual Impacts ......................................................................................................................................245 Future Monitoring Requirements........................................................................................................245

12. AIR QUALITY AND CLIMATE CHANGE.................................. 249 Introduction .............................................................................................................................................249 Terms of Reference................................................................................................................................249 Assessment Methodology .....................................................................................................................251 Traffic Emissions......................................................................................................................................251 Dust Emissions.........................................................................................................................................252 Objectives of Assessment .....................................................................................................................252 Competence of Surveyor......................................................................................................................253 Standards and Guidance ........................................................................................................................253 Baseline Air Quality................................................................................................................................255 MEPA Data ...............................................................................................................................................255 Assessment of impacts...........................................................................................................................256 Climate Change .......................................................................................................................................256 Air Quality ................................................................................................................................................258 Mitigation ..................................................................................................................................................261 Residual Impacts ......................................................................................................................................262

13. NOISE EMISSIONS AND VIBRATION....................................... 265 Introduction .............................................................................................................................................265 Terms of Reference................................................................................................................................265 Area of Influence.....................................................................................................................................267 Assessment Methodology .....................................................................................................................269 Noise..........................................................................................................................................................269 Vibration....................................................................................................................................................270 Standards and Guidance ........................................................................................................................270 Survey Methodology...............................................................................................................................271 Determining Impact Significance..........................................................................................................272 Noise..........................................................................................................................................................272 Vibration....................................................................................................................................................273 Baseline Conditions: Noise...................................................................................................................275 Noise Measurements .............................................................................................................................275 Key Receptors .........................................................................................................................................275 Baseline Conditions: Vibration.............................................................................................................276 Impact Assessment: Noise....................................................................................................................276 Potential Impacts.....................................................................................................................................276 Prediction and Significance of Impacts................................................................................................276 Impact Assessment: Vibration..............................................................................................................280 Potential Impacts.....................................................................................................................................280 Prediction and Significance of Impacts................................................................................................280

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Mitigation ..................................................................................................................................................282 Residual Impacts ......................................................................................................................................282

14. SUMMARY OF KEY IMPACTS, INTERACTIONS BETWEEN IMPACTS, AND MITIGATION.................................................... 285

Introduction .............................................................................................................................................285 Summary of Key Impacts.......................................................................................................................285 Interaction of Impacts ............................................................................................................................286 Mitigation ..................................................................................................................................................293 Summary of Mitigation...........................................................................................................................293 Commitment to Mitigation...................................................................................................................294

LIST OF TABLES

Table 4.1: Floorspace allocation: existing hotel and proposed extension....................................41 Table 4.2: Proposed facilities..................................................................................................................42 Table 4.3: Traffic generated during excavation ..................................................................................48 Table 4.4: Raw materials required during construction...................................................................51 Table 4.5: Employment during excavation and construction ..........................................................52 Table 4.6: Estimated employment .........................................................................................................56 Table 5.1: Solid Construction Waste ...................................................................................................73 Table 5.2: Municipal waste generation figures....................................................................................75 Table 5.3: Scheme criteria.......................................................................................................................75 Table 5.4: Waste management criteria ................................................................................................76 Table 5.5: General Waste generated by the hotel ............................................................................78 Table 7.1: Land uses and associated run-off co-efficients for the sub-catchment associated

with the Study Area...................................................................................................................... 134 Table 7.2: Annual water balance for the sub-catchment associated with the Study Area. ... 134 Table 7.3: Summary of Laboratory Analysis Results ...................................................................... 138 Table 7.4: Summary of Impacts on the Geo-environmental Resources.................................... 143 Table 8.1: Classification of agricultural land according to the USDA system of classification

........................................................................................................................................................... 153 Table 8.2: Summary of Impacts on Agriculture.............................................................................. 160 Table 9.1: Species of conservation significance ............................................................................... 176 Table 9.2: Protected trees recorded on site ................................................................................... 179 Table 9.3: Summary of Ecological Impacts........................................................................................ 188 Table 10.1: Protection ratings & cultural significance .................................................................... 201 Table 10.2: Impact Significance Criteria............................................................................................ 202 Table 10.3: Scheduled sites relevant to this study.......................................................................... 204

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Table 10.4: Cultural Features that Merit Conservation: Summary of Policy Importance ..... 206 Table 10.5: State and length of rubble walls in the A of I ............................................................. 209 Table 10.6: Summary of Impacts on Cultural Heritage ................................................................ 215 Table 11.1: Potential sensitive landscape receptors....................................................................... 225 Table 11.2: Landscape types, Character Areas .............................................................................. 231 Table 11.3: Summary of Application Site visibility from viewpoints.......................................... 236 Table 11.4: Changes in Landscape Character and the significance of the impacts.................. 238 Table 11.5: Summary of Impacts on Landscape and Visual Amenity......................................... 246 Table 12.1 Annual average concentrations for Mellieha 2003-2005 .......................................... 256 Table 12.2: Summary of Impacts......................................................................................................... 263 Table 13.1: Construction vibration levels......................................................................................... 268 Table 13.2: Transient vibration guide values for cosmetic damage ............................................ 271 Table 13.3: Equivalent dB(A) levels................................................................................................... 273 Table 13.4: Location of noise monitoring points........................................................................... 275 Table 13.5: Summary of survey results ............................................................................................. 275 Table 13.6: Maximum noise levels for construction plant ............................................................ 277 Table 13.7: Predicted sound levels at noise sensitive receptors................................................. 278 Table 13.8: Summary of noise and vibration impacts..................................................................... 283 Table 14.1: Summary of Interactions between Impacts ............................................................... 286 Table 14.2: Summary of Impacts......................................................................................................... 287

LIST OF FIGURES

Figure 1.1: Site location .............................................................................................................................4 Figure 4.1: Site location ...........................................................................................................................24 Figure 4.2: Site Topography....................................................................................................................25 Figure 4.3: Land use ..................................................................................................................................27 Figure 4.4: Agricultural land surrounding the Site .............................................................................28 Figure 4.5: Remains of the donkey-driven water mill .......................................................................28 Figure 4.6: Mellieha Bay during the summer.......................................................................................29 Figure 4.7: The residential area..............................................................................................................29 Figure 4.8: North West Local Plan: Ghadira Isthmus Strategy Map: Map 34A...........................30 Figure 4.9: North West Local Plan: Ghadira Isthmus Protected Areas Map: Map 34...............31 Figure 4.10: Artistic interpretation of the Waterpark and bungalows proposal ........................34 Figure 4.11: Block Plan of Proposal 2 ...................................................................................................35 Figure 4.12: Block Plan of the Proposal 3a (as presented in the first draft of this EIS).............36 Figure 4.13: Block plan of Proposal 3b.................................................................................................38

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Figure 4.14: Block plan of Scheme (proposal 4).................................................................................39 Figure 4.15: Rendered image of proposed Scheme...........................................................................40 Figure 4.16: Construction timetable.....................................................................................................45 Figure 4.17: Landscaping zones ..............................................................................................................47 Figure 4.18: Site layout during construction.......................................................................................53 Figure 4.19: Pre excavation survey .......................................................................................................54 Figure 4.20: Excavation plan ...................................................................................................................55 Figure 5.1: Collection of runoff including reservoirs and channelling ...........................................72 Figure 7.1: Area of Influence for Geology and Geomorphology................................................. 116 Figure 7.2: Area of Influence for Hydrology and Hydrogeology ................................................. 117 Figure 7.3: Location of boreholes....................................................................................................... 119 Figure 7.4: Geology of the site and the surrounding area ............................................................ 125 Figure 7.5: Geomorphology of the site and the surrounding area ............................................. 129 Figure 7.6: Digital elevation model of the Study Area (marked by a solid black line) and the

surrounding terrain....................................................................................................................... 135 Figure 7.7: Watershed and sub-catchment area at the Site and the surrounding area.......... 136 Figure 7.8: Surface water flow across Site........................................................................................ 137 Figure 8.1: Agricultural Area of Influence......................................................................................... 149 Figure 8.2: Fields within A of I............................................................................................................. 154 Figure 8.3: Reservoirs and boreholes................................................................................................ 155 Figure 8.4: Agricultural land cover recorded in the Regional Environmental Assessment ... 156 Figure 8.5: Field survey ......................................................................................................................... 157 Figure 9.1: Scheduled areas as designated in the North West Local Plan ................................ 166 Figure 9.2: Habitats Survey Area of Influence.................................................................................. 169 Figure 9.3: Tree survey Area of Influence ........................................................................................ 170 Figure 9.4: Il-Hofra saline marshland ................................................................................................ 173 Figure 9.5: Habitats within A of I........................................................................................................ 174 Figure 9.6: Wind rose for Malta ......................................................................................................... 183 Figure 10.1: Area of Influence for cultural heritage survey .......................................................... 195 Figure 10.2: Cultural Heritage features located within the A of I ............................................. 205 Figure 10.3: Cultural features recorded within the A of I ............................................................ 207 Figure 10.4: Rubble walls ...................................................................................................................... 210 Figure 11.1: Regional Landscape Character Areas ......................................................................... 222 Figure 11.2: Area of High Landscape Value and the Area identified for recognition as a

protected Landscape Area in IUCN III..................................................................................... 223 Figure 11.3: Zone of Visual Influence and Viewpoints.................................................................. 227 Figure 11.4: Local Landscape Character Areas ............................................................................... 228 Figure 11.5: Viewpoint 1 before and after the Scheme................................................................. 239

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Figure 11.6: Viewpoint 2 before and after the Scheme................................................................. 240 Figure 11.7: Viewpoint 3 before and after the Scheme................................................................. 241 Figure 11.8: Viewpoint 4 before and after the Scheme................................................................. 242 Figure 11.9: Viewpoint 5 before and after the Scheme................................................................. 243 Figure 11.10: Viewpoint 6 before and after the Scheme............................................................... 244 Figure 12.1: Distance of nearest residential area affected by the NW wind............................ 254 Figure 13.1: Area of Influence: Noise ................................................................................................ 269 Figure 13.2: Location of Noise Measurement Points..................................................................... 274

APPENDICES

Appendix 1: Geological Sub-Surface Investigation Report


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1. INTRODUCTION

SUMMARY OF SCHEME PROPOSAL 1.1. This Environmental Impact Statement (EIS) was commissioned by Mr Silvio Debono

on behalf of the Seabank Hotel to support planning application PA 00720/05 for the Extension to the existing Seabank Hotel and extension of facilities at Mellieha Bay, Mellieha.

1.2. Planning application PA 00720/05 was validated by the Malta Environment & Planning Authority (MEPA) on 28th February 2005.

1.3. MEPA determined that the Application required an EIS on the basis of Schedule 1A Category 3.3.1.1 of the Environmental Impact Assessment Regulations, 2007 (LN 114 of 2007), which deals with extensions to existing tourist accommodation outside the development zone.

1.4. Hereafter, in this EIS, the proposed extension to the Seabank Hotel is referred to as ‘the Scheme’. A full description of the Scheme is provided in Chapter 4.

1.5. This report is the second draft of the EIS and takes into consideration (i) changes made to the Scheme as a result of comments from MEPA regarding its design; and (ii) comments from MEPA and its consultees on the first draft of the EIS. This draft often refers to the ‘revised Scheme’, which makes reference to the recent changes made in light of comments from MEPA. Technical Appendices remain unchanged from the first draft of the EIS.

PURPOSE OF THE EIS 1.6. The purpose of this EIS is to present the findings of the Environmental Impact

Assessment (EIA). EIA is the process of systematically identifying and assessing the likely significant environmental impacts of a proposed project. EIA also ensures that the significance of these impacts, and the scope for reducing them, is clearly understood by both the public and MEPA before a decision is made on whether or not the Scheme should be approved.

BACKGROUND TO THE SCHEME 1.7. The Site abuts the existing Seabank Hotel in Mellieha Bay, one of three tourist

accommodation establishments within the Bay. The Seabank Hotel started as a small 9-room guesthouse, when it was bought by the current owners in 1984. The original guesthouse was expanded to an 80-room hotel in 1991. Further extensions took place in 1996, 2001, and 2004, whereby the complement of the hotel was increased to 282 rooms.

1.8. The Seabank Group has been seeking to improve the quality of the hotel and especially the amenities it can offer to its customers through the development of the


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product on offer. A number of alternatives were considered over the past few years, all aimed at upgrading the tourism product in this part of the island. The current Scheme aims to extend the hotel and its facilities on land that has been earmarked in the North West Local Plan1 for “restrained redevelopment”. The revised Scheme ensures that the Application Site remains within the area designated as “restrained redevelopment” (see Chapter 4). The only part of the development located outside this area are parts of the swimming pools, which structures are accepted as ancillary developments outside the development zone in such cases.

1.9. This EIS assesses the potential significant impacts of the Scheme in accordance with the Terms of Reference issued by MEPA.

STRUCTURE OF THE EIS 1.10. Following this introduction, the EIS is structured as follows:

• Chapter 2: EIA Methodology

• Chapter 3: Justification for the Scheme

• Chapter 4: Description of Site and Scheme

• Chapter 5: Waste Management Plan

• Chapter 6: Legislation and Policy Context

• Chapter 7: Geo-Environment

• Chapter 8: Land Cover and Agriculture

• Chapter 9: Ecology

• Chapter 10: Archaeology and Cultural Heritage

• Chapter 11: Landscape and Visual Amenity

• Chapter 12: Air Quality & Climate Change Effects

• Chapter 13: Noise and Vibration

• Chapter 14: Key Impacts, Cumulative Effects and Summary of Mitigation

1.11. The EIS also contains the following Technical Appendices:

• Technical Appendix 1: Terms of Reference and Method Statements

• Technical Appendix 2: Geo-Environmental Baseline Study

• Technical Appendix 3: Agriculture Baseline Study 1 Malta Environment and Planning Authority, 2006


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• Technical Appendix 4: Ecology Baseline Survey

• Technical Appendix 5: Archaeology and Cultural Heritage Baseline Study

• Technical Appendix 6: Noise Baseline Study

1.12. The EIS also includes a Non-Technical Summary in Maltese and English.


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Figure 1.1: Site location


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2. EIA METHODOLOGY

INTRODUCTION 2.1. This chapter sets out the broad method that has been used in the EIA for the

proposed Scheme. It sets out the key stages that have been followed, in line with EIA best practice. This chapter also provides a section on how the significance of impacts has been assessed, and how this has been a consistent process throughout the EIA.

THE EIA PROCESS 2.2. The current guidance on the EIA process is the Environmental Impact Assessment

(EIA) Regulations, 20072. The Scheme qualifies as a Category I project under Section 3.3.1.1: “Construction of and extension to hotel, holiday village, hostel, or tourist facility that is outside development zone with a capacity of more than 250- beds” of Schedule IA.

TERMS OF REFERENCE 2.3. The Terms of Reference (ToR) for the EIA were prepared by MEPA in consultation

with relevant Government Departments. The final version was given to the Architect on 26th November 2007 (see Technical Appendix 1: Terms of Reference, and Method Statements).

2.4. The ToR for the EIS were formulated following a scoping exercise undertaken by MEPA to identify the issues to be considered in the EIA. The ToR focus on those impacts of the proposal that MEPA consider to be significant and therefore requiring further assessment, avoiding the examination of all potential environmental impacts. They also set out the various components of the EIA.

Baseline Studies 2.5. Adi Associates Environmental Consultants Ltd carried out a Regional Environmental

Assessment for the entire isthmus. Baseline studies were carried out as part of the assessment. It was agreed with MEPA that these baseline studies would be referred to and updated as necessary by experts in the field. New baseline studies were carried out for cultural heritage, noise, visual amenity, ecology, agriculture, hydrology, and geo-technical studies. Land use and tree surveys were also carried out.

Air Quality and Climate Change 2.6. Section 2.8 of the Terms of Reference require a baseline survey of the current

background levels of pollution, including dust Considering that the Scheme consists of an extension to an existing hotel and not a dust generating activity (as a quarry would be) dust baseline is not considered relevant and was therefore scoped out. The impact of dust generated during construction is however assessed, both in the

2 Legal Notice 114 of 2007.


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Chapter on Air Quality, and that on Ecology. The Appropriate Assessment also addresses the impacts of dust on the ecology of the SAC.

2.7. The impacts on air quality from traffic are also considered negligible because a hotel operation does not generate a significant amount of cars, especially considering that the arterial road in front of the hotel is very busy during the summer months. Additionally the seasonality of the use of roads in the area makes establishing a baseline extremely difficult. Please refer to Chapter 12 for more details.

2.8. Green house gas emissions as a result of the Scheme are requested under Section 1.2.10 of the Terms of Reference. These have been quantified, based on electricity generation. Emissions from traffic are considered negligible; contribution to GHG emissions cannot be estimated because these would depend on distance travelled.

Appropriate Assessment 2.9. As requested by MEPA a separate Appropriate Assessment has been carried out in

addition to the Ecology Assessment found in Chapter 9. The Appropriate Assessment assesses the effects of the Scheme on the integrity of the Special Area of Conservation and the Special Protection Area (both lie within the same boundary).

Economics 2.10. Section 1.1.1 of MEPA’s ToR require an overall economic justification of the proposal.

Information may be drawn from the economic analysis conducted as part of the project feasibility study. It was agreed with MEPA that detailed economic assessment is not required but reassurance is required that this will be a viable project3.

Social Impacts 2.11. It has been agreed with MEPA that social aspects will be treated in the individual

chapters, so long as a comprehensive overview of social issues likely to arise is presented4.

METHOD STATEMENTS 2.12. As required by the EIA Regulations, the Consultants who prepared this EIS were

approved by MEPA5.

2.13. The Consultants undertaking the agriculture, geo-environment, landscape and visual amenity, ecology, cultural heritage, and noise baselines, produced a Method Statement in collaboration with Adi Associates. The Method Statements outlined the baseline survey work to be carried out, the methods used to assess the predicted impacts of the Scheme, and the means by which their significance would be determined. The Method Statements included the following information:

3 E-mail from MEPA (J. Abela Vassallo) dated 23/11/2007. 4 E-mail from MEPA (J. Abela Vassallo) dated 23/11/2007. 5 E-mail from MEPA (J. Abela Vassallo) dated 05/12/2007.


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• Introduction listing the objectives of the survey and reference to the ToR;

• Details of baseline survey methodology;

• Area of Influence;

• Competence of surveyors;

• Field survey methodology;

• Analytical methodology;

• Evaluation of data;

• Identification of potential impacts;

• Prediction of impacts;

• Impact significance; and

• Mitigation.

2.14. The Method Statements are included in Technical Appendix 1: Terms of Reference and Method Statements. The Method Statements were then used as the basis for carrying out the EIA.

EIA APPROACH 2.15. Good practice advises that EIA should be treated as an iterative process, rather than

a one-off, post-design environmental appraisal. In this way, the findings from the EIA can be fed into the design process, leading to the production of a more environmentally sensitive project. This approach was adopted for this EIA.

2.16. Baseline surveys for the different specialist EIA topics were undertaken by the Consultants, based on the Area of Influence agreed with MEPA for each topic area.

2.17. A detailed assessment of the Scheme’s impact on the features present in the Area of Influence was undertaken and any potential environmental benefits of the Scheme identified.

SIGNIFICANCE OF IMPACTS 2.18. Assessment of the significance of impacts arising from the Scheme is a key stage in

the EIA process. It is this judgement that is key in informing the decision-making process. However, defining what is significant is not a simple task. In general terms, environmental significance involves assessing the amount of change to the environment perceived to be acceptable to the community (Sippe, 19996).

6 Sippe R (1999) ‘Criteria and Standards for Assessing Significant Impact’ in Petts J ‘Handbook of Environmental

Impact Assessment, Volume 1.


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2.19. The following criteria have been used to assess the significance of an impact:

• Type of impact (adverse/beneficial);

• Extent and magnitude of impact;

• Direct or indirect impact;

• Duration of impact (short term/long term; permanent/temporary);

• Comparison with legal requirements, policies and standards;

• Sensitivity of receptor (residential dwelling, farm, etc.);

• Probability of impact occurring (certain, likely, uncertain, unlikely, remote);

• Reversibility of impact;

• Scope for mitigation/enhancement (very good, good, none); and

• Residual impacts.

2.20. Using these criteria, the significance of the impacts arising from the Scheme has been categorised throughout the EIS, as follows:

• Not significant;

• Minor significance; and

• Major significance.

2.21. Definitions of the meaning of the “significance categories” above in relation to each topic area are included in the topic chapters. However, in general terms, if an impact is “not significant”, it is environmentally acceptable, “minor significance” reflects the fact that the impact is manageable, possibly through mitigation measures, and “major significance” relates to the fact that the impact is environmentally damaging and requires redesign or mitigation measures to minimise it.

2.22. The EIS contains an assessment of the significance of predicted impacts and, following the proposed mitigation measures, the significance of any residual impacts. A residual impact is any remaining impact that would exist following the implementation of proposed mitigation measures. The impact would, therefore, not be reduced to “insignificant” by mitigation measures, and would still be of minor or major significance. Mitigation measures and residual impacts are addressed in the chapter of the EIS that deals specifically with the source of the significant effect. A summary of mitigation measures are tabulated at the end of each chapter and a summary of significant impacts is included in Chapter 14.


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UNCERTAINTY 2.23. The EIA process is designed to enable good decision-making based on the best

possible information about the environmental implications of a proposed development. However, there will always be some uncertainty as to the exact scale and nature of the environmental impacts. This arises through shortcomings in information, doubts, or lack of certainty on the likelihood that an incidence would occur, or due to the limitations of the prediction process itself. It is stated in the EIS where uncertainties have arisen and where they remain. Good practice requires that a project is monitored during construction and operation so as to determine whether the impacts originally predicted were correct.

PRESENTATION OF THE ENVIRONMENTAL IMPACT STATEMENT

2.24. The EIS is divided into three main sections after the Introduction and this chapter providing the EIA Methodology. Part 1 comprises Chapters 3 to 6:

• Chapter 3 provides a justification for the Scheme;

• Chapter 4 provides a detailed description of the Scheme and its surroundings;

• Chapter 5 concerns waste management; and

• Chapter 6 summarises the relevant legislation and policy context, including planning policies.

2.25. Part 2 of the EIS (Chapters 7 to 13) describes the potential environmental impacts of the Scheme in relation to a number of different topic areas. These topic areas were identified in the ToR. The information in each of these chapters is structured in a consistent way, as follows:

• Introduction: identifying key issues and how the chapter relates to the requirements of the ToR;

• Assessment Methodology: a summary of the methods used (desk study, surveys, consultations, etc.) in undertaking the EPS topic chapter;

• Existing Conditions: a summary of the baseline situation and trends irrespective of the development proposals; and

• An assessment of impacts associated with the operation of the Scheme, following the headings below:

o Potential impacts: a summary of the potential impacts of the Scheme;

o Prediction and significance of impacts: a prediction of the likely impacts of the Scheme against the baseline situation and an assessment of the significance of the impacts;


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o Mitigation measures: a summary of potential mitigation / enhancement measures to offset any identified adverse impacts of the Scheme;

o Residual impacts: a clear statement of those impacts that will still have an impact following mitigation, indicating the significance of the residual impact; and

o Summary: a summary table of the impacts.

2.26. Part 3 of the EIS (Chapter 14) addresses the cumulative effects of the Scheme, and summarises the impacts and proposed mitigation measures.


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3. JUSTIFICATION

INTRODUCTION 3.1. This chapter describes the objectives of the Scheme and the perceived demand for it

in accordance with Sections 1.1.1 and 1.1.2 of the ToR.

OBJECTIVES OF DEVELOPMENT 3.2. The main objectives of the developers of the Scheme are:

• To increase the size of the hotel in order to be able to take advantage of economies of scale and thus:

o offer an all-inclusive concept;

o operate more amenities, such as animation in a cost effective manner;

o provide pool facilities and public areas consistent with the needs of a larger hotel;

o provide a state of the art spa centre that will enhance the north region’s quality offer for clients;

o help further develop ancillary activities such as horse riding, rambling and scuba diving holidays;

• Continue to sustain TUI’s presence in Malta, the Seabank being a RIU flagship property.

• To provide underground parking that meets the needs of the guests and workers of the Scheme;

• To contribute to the amenity of the area by making parts of the Scheme accessible to the public; and

• To integrate, as much as possible, the Scheme with the local context and environment.

POLICY JUSTIFICATION FOR THE SCHEME 3.3. The design of the Scheme is influenced by the Structure Plan for the Maltese Islands,

the North West Plan, and MEPA’s Structure Plan Review Tourism Topic Paper7. The relevance of the Scheme to these policy documents is described below. The relevance of policies and legislation in relation to the Scheme is discussed further in Chapter 6.

7 Structure Plan for the Maltese Islands Tourism Topic Study, Final Draft, MEPA, 2000


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Planning Policy 3.4. MEPA’s policy for the Ghadira area seeks to resolve competing spatial demands by

affording priority to the conservation and management of the natural and cultural environment (for a detailed discussion see Chapter 6).

Structure Plan for the Maltese Islands

3.5. Policy BEN 5 guides development in non-urban areas; it states that “Applications for development permits outside urban areas will be judged against the policies and design guidelines of the Local Plans for Rural Conservation Areas, and in the interim period, to Structure Plan policies and the guidelines contained in the Explanatory Memorandum”.

3.6. Policy TOU 4 provides for the location of new tourist accommodation within “existing built-up areas by extension and conversion of suitable buildings and the development of infill sites….” Mellieha is identified as a suitable location for additional tourist accommodation, although the site cannot be considered as an existing built-up area.

North West Local Plan

3.7. The Application Site is within the area covered by the North West Local Plan (NWLP), and is governed by the Ghadira policies. The Strategy Plan for Ghadira designates the Application Site as “Restrained Redevelopment”. The term “restrained redevelopment” is not defined in the Local Plan; consequently it is difficult to interpret whether or not the Scheme or parts of it fall within this definition.

3.8. The issues relevant to the development outlined in the NWLP for the area are:

i. Competing and conflicting demands on limited land and sea space - Proliferation of land and sea uses such as tourist accommodation, leisure facilities, catering establishments… which are continually increasing the demand for space at the exclusion of less environmentally damaging activities such as agriculture, nature appreciation, walking, and bathing;

ii. Over development on existing land - Intensification of existing uses such as incremental growth of tourism and leisure development,… which are detracting from the quality of the experience of the area and leading to further congestion;

iii. Congestion – The range and scale of uses continue to attract larger numbers of visitors which access the area by private cars increasing demand for more land for car parking, clogging up road junctions, leading to air and noise pollution, creating conflicts with pedestrians and contributing to a chaotic atmosphere;

iv. Environmental Impacts – The proliferation of activities, over development and congestion mentioned above result in negative environmental impacts such as:


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o visual intrusions by poorly designed and located buildings and structures;

o visual intrusions by vehicles;

o air, noise and bathing water pollution;

o degradation of habitats (sand dunes and posidonia meadows); and

o loss of agricultural land.

3.9. The key planning interventions relevant to the Scheme to address such issues are described in relation to policy NWML 18 – Strategy for Ghadira Isthmus:

i. Protect and enhance the natural and cultural environment by:

o Prohibiting development, which adversely affects statutory protected areas;

o Identifying further terrestrial and marine areas/sites for protection; and

o Identifying opportunities for environmental enhancement.

ii. Improve transportation problems by:

o Managing access;

o Improving pedestrian safety;

o Managing car-parking provision; and

o Encouraging traffic management schemes.

iii. Control tourism related development by:

o Identifying tourism related development opportunities on existing tourism development sites;

o Defining boundaries and policy constraints for tourism related development opportunity areas on existing tourism development sites; and

o Prohibiting establishment of new tourism related facilities outside the identified areas.

v. Manage recreation activities by:

o Identifying opportunities for environmentally friendly recreation.

3.10. In addressing the upgrading of existing tourist accommodation in coastal areas that are ODZ, Policy NWTO 2 indicates that MEPA would favourably consider proposals


14

that have obtained the prior approval of the Malta Tourism Authority, and which meet various criteria in respect of site commitment, visual integrity, access, and that the development does not result in an increase in the number of beds.

3.11. The Local Plan strategy for tourism seeks to:

i. encourage new tourism accommodation projects and channel them towards the Tourism Zones and the Entertainment Priority Areas of Mellieha…;

ii. facilitate the expansion of existing tourism accommodation establishments in urban areas only;

iii. encourage the upgrading of existing tourism accommodation establishments both in urban and rural areas;

iv. permit new ancillary facilities to the tourism industry which enhance the experience of the visitor and improve the quality of the tourist product such as visitor/interpretation centres, museums, recreation/leisure/entertainment uses, promenades, and to direct them towards established sites for visitor attractions; and

v. resist low quality, poorly designed and inappropriately located tourism related development, especially within the established locations for visitor attractions.

3.12. The Scheme is congruent with the requirements of the tourism strategy for the area. It is noted that although the hotel site is proposed to extend onto the ODZ area, all the buildings will be within the area identified in the North West Local Plan as for “restrained redevelopment”.

Tourism Topic Paper

3.13. The Tourism Topic Paper sets out a strategy for the direction of tourism up to 2020. Since it is based on the analysis of data dating from 1995 – 1999, the specifics of the data analysis do not take into account the substantial changes in tourism over the last 8 years, and does not foresee, for example, the effects of Malta joining the EU, the advent of low cost air fares, the general upgrading of the accommodation, or the impact of VISET / Cruise Liner Terminal on cruise passenger numbers. The strategy envisaged a situation where hotel bedstock demand would range from 18,679 to 39,3798 by 2010, against a supply (in 1999) of 29,592 beds. The hotel bedstock at the end of September 2007 stood at 33,106, representing a shortfall of 6,273 beds against MEPA’s 2010 upper end estimate.

8 The lower figure results from Scenario 4 – decrease annual tourism arrivals to 900,000, and the upper figure

results from Scenario 1 – tourism arrivals continue to increase at the annual average over 1990 – 1999 (4.7%). Ministry for Tourism and the MTA in 2000, based their strategy on a 3% annual increase, resulting in a bedstock demand forecast in 2010 of 35,709.


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3.14. Although the strategy notes that the seaside resorts have “developed their tourist offer” and that they only require ancillary facilities, it also notes that rural localities “have an important part in diversifying the Maltese Islands’ tourist offer, particularly by the development of products which enhance the intrinsic qualities and characteristics of these areas”. The strategy also suggests:

In specific localities future strategies should look at the possibility of rejuvenating an otherwise tired product which is losing its attractivity. This may include redevelopment strategies, diversification strategies, embellishment programmes, and re-positioning strategies.

3.15. The Scheme is congruent with the requirements of the draft Tourism Topic Paper. It will increase the hotel bedstock, and being sited on the edge of the urban area and close to a wide range of recreational facilities available in the hinterland, it is well placed to contribute to the diversification of Malta’s product range.

DEMAND FOR THE SCHEME 3.16. The demand for Scheme has been provided by the developers of the Seabank hotel

and their financial / economic consultants. The arguments presented below justify why the extension is required. It shows that occupancy is expected to be high especially because the hotel is affiliated with international brands – RIU and TUI.

The RIU Brand 3.17. The Hotel RIU Seabank has been operating under the RIU brand in the form of a

franchise agreement since April 2005. The RIU brand is a listed Spanish chain of Hotels, specializing in resort properties. It is has 45,000 beds in 120 hotels in 18 countries, 18,000 employees, and accommodates 2.1 million clients per year.

3.18. In the world of sun and beach holiday accommodation, RIU is a mark of quality, both in management and product, a quality that results in high yearly occupancy average (87%), and loyalty (35% of guests are repeat clients; half a million are holders of the RIU Class brand loyalty card). Product quality and its successful marketing plus efficient management of the whole hotel chain all make RIU Hotels one of the most profitable companies in Europe.

3.19. Other factors in the successful marketing of RIU’s product are the chain’s agreements with the world’s top tour operators, particularly with Germany’s TUI, Europe’s largest tour operator and partner and shareholder in RIU Hotels and Resorts.

Current Trends in Resort Accommodation 3.20. Hotel RIU Seabank is by definition a resort hotel, traditionally well-served by the

strengths of tour operation business. Tour operation business is going through a patch of re-aligning its modus operandi to reflect current ways of marketing and selling a destination – the market is essentially adjusting to achieve economies of scale. A number of industry leaders have merged / been taken over. TUI, as the


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largest European tour operator (and a shareholder in RIU Hotels) acquired the UK household name of Thomsons, and various other mergers are taking place or are in the pipeline, such as the acquisition by Thomas Cook of My Travel.

3.21. Demand in Malta and throughout Europe has grown significantly as a result of the low cost carriers, resulting in substantial increases in shoulder and low season arrivals.

Lack of Beds 3.22. Hotel RIU Seabank has continuously been faced with a shortage of supply of room

stock to satisfy and meet tour operators’ persistent requests and more recently the demands arising from web generated business.

3.23. In 2006 the Hotel RIU Seabank saw its year on year occupancy levels increase to more than 80%, and in the period May through to October an average of 100 clients had to be relocated to other hotels. Despite the fact that the hotel reduced its room allocation to tour operators by 18%, it was again overbooked throughout the summer season. This is despite a 27% increase in room rates over the period 2005 – 2007.

Improving and Diversifying the Product 3.24. In addition to a well-substantiated need for additional rooms, the Hotel RIU Seabank

needs to address other weak points in order to maintain its standing:

• The pool facilities still cover the same footprint as originally constructed in 1991, when the Hotel was still an 80-room property as against the current 282 rooms, rising to 612 rooms should development permission be granted for the current application;

• Current size inhibits economies of scale: All new RIU developments have a minimum of 500 rooms. The size factor is key in ensuring that the Hotel has a room stock level that is commensurate with other RIU hotels and economies of scale;

• The current facilities limit realisation of the hotel’s potential through the provision of a holistic beach resort, as defined by RIU and TUI; and

• The Hotel needs to enhance its winter offering – the ever increasing demand for health and welfare tourism, and the Hotel’s proximity to a number of natural attractions within walking distance, make the development of a high quality spa centre a sine qua non.

3.25. The Hotel is fast becoming a product ideally placed for holidaymakers in both summer and winter season wishing to get away from it all. This brings along with it the all inclusive holiday concept.


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The All Inclusive Concept 3.26. The RIU and TUI vision for sustainable growth for the next decade or so within this

sector is to opt for a dedicated, high quality all-inclusive operation:

• More than 55% of RIU’s hotels worldwide are today all inclusive;

• This concept is no longer limited to ‘remote’ destinations but fast gaining ground within our neighbouring and next of kin competitors; and

• The all-inclusive concept is the holiday product that RIU reports as selling most rapidly.


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4. DESCRIPTION OF SITE AND SCHEME

INTRODUCTION 4.1. This chapter describes the Scheme that is assessed in the EIA. It sets out the

purpose of the Scheme and includes a description of the Application Site and its surroundings. More detailed descriptions of selected elements are also included in the relevant topic chapters of the EIS.

PURPOSE OF THE SCHEME 4.2. The purpose of the Scheme is to extend the current Seabank Hotel at Mellieha Bay

with a further 218 bedrooms for a total complement of 500, and to extend the supporting facilities of the hotel through the provision of extensive landscaping / pool areas, and extension of facilities such as the Spa and restaurants (see detailed description below) to cater for the larger number of customers. The project will be largely located within the area identified in the North West Local Plan as for “restrained redevelopment”. (The only parts of the project located outside this area are parts of the pools and sundecks; these will be located to the immediate west of the existing hotel and pool, and north of the new hotel wing)

BACKGROUND TO THE PROJECT 4.3. The Seabank Group acquired the property in 1984, which at the time included a 9-

room guesthouse. The first major expansion of the hotel took place in 1991 and the hotel opened its doors in May 1992 as an 80-room hotel. The hotel was extended in 1996 for a total of 202 rooms (PA 04548/93) and again in 2001 when the rooms were increased to 251 and a number of amenities added (PA 05220/00).

4.4. The increase in the number of rooms to a more financially sustainable number has always been on the cards for the Seabank Group; however, over the past years different options aiming at increasing the product offer and the amenities available on site were actively considered. In 2004-5, the hotel underwent a major refurbishment and upgrading exercise, which resulted in the addition of further amenities and the total room complement increased to 273 (PA 01745/05). Simultaneously, a number of studies9 were undertaken to look into the possibility of upgrading the entire Mellieha Bay area into a more holistic and coherent tourism destination, with the main driver being environmental rehabilitation.

4.5. The Group explored further ideas to improve the tourism product, including through the construction of attractions such as a golf course, a water park, and self-catering bungalows. A number of these proposals were considered in some detail and are described in later sections of this Chapter.

9 Adi Associates Environmental Consultants. 2005. Regional Environmental Assessment.


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4.6. In April 2005, the Seabank Hotel started operating under franchise with Riu. Riu is one of the larger hotel chain operators in the world, operating over 100 hotels in Europe, Africa, and the Caribbean. Riu is 50% owned by TUI, one of Europe’s largest tourism operators, which provides a unique combination of two forces that normally compete with each other for customer loyalty – tour operator and hotel chain branding. Seabank’s partnership with the Riu chain has helped it to improve the quality of its product, which has resulted in improved occupancy and higher room rates.

4.7. The Seabank Hotel's location is ideal for holiday makers, on short stays or otherwise, who are looking for a 'get away from it all' environment. Such holidaymakers, who are traditionally - albeit, not exclusively - closely linked to tour operator business, feature strongly within Riu's and TUI's product offers. The holiday proposition put to such clients is strongly enhanced in an all inclusive operation, and Riu is accordingly encouraging Sea Bank to expand its size and to adopt such an operation, as described in Chapter 3. The hotel needs to provide additional activities for its guests to participate in, both within the hotel and in surrounding areas, with added animation; and this in turn requires a higher investment in ancillary facilities that must be sustained by improved economies of scale.

4.8. The Riu / TUI vision for the Seabank Hotel accordingly hinges on the hotel’s expansion and potential for providing an all-inclusive package. They aim for:

• A dedicated, high quality, all-inclusive operation;

• A larger hotel that can operate efficiently under the all-inclusive concept and has the scale to provide and operate more amenities and activities (e.g. animation) in a cost-efficient manner;

• A hotel that is designed with Riu’s full participation;

• A hotel with substantial pool and garden areas that are consistent with the needs of a large hotel;

• A hotel that can provide a self-contained holiday;

• A hotel that would be TUI’s main facility in Malta; and

• A hotel that can help TUI achieve the threshold of 12,000 tourists per annum that would make regular charters viable.

OBJECTIVES OF THE SCHEME 4.9. The Scheme’s objectives are to enhance the facilities available at the Hotel and to

achieve the Riu / TUI vision for it. This would be achieved by:

• Expanding the pool and garden facilities to cater for a larger customer base;


21

• Improving the existing Spa to provide additional facilities or services;

• Enlarging and improving the reception area to cater for a larger number of guests;

• Improving the hotel’s product to continue to achieve the quality standards that Riu clients have grown accustomed to;

• Enlarging the hotel by adding a further 340 rooms to achieve the necessary critical mass that would allow the hotel to offer “soft amenities” such as constant animation (entertainers, sports and other activity organisers) that are sought after by Riu / TUI clients;

• Enhancing the winter product through better promotion of the environmental assets in the vicinity of the hotel and eco-driven activities such as bird watching, horse riding, trekking, nature trails, water sports (e.g. wind surfing and sailing) at Mellieha Bay, etc.; and

• Further promoting health and welfare tourism through the hotel’s extended Spa facilities, which could also complement the nature tourism aspect of the hotel’s winter offer.

4.10. In attaining these objectives, the project will be consistent with the broad objective of improving the tourist product that is being pursued by Malta's tourism industry. Malta has in recent years seen marked changes in tourism patterns and expectations. Many inferior accommodation products have had to discontinue operations as they are no longer relevant to the tourist demand being experienced. On the other hand, hotels with a successful product must invest both to maintain their competitiveness with competing overseas resorts, and to maintain Malta's overall capacity.

SITE DESCRIPTION AND LOCATION

Location 4.11. The Scheme site lies at the south-western corner of the head of Mellieha Bay in an

area known as Ic-Cens, located to the immediate west of and behind the Seabank Hotel (see Figure 4.1). The Site is roughly square as shown in Figure 4.1. A large part of the site is currently used as a surface level car park (see Figure 4.4). The rest of the site is agricultural land in various stages of abandonment or use. Those fields that are still in active cultivation are mainly used to grow garden vegetables. Technical Appendix 3: Agriculture Baseline Survey includes details of the fields in the Scheme site and its surroundings. The fields are bounded by traditional rubble walls and a few include water reservoirs.

4.12. A few carob trees, prickly-pear plants and a few other fruit trees are present along the margins of some of the fields. The rest of the trees on site are those within the hotel grounds and mainly consist of palm trees, banana trees and recently planted


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olive trees. A tree survey is included in Technical Appendix 4: Ecology Baseline Survey.

4.13. A solitary building exists at the far end of the car park. This was originally a farmhouse which has since been restored and converted into a temporary bungalow accommodation, which serves as an extension to the hotel. Access to this bungalow is via a private path leading from the hotel. There is a pending planning application (PA 04804/05) that seeks to sanction this development.

Zoning 4.14. The Key Diagram of the Structure Plan for the Maltese Islands indicates that the site is

Outside the Development Zone (ODZ). The Temporary Provisions Scheme also shows the site as ODZ. The Ghadira Isthmus Strategy Map (Map 34A) (see Figure 4.8) of the North West Local Plan (NWLP)10 shows much of the Application Site as for “Restrained Redevelopment”. The Ghadira Isthmus Protected Areas Map of the NWLP (Map 34) (see Figure 4.9) shows that part of the site is designated as an Area of Agricultural Value and a number of protected features are in the vicinity of the Site including:

• The Il-Hofra marshland - Level 1 Area of Ecological Importance and Level 1 Site of Scientific Importance [Scheduled under the Development Planning Act];

• The beach at Ghadira – Level 4 Site of Scientific Importance [Scheduled under the Development Planning Act];

• The Ghadira Special Area of Conservation, Special Protection Area and Natura 2000 Site [under LN 311 of 2006 and GN 112 of 2007];

• A Nature Reserve [under the Protection of Birds and Wild Rabbits (Amendment) Regulations 2003 (LN 41 of 2003)].

• A Ramsar Site (Ghadira Nature Reserve);

• Maritime Garrigue at id-Dawra tat-Torri – Level 2 Area of Ecological Importance [GN895 of 2002];

• WWII Beach Post at Id-Dawra tat-Torri – Grade 2 Historic Building [GN 895 of 2002]; and

• WWII Defence Post at Ta’ San Niklaw – Grade 2 Historic Building [GN 895 of 2002].

4.15. The National Protective Inventory identifies eight archaeological features in the Mellieha Bay area. A number of Grade E11 archaeological features have also been

10 MEPA, 2006. The North West Local Plan. 11 A Grade E archaeological site is one that was known to exist in the past but is no longer visible, or has been

inferred from literature. These sites are afforded precautionary protection through the establishment of a


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noted in the inventory. None of these features exists within the Scheme site but two systems of cart ruts are found close to the site.

4.16. The Structure Plan for the Maltese Islands designates this part of the island as a Rural Conservation Area.

4.17. The Site is located outside the Drinking Water Safeguard Zone12 .

Access

4.18. Access to the site is via two roads – Marfa Road, which leads from the centre of Mellieha to Ghadira Bay and from the Ta’ Pennellu area via the Mellieha By-pass.

Services

4.19. Water, electricity, and foul drains are available on site and serving the existing Hotel and adjacent developments. The requirements of the Scheme will not present any problems to the existing infrastructure.

Site Topography 4.20. Figure 4.2 represents the site levels. It shows that the elevation of the Site varies

between 5m and 14m above sea level, and that it slopes to the north - the average slope gradient is 40.

sizeable buffer zone in the general area of the site until the area can be properly inspected and the presence of such remains confirmed or otherwise.

12 Malta Resources Authority website: www.mra.org.mt on 14th March 2006

http://www.mra.org.mt


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Figure 4.1: Site location


25

Figure 4.2: Site Topography


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Surrounding Land Uses 4.21. Figure 4.3 describes the land uses surrounding the Site. The principal uses in the

vicinity of the Site are agriculture, commercial, and residential.

Agriculture

4.22. The area to the east, south and west of the Site is predominantly agricultural land (see Figure 4.4). Most of the land is in active agricultural use (various crops); other fields are abandoned. The fields tend to be larger to the west of the Site (at Il-Hofra area) than those to the east and south.

4.23. A series of reservoirs are found in the area. One in particular has water channels running to an abandoned donkey-driven water mill that is located to the west of the site (see Figure 4.5).

4.24. A detailed survey of the agricultural land within the A of I of the Scheme is available in Technical Appendix 3: Agriculture Baseline Study.

Commercial

4.25. The commercial land uses close to the site are related to tourism and food & beverage. Apart from the Seabank Hotel itself, there are the Mellieha Holiday Complex and the Tunny Net Complex. These are located to the northwest and northeast of the site, respectively.

4.26. A number of commercial premises are located on the beach. These kiosks usually operate during the summer months and offer several services include umbrella / sunbed hire and food and drink purchase (see Figure 4.6).

Residential

4.27. A residential area is located to the northeast of the site, along Marfa road (see Figure 4.7). This area consists of a mix of flats and apartments. Some of the flats / apartments are summer residences while others are offered as holiday apartments.

4.28. A few farmhouses are located outside the residential area. Such dwellings form part of agricultural land.

Recreation

4.29. The Ghadira beach is found to the north of the site. This is a prime summer recreational area that is used by locals and tourists alike. Apart from sea-related activities (swimming, sunbathing, and water sports), the area is also a magnet for summer barbecues.


27

Figure 4.3: Land use

PA06090/05: Construction of a Micro Enterprise Park: Environmental Planning Statement

28

Figure 4.4: Agricultural land surrounding the Site

Figure 4.5: Remains of the donkey-driven water mill


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Figure 4.6: Mellieha Bay during the summer

Figure 4.7: The residential area


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Figure 4.8: North West Local Plan: Ghadira Isthmus Strategy Map: Map 34A


31

Figure 4.9: North West Local Plan: Ghadira Isthmus Protected Areas Map: Map 34


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DESCRIPTION OF THE SCHEME 4.30. Within the Application Site, 8,378 m2 will be built-up (including the existing building)

and a further 7,856 m2 will consist of the outdoor pools and deck areas 4,524 m2 will be landscaped gardens.

4.31. The Scheme consists of the addition of 218 guest rooms to the existing hotel and the enlargement of existing facilities (reception, landscaped gardens, pools, and restaurants) to cater for the larger number of customers and to meet the requirements of the Riu brand.

Alternatives Considered 4.32. In considering alternatives to the Scheme, these focused on alternative layouts and

designs. Alternative site considerations are not relevant seeing that the Scheme is an extension to an existing establishment. Alternative uses of the site have been considered before and were described in the Project Description Statement prepared for this Application. These are summarised in the following sections.

4.33. In arriving at the Scheme, a number of alternative proposals were elaborated over the past years by the Seabank Group in their efforts to implement the hotel’s overall strategy. These included:

• Proposal 1 – A waterpark and self-catering tourist accommodation;

• Proposal 2 – Extension to the hotel and self-catering tourist accommodation;

• Proposal 3a – The Scheme as described in the first draft of the EIS i.e. extension to the hotel and its facilities;

• Proposal 3b- Adjustments to Proposal 3a following consultation with MEPA; and

• Proposal 4 – The Scheme.

Proposal 1 – Waterpark and self-catering tourist accommodation

4.34. This proposal was conceived in 2005 as an extension to the Seabank Hotel and the provision of an innovative and unique attraction in the form of a waterpark. This proposal was viewed as part of an area-wide upgrading and rehabilitation project for the Mellieha Bay area – part of the Destination Mellieha Project, which had been submitted to the Government of Malta in 2004. The project consisted of an extension of the hotel in the form of self-catering bungalow accommodation, basement parking facilities, and the waterpark, which would include a variety of rides, restaurants, and leisure facilities specifically designed for all age groups.

4.35. The project was designed to take advantage of the existing topography of the site.

4.36. A development permit application (PA 00720/05) for this proposal was submitted in 2005 but this was eventually changed to the proposal outlined as Proposal 2 below.


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4.37. Figure 4.10 shows an artistic interpretation of proposal 1.

Proposal 2 - Extension to the hotel and self-catering tourist accommodation

4.38. This proposal, which was developed in 2006, consisted of a 246 room extension to the main hotel, a 713 m2 outdoor pool, a 428 m2 indoor pool, a 763 space underground car park, and 68 self-catering bungalows set in landscaped surroundings.

4.39. This was effectively a development on Proposal 1 and indeed the same application number was retained and fresh plans submitted in October 2006. The application was re-published in November 2006 but no further progress was made until the current proposal.

4.40. Figure 4.11 shows a block plan of the development proposed in Proposal 2.

Proposal 3a – Extension to the hotel and its facilities.

4.41. This option was the subject of the first draft of this EIS, which was submitted to EMPA and statutory consultees in December 2007.

4.42. A number of different options were considered in developing the Scheme. This proposal was considered in detail on the basis of two main guiding principles:

• The extension is to be sited on the eastern side of the Application Site in order to keep the construction as far away as possible from the sensitive Area of Ecological Importance located approximately 100m from the western boundary of the Application Site; and

• The layout and design of the Scheme must take into consideration the visual effects such that it would have the minimum visual impact possible when viewed from outside the site.

4.43. The above considerations, together with the needs of the hotel were given consideration throughout the design phase of the project. The new extension presented as part of this proposal departed from the existing block hotel building and terraced down in three directions towards the existing terrain. This allowed the Scheme to develop in a pyramidal fashion with guest rooms located on the exterior of the building volume to take advantage of views, light, and ventilation. This construction philosophy resulted in the creation of a central core at the lower levels, that would have accommodated parking facilities on some of the floors. This proposal reduced excavation and minimised both cost and construction waste.

4.44. Well-sized terraces were provided to make it possible to include, within the building volume, green belts that would allow the landscaped areas to be provided at ground level to overlap onto the proposed extension, thereby creating a continuum between landscaping and built up areas.

4.45. Figure 4.12 shows a block plan of Proposal 3a.


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Figure 4.10: Artistic interpretation of the Waterpark and bungalows proposal


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Figure 4.11: Block Plan of Proposal 2


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Figure 4.12: Block Plan of the Proposal 3a (as presented in the first draft of this EIS)


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Proposal 3b – Variation on proposal 3a

4.46. This proposal was the first in a number of additional changes made to the Scheme since the first draft of the EIS was submitted to MEPA. These changes were made following input from MEPA and statutory consultees on the Scheme proposal. As illustrated in Figure 4.13, a main change at this stage related to the reduction of the footprint of the extension as well as its overall height.

4.47. This proposal also included changes to the façades of the existing building to ensure that the building design of the existing hotel would be in accord with that of the extension such that it becomes less obvious that the Scheme is in fact an extension to an existing building. Such changes, for example, additional columns, are also required to ensure that the existing building can support the additional floors.

4.48. Figure 4.13 provides a block plan of Proposal 3b.

Proposal 4 – The Scheme

4.49. Following further discussions with MEPA, the footprint of the proposed extension was again reduced to contain the entire building within the area zoned as for “Restrained Redevelopment in the North West Local Plan, as was the height of the extension (which is now in line with the existing building). Considerations were also made regarding traffic flows and entry points to the car park. Other changes considered included the relocation of the reception area to the side of the building (fronting the terminal stretch of the Mellieha By-pass, swapping places with the existing restaurant. However, to be in line with RIU requirements, this idea was subsequently discarded.

4.50. This last proposal therefore is based on an extension that is further reduced in footprint and height. Vehicular access to the car park is from the west of the existing hotel as illustrated in Figure 4.14. Figure 4.15 provides a rendered image of the Scheme.

The Zero Option

4.51. The zero option considers the impacts from non-implementation of the Scheme. Should the Scheme not go ahead the current site would continue to be used as a carpark and agricultural land will continue to be used. If the Scheme does not go ahead, there may be a risk to the feasibility of the existing hotel.

Alternative Assessment

4.52. Proposal 3a sought to downsize the initial proposals (1 and 2) to reduce the scale and therefore any associated impacts of the project. Following a detailed impact assessment and discussions with MEPA, the design was adapted further to minimise such impacts where possible. The footprint and height of the building was further reduced in the latest option (Proposal 4), which is the subject of this EIS. As a result of these changes, the number of rooms were also reduced from the original 612 to 500.


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Figure 4.13: Block plan of Proposal 3b

Car Park entrance (200 spaces)

Reception/lobby extension Restaurant Terrace

Main Pools Pool Bar and Snack bar Children’s Pool


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Figure 4.14: Block plan of Scheme (proposal 4)

Reception/Lobby

Restaurant Terrace

Garage entrance

AnimationTheatre

Rain WaterChannel

Pool Bar & Snack

Reception/Lobby

Restaurant Terrace

Garage entrance

AnimationTheatre

Rain WaterChannel

Pool Bar & Snack


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Figure 4.15: Rendered image of proposed Scheme


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The Scheme 4.53. The Scheme consists of the net addition of 218 guest rooms to the existing hotel and

the enlargement of existing facilities (reception, landscaped gardens, pools, and restaurants) to cater for the larger number of customers and to meet the requirements of the Riu brand.

4.54. The Scheme will also include:

• An upgraded and extended reception area;

• The re-location of administrative areas and facilities;

• Extension and upgrading of the existing gym;

• Creation of an indoor pool area at the upgraded Spa centre;

• Enlargement of the outdoor pool and pool deck area;

• Upgraded and extended catering facilities;

• Provision of adequate car parking facilities;

• Re-location and upgrading of the existing plant room;

• Provision of extensive landscaped areas; and

• The relocation of the car park and service entrances to the front of the building to minimize land take from the agricultural land to the west of the hotel.

Floorspace Allocation 4.55. The distribution of land uses are described in Table 4.1 and Table 4.2.

Table 4.1: Floorspace allocation: existing hotel and proposed extension Land Use Existing Hotel Proposed Guest Rooms 282 500 Beds 564 1000 Restaurant covers 895 1150 Health Club/ Spa & shops (m2) 985 1099 Conference (m2) 856 nil Bars & coffee shops (m2) 1519 1551 Parking 100 200

4.56. It is the intention of the Applicant that the Seabank Riu Hotel will become an all-inclusive resort. This means that guests will have an almost exclusive use of the hotel including the health club and most of the F&B facilities. Only 22 per cent of the total F&B floorspace will be open to the public, i.e. the Maltese Speciality Restaurant (425m2) and the Jungle Restaurant (474m2). Open spaces will be landscaped.


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4.57. The extension will have seven levels, with some floors located below the existing soil level and the top floors restricted and terraced in order to respect the road gradient.

4.58. As can be seen in Table 4.2, the design of the building, including its departure from the block form of the existing hotel, its terracing, and its pyramidal form, results in smaller upper levels.

4.59. Table 4.2 describes the site coverage of the different facilities proposed.

Table 4.2: Proposed facilities Level Facility Area (m2) (

-1 New gym 132 -1 Family Entertainment Area 211 -1 Maltese Specialty Restaurant 484 -1 Spa Centre (pool area) 52 -1 Spa Centre (deck area) 178 -1 Jungle 675 -1 Mariner’s pub 85 -1 Family Entertainment 786 -1 Spa Centre 504 -1 Storage & plant room 1,433 -1 Access to Spa & Familt Entertainment 86 -1 Garage 7,142 -1 Access to carpark & Loading/Unloading 1,009 0 Outdoor pool 1,733 0 Outdoor pool (deck area) 6,123 0 Internal dining area / restaurant 1,000 0 External dining area 230 0 Shops 48 0 Specialty Restaurant 221 0 Fire escape 24 0 Admin entrance 17 0 Spa Upper Level 185 0 Public toilets 1,018 0 Reception & Lobby 577 0 Lobby bar 419 0 Specialty Restaurant 501 0 Night Club 797 0 Stores 290 0 Kitchen & BOH13 1,646 1 Lift lobby 315 1 Guest rooms 89 no 2 Lift lobby 314 2 Guest rooms 115 no 2 Storage 46 3 Lift lobby 218 3 Guest rooms 113 no 3 Storage 46 4 Lift lobby 102

13 Back-of-house


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Level Facility Area (m2) ( 4 Guest rooms 110 no 4 Storage 46 5 Lift lobby 102 5 Guest rooms 73 no 5 Storage 46

Access and Parking

Access

4.60. The Hotel customer parking currently provided on the Application Site is accessed from a left turn in / out entrance onto Dawret il-Mellieħa (an arterial road with a central barrier). Existing service un/loading occurs at the current service entrance along Dawret il-Mellieħa; this creates a safety hazard on the arterial road. Existing access for tourist coaches is at a left turn in / out slip road at the main entrance drop off from Triq il-Qammieħ (an arterial road with central barrier); the inadequate layover areas result in a safety hazard at the exit.

4.61. Access to and from the proposed car park that underlies the extension is planned to be to the west of the slip road at the main entrance along Triq il-Qammieħ. Service vehicles will use the same entry / exit point, see Figure 4.14. Details on these provisions are included in the accompanying Traffic Impact Statement.

Parking

4.62. The Scheme provides a total of 200 parking spaces for vehicles. Access to the car park in the basement will be from a single entry / exit point on Triq il-Qammieħ. The access point is illustrated in Figure 4.14.

CONSTRUCTION

Timing 4.63. Excavation of the Application Site and construction of the extension to the Seabank

Hotel is anticipated to take 6 months. Excavation will be carried out over 2 months and construction will take three and a half months. Finishing works are anticipated to take between 2 and 3 months and landscaping the final 6 weeks. The timing of the various activities is described in Figure 4.16.

Site Operations 4.64. The works will be undertaken in accordance with the Environmental Management

Construction Site Regulations, 2007, including:

• A site manager will be appointed;

• A site billboard / notice board will be erected;


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• Stone cutting will be undertaken in an enclosed area or using a dust extraction and collection system;

• Loose building materials that are to be stored on site will be kept in sturdy, sealable containers;

• The Application Site will be kept clean and rodent control will be implemented, as described in Schedule 1 Regulation 7;

• Hoardings and barricades will be erected as described in Schedule II, Regulation 6;

• Excavation will be carried out between Monday and Saturday, except public holidays, from 07:00 to 20:30;

• Construction will be carried out on all weekdays, except public holidays, from 07:00 to 20:00, and 07:00 to 13:30 on Saturdays;

• No excavation or construction works will be carried out between July and September;

• Dust emissions will be controlled as described in Schedule III of the draft regulations;

• Maximum noise levels will be kept at or below 110dB as stipulated in Schedule IV of the draft regulations;

• Health and hygiene will be addressed as described in Schedule IV of the draft regulations;

• The Site amenities (site office, waste management areas, storage areas, etc) will be located in a dedicated area on site (see Figure 4.26);

• Pedestrian and vehicular flow along the surrounding streets will not be interrupted. All excavation and building activity will be set back from street boundaries; and

• A site safety officer will be appointed to oversee the safety requirements on Site and ensure adequate safety provisions are in effect throughout Scheme construction.


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Figure 4.16: Construction timetable


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Landscaping 4.65. The landscaping scheme being proposed is intended to return a large proportion of

the unused area back to nature, in part to re-establish a Tetraclinis woodland environment in the area. The Tetraclinis articulata (Sandarac Gum Tree, Mlt. Sigra ta’ l-Gharghar) in the Gnien Ingraw area represents the second largest population of the Arar in Malta. Though there is still no concrete scientific evidence, this and another population also at Mellieha (located in the Wied tal-Mizieb area), may have once been two distinct populations interacting at their margins thus providing further incentive for restoring the two sites back to their natural state.

4.66. Therefore, the landscaping proposal is for the creation of three different zones labelled A-C immediately around the western and southern boundaries of the hotel perimeter (see Figure 4.17).

4.67. The agricultural zone which immediately surrounds the entire North to Northwest sector of the hotel outdoor facilities will retain the current agricultural setting with some features reinforced to highlight aspects of Maltese agricultural production. Although the accommodation will be entirely catered for by the hotel, the landscaping and associated activities of this area will be given to agriculture-related practices such that aspects of agro-tourism will also be included. Zone B will be less restrained and Zone C should be as wild as possible allowing for the natural development of a plant community compatible with a small open woodland. However, the primary attention will be to give the different areas a selection of different colours, fragrances, texture and an overall organic feel. Emphasis will also be made on a smooth transition between the zones A, B, and C. If well managed, the three zones can attract wildlife. The zones will be divided as follows:

• Zone A: Agriculturally important trees and herbs;

• Zone B: Garrigue/Steppic species; and

• Zone C: Open woodland with few trees (Tetraclinetum dominated by Sandarac)

4.68. Technical Appendix 3 describes each of the zones in more detail.


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Figure 4.17: Landscaping zones


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Excavation 4.69. The total volume of material to be excavated from the site is estimated at 31,400m3.

The depth of excavation varies in different areas; the site gradient also contributes to this variation in excavation depth. The projected height of excavation is expected to vary from a minimum of 6.0 meters close to the existing hotel building and increases to 13.5 meters further uphill along Triq Dawret il-Mellieha.

4.70. Geo-technical studies on the material to be excavated have been carried out in December 2007. Laboratory results are included in Appendix 1 and a detailed review of the geology of the area is found in Technical Appendix 2: Geo-environmental Baseline Study.

4.71. Soil present on site within the areas to be excavated will be stripped and stored in a specially dedicated area on site (see Figure 4.18) and subsequently used in the landscaping scheme. Any extra soil will be carted away in accordance with instructions to be given by the Department of Agriculture in line with the Fertile Soils (Preservation) Regulations.

4.72. Rubble walls will be dismantled and the stones stored for re-use in the landscaping scheme on site. Construction of new rubble walls will be necessary to re-create boundary walls and to provide other rustic features in the landscaping scheme. Any extra stones will not be dumped; instead they will be used to maintain rubble walls in the fields behind the hotel or re-utilised in other areas off site.

4.73. Excavation is expected to take 2 months; management of inert waste is described in Chapter 5.

4.74. A pre excavation survey was carried out to determine the pre excavation levels as well as the benchmarks. The pre excavation survey is reproduced in Figure 4.19.

4.75. Excavation shall be carried out by means of heavy duty and medium duty excavators such as rotary trenchers, hi-macs and JCB’s. Excavated surfaces will then be trimmed to the required levels using hand tools. No explosives will be used for excavation or any other purpose during the construction of this project. Excavation levels are shown in Figure 4.20.

Table 4.3: Traffic generated during excavation

Volume to be excavated & removed from Site 31,400 m3 Bulking Factor = 1.3 Bulked Volume = 40,820 m3 Volume / Truck = 20m3 No. of Truck Trips = 2,041 Duration of trips = 40 days Average Rate per day = 51 Trips / day

4.76. On completion of the excavation works a post excavation survey will be conducted to determine the precise excavation levels.


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Construction works

Phasing

4.77. Following the excavation of the site, the construction and finishing works will be phased over a four and a half month period, as follows:

• Construction Phase 1;

• Construction Phase 2;

• Finishing Phase 1;

• Finishing Phase 2; and

• Hard and soft landscaping works.

It is noted that the phasing will overlap as described in Figure 4.16.

Construction Plant

4.78. The following equipment is expected to be deployed on site at any one time:

• 3 Tower Cranes;

• 1 mobile crane;

• 8 ready Mix Trucks (per day);

• 8 Delivery Trucks; and

• 1 Delivery Trailer,

as well as generators, welding machines, water tankers, air compressors, bobcats, and high-up lifters.

4.79. The location of the tower cranes and general site layout is described in Figure 4.18.

Temporary works, site enclosure, site access points and storage

4.80. During the construction stage, the site for the proposed extension of the Seabank hotel will have one access point manned by a temporary gate (see Figure 4.18). The gate (Access Point 1 on Figure 4.18) will be located on the South-eastern perimeter of the construction site where the access road is linked via two roads (Triq il-Marfa and Dawret il-Mellieha). This gate will give access to the construction site, site offices and storage areas.

4.81. During the construction stage the site and the area for temporary Site offices/storage will be surrounded by a perimeter fence. The temporary perimeter fence will consist of a 2m high chain link fence, which will be dismantled on completion of the construction works.


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4.82. A billboard sign measuring 1.75m x 2.5m will be installed on site throughout the construction phase of this project. The sign will be located next to access point 1, and will display the name of the project, the responsible architects, the site manager, and the project completion date together with a list of contractors involved in this project.

4.83. The temporary Site office comprises an office for the Resident Engineer/Project manager. The contractor’s compound includes an office for the site architect, stores, and facilities for the workers.

4.84. During the construction phase, the temporary storage areas for the plant, machinery, and material will also be located in the temporary construction camp as shown in Figure 4.18.

4.85. After the completion of the construction works on site, the area housing the temporary construction camp will be reinstated to its original state as part of the landscaping and reinstatement works.

Vehicle routing and traffic management

4.86. Construction vehicles will access the site via Dawret il-Mellieha (the Mellieha By-Pass).

4.87. A Traffic Management Plan will be prepared and will be submitted for the approval of the Local Council, the police, and ADT. This will mainly consist of the installation of traffic signs indicating a construction site exit.

4.88. Parking provision will be allocated in the temporary construction camp; however, due to the nature of the works and the requirement for the mobility of cranes and other large machinery, on site parking will be limited and controlled.

Raw materials

4.89. The Proposed extension will be constructed as a series of cast in situ concrete flat slabs supported on a series of columns placed on a grid. External walls are characterized by large openings leading to the various terraces. The external walls or glazed areas are to be insulated to minimize heat gains in summer and avoid losses during the winter period. Internal walls will consist of light weight partitioning to minimize dead weight on the slabs, thus increasing the efficiency of the structure and reducing the construction phase to create fewer disturbances on site.

4.90. Raw materials required during construction are presented in Table 4.4. Construction materials will be delivered to the Site in relatively small quantities, as required for immediate use. Temporary holding areas are identified within the Site for materials to be unloaded from transport, see Figure 4.18 (area indicate for construction material). Movement of construction materials within the Site will be by tower crane.


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Table 4.4: Raw materials required during construction

Item Materials Amounts 01 Concrete • Foundations 1,500 m3 • Columns 450 m3 • Slabs 5,000 m3 • Pools 590 m3 ESTIMATED VOLUME OF CONCRETE 7,540 m3 02 HCB walls 8,000 m2 03 Insulated Partitioning walls 16,500 m2 04 Insulating material to horizontal surfaces 5,300 m2 05 Glazed areas 4,200 m2.

Runoff and aquifer protection

4.91. The perimeter of the Application Site will be fenced off and the existing roadside culvert along part of the eastern boundary protected and maintained. A low 3-coarse wall will be erected along the entire western boundary of the site (along the side of the rural road) so as to prevent surface run-off from entering the site. During excavation, rainwater landing on the site will be channelled to appropriate collection points and once the back-wash reservoir for the pools is excavated, this will be used to collect rainwater. This and the larger rainwater reservoir, will be constructed early in the construction phase so that they may be used for stormwater management during the construction phase.

4.92. Refuelling of equipment will be carried out off site.

Emissions

4.93. Dust emissions will be reduced though the adoption of a number of dust mitigation measures during the excavation and construction stages as described in Chapter 12. These will include: watering down the excavation areas to limit any generation of dust to within the site boundary, covering trucks carrying-building material out of site, use of a wheel washing facility for construction vehicles exiting the site, containment of building materials during construction, and erection of a fence around the entire construction perimeter as discussed above. Any spillages resulting from the construction activity along or across a public way must be removed each day and public sidewalks and public areas within 10 metres from either side of the extremities of the construction site including sidewalks and roads will be swept or vacuumed.

4.94. In order to reduce noise emissions, all equipment will be provided with effective silencers and all plant and equipment will be fitted with noise-suppression devices; work will be restricted to normal working hours. All plant to be used on this project will be in possession of the necessary certification and licences. Noise suppression methods prescribed in Schedule IV of the Environmental Management Construction Site Regulations must also be adhered to.


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Health and safety

4.95. All on-site personnel will be made aware of the health and safety requirements. Site safety practices will be initiated and maintained throughout the period of construction, and will include specific emergency measures in case of accidents. A first aid station will be available at the Temporary Construction Camp next to the Site Offices. Emergency telephone numbers and contact numbers of doctors designated to attend to the site personnel will be made available at the site office.

Construction Period and Personnel

4.96. The number of persons working on the project is expected to vary during the different phases of the project. The three main phases of the project are:

• Excavation phase;

• Construction phase; and

• Finishes including Mechanical & Electrical works.

4.97. The excavation phase is the phase with the least number of workmen on site, while the number of workmen on site would reach its maximum during the overlap between the construction and finishing phases. During this period construction workmen and contractors working on finishes would be working simultaneously. Table 4.5 gives the number of personnel on site during the different phases.

Table 4.5: Employment during excavation and construction Phase Number of workmen Excavation phase 6-8 Construction Phase 30-35 Finishes 40-50

Project Management 4.98. A project management team will be responsible for construction operations; they will

work closely with the contractors’ site management team to ensure that there is full control and responsibility of on-site activities. The project management team will also be responsible for liaising with the Local Council and the neighbours to ensure that the potential for complaints is minimised and where complaints are made, they are addressed with due expediency.


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Figure 4.18: Site layout during construction


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Figure 4.19: Pre excavation survey


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Figure 4.20: Excavation plan


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SCHEME OPERATION 4.99. This section describes the operation of the Scheme as required by the ToR. The

main focus is on residues and emissions, water consumption, storage and management, impacts on water quality in the bay, power requirements and energy consumption and management.

4.100. The key operational aspects in respect of the above are limited to the increase in the number of people in the area – residents, guests, patrons, and employees, and the effects that would result from this increased activity. Traffic-related aspects are addressed in the Traffic Impact Statement.

Employment 4.101. The Scheme is expected to employ a total of 202 people over and above those

currently employed by the Hotel, see Table 4.6. In addition, a total of nine other persons not directly employed by the Hotel, are expected to work in the Hotel including Spa / Health Club staff, shop attendants and tour representatives.

Table 4.6: Estimated employment

Employment Current Current

+ extension

Room attendants/public area cleaners 42 90 Maintenance and gardening staff 10 21 Front Office 13 24 Food and Beverage Staff 121 187 Sales and Marketing 4 7 Administration 10 14 Concierge 3 5 Kitchen Brigade 36 78 Animation - 15 Total staff 239 441

Hours of Operation 4.102. Since the Scheme is a hotel, it will operate 24 hours a day for seven days a week.

The Management Offices will have normal office hours of operation from 7 am to 6 pm. Food and beverage outlets operate for longer hours depending on their trading licence but are assumed to operate until 2 a.m. The Spa facilities would operate from Monday to Sunday between 7 am and 10 pm.

Services and Utilities

Existing services

4.103. The site is already serviced with all utilities (electricity, water, sewage, telecommunications) and servicing the extension will be a straightforward affair.


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Electricity

4.104. The present electricity load at the existing Hotel is 1600 kVA at a power factor correction of 0.99. The hotel also produces RO water at a rate of 80m3/day. For emissions from electricity generation please refer to Chapter 12.

Water

4.105. The overall consumption of water at the existing hotel averages at 0.18 m3 per guest night, which roughly equates to 85 m3/day in winter and 107 m3/day in summer. The balance between the RO water production and the actual average usage is mains and second class water.

4.106. The reject from the RO plant (brine at 37,000 µs) is discharged to sea via a pipeline. Rate of discharge is approximately 6 m3/hr.

4.107. Other discharges to the marine environment consist of seawater which is pumped via a borehole and used to cool the chillers. This is discharged at a maximum rate of 300m3/hr at 21°C at the discharge point and with a maximum velocity of 2.35m/s.

4.108. No new discharges will be added as a result of the Scheme. Existing infrastructure will be utilised for the Scheme and while volumes of discharges will increase no new material will be added. Discharges will be in line with relevant discharge permits.

New or extended services

4.109. The services to be installed at the Scheme will be designed to be environmentally friendly utilising the latest technologies to minimise on the use of fuels and, where possible, use renewable energy.

4.110. The Scheme will utilise the following infrastructure services:

• Extra Low Voltage Systems:

o Fire Alarm System: The present fire alarm system will be extended by 450 optical smoke detectors, 30 manual call points and 50 sounders to cover the new areas;

o CCTV: The current CCTV system will be extended to include 30 more cameras to cover the new corridors/public areas;

o CATV: The current CATV system will be enlarged by 340 new points to cover TV points in all 340 new guestrooms;

o Telephone System: The PABX system will be extended by 370 extensions to cover all the 340 new guestrooms, services rooms, lifts and public area; and

o Guest Room Management System: 340 stand alone guest rooms management system will be installed in all guest room to optimise the use of electricity. This system will ensure that (i) the A/C units in the guestrooms will stop


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operating when the balcony doors are opened, and (ii) all lights, A/C units, and TVs are automatically switched off when guests leave their rooms.

• Mechanical Services:

o Fire Fighting System: The present hose reel fire fighting system will be extended by 20 hose reels to be installed in all service guestrooms. The fire pump system will also be changed to include an inverter controlled pump to optimise the use of electrical energy on the pump;

o Cold Water System: A new 150m³/day RO system will be installed to cater for the production of cold water and hot water for the new extension. The sea water RO system will be supplied with an energy saving exchange high pressure system to cut down the electrical consumption of the system to 4kW/m³ of water produced. The 150m³/day RO consuming 4kW/m³ will consume a total of 600kWh in one day of 24 hrs production. The 150m³/day will cater for 100% of the water needed in this extension for hot and cold water systems;

o Hot Water System: 23m³/day of hot water will be produced by 1 x 500kW cast iron sectional hot water boiler working on light heating oil. Two 6m³ calorifiers will be installed in the same plant room. Cold water feed to the calorifiers will be through solar panels to cut down on the amount of light heating oil;

o Irrigation System: Water for irrigation purposes will be provided by drip irrigation connected to an on-site storm water reservoir;

o Access Control: Stand alone access control will be used on all guest room doors. The system will be interfaced with the guestroom management system; and

o Pipe work: All pipe work used will be environmental friendly and will be made from recycled material (PPR).

o Reservoirs: The following reservoirs will be provided:

§ RO water: 2 x 182 m3;

§ Second class water: 1 x 182 m3; 1 x 400 m3;

§ Fire fighting water: 1 x 182 m3; and

§ Storm water: 1 x 500m3

• HVAC System:

o Extraction: 8 air changes for each guestroom bathroom will be carried out through roof top extraction fans working at a sound level of 35dBA at a distance of 1m;


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o Air Conditioning: A water-to-air system will be used to air condition the new extension. All fan coil units installed in the rooms will have a noise level of 35dBA at a distance of 1m. These will be installed with 3-way valves thus optimising the use of chilled and hot water. Chilled water will be at 9°C - 11°C whereas hot water produced by boilers will be at 50°C. Chilling will be carried out by 2 x 550kW sea water cooled chillers14 installed at basement level. The proposed sea water chiller has the highest COP of 4.5, thus cutting down on at least 20% of the electrical energy consumption and does away completely with the use of cooling towers and air cooled condensers. Heating will be carried out by one 500kW hot water boiler working on light heat fuel oil. The two boilers will be separated to ensure a low heating water temperature of 50°C for HVAC and 70°C for hot water, thus reducing fuel consumption.

• Electricity:

o Main Electrical Supply: The present electrical load will be upgraded by 1000KVA to cater for the new HVAC/Electrical load. The entire electrical load will be power factor corrected to 0.99, thus cutting down by at least 8% on the running of fuel used by EneMalta to produce the 1000KVA. This 1000 kVA upgrade will be split as follows:

o 550 kVA of A/C power (an average consumption of 3 hrs/day in winter and 12 hrs/day in summer);

o 100 kVA to run the plant (an average consumption of 16 hrs/day); and

o 350 kVA for general lighting and power (an average consumption of 8 hrs/day).

o Stand by generator: A new 500KVA diesel standby generator will be installed to cover all the lighting and power except for the HVAC. The above will be installed at basement level and will operate at 70dBA at a distance of 1m.

o Light Fittings: All internal light fittings will have energy saving lamps both for guest rooms and public areas. Corridor lights will be sensor controlled to cut down on light consumption whereas landscape lighting will be specifically chosen to cut down on any light pollution.

• Lifts:

o Four passenger lifts and two service lifts will be installed in the new extension. The lifts will be machine room-less lifts, thus doing away with motor rooms at roof level. The lifts will be VVVF, thus ensuring a reduction in energy consumption on a 2-speed control system. The lifts will be supplied with an up and down fully collective control, duplex control, and automatic

14 The existing system will be used.


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evacuation system, thus cutting down on the amount of useless trips. Duplex control lift will be supplied with one call button per landing. A 900mm lift door opening will be allowed for wheelchair access.

• Pools:

o The Scheme will include three pools. The pool volumes are as follows:

§ Children’s’ outdoor pool – 32.5 m3;

§ Main pool – 1,962 m3; and

§ Club Pool – 279.6 m3.

o First class, second class water will be used in the three pools. The pool water filtration system will comprise sand filters and use of circulating pumps.

o The pump room will be installed at basement level to ensure that there is no impact from noise.

o Sanitization of pool water will be carried out through automatic dosing of chlorine (< 2kgms/day).

• Sewage:

o It is estimate that approximately 160m3/day of municipal sewage will be produced by the new guest rooms.

Equipment Needed to Provide the Identified Services

4.111. The services listed in the section above will require the installation of a range of new equipment, as follows:

• ELV Systems:

o Extending the present fire alarm system PABX, CCTV, and CATV systems;

o 340 stand alone door access control panels; and

o 340 stand alone guest room management system.

• Mechanical Works:

o 150m³ sea water RO system;

o Fire fighting water pump and 20 hose reels;

o Cold water inverter control pressurised water pump system;

o Two 6m³ hot water calorifiers;

o One 500 kW cast iron sectional hot water boilers;


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o Inverter type irrigation water pump; and

o PPR Pipe work.

• HVAC Systems:

o Pipe work will be PPR (Lagged);

o Two 550 kW sea water cooled chillers;

o 350 concealed water to air fan coil units; and

o One 500 kW cast iron sectional hot water boiler.

• Electrical System:

o A 1000 kVA substation;

o One 500 kVA diesel standby generator;

o One Power factor correction unit;

o A 1000 kVA 16-way main electrical switchboard; and

o 20 electrical 3-phase distribution boards.

• Lifts:

o Six machine room less VVR passengers/service lifts.

Electricity and power

4.112. The maximum annual energy consumption as estimated by the consultant engineer is 2,917 MWh. Please see Chapter 12 for further details including green house gas emissions.

Energy Saving Measures

4.113. The following energy saving measures will be implemented:

• Use of energy saving lamps in guest rooms, corridors, and other public areas (saving 40% on lighting energy);

• Use of 0.99 power factor correction units15 (saving 6% on the production of electricity);

15 Power factor is the ratio between the KW and the KVA drawn by an electrical load where the KW is the

actual load power and the KVA is the apparent load power. It is a measure of how effectively the current is being converted into useful work output and more particularly is a good indicator of the effect of the load current on the efficiency of the supply system. A load with a power factor of 1.0 results in the most efficient


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• Use of existing seawater cooled chiller with a COP of 3.6 (saving 33% energy);

• Provision of heating by means of light heating fuel oil;

• Installation of a guestroom management system to control energy use in rooms (30% savings on guestroom electricity);

• Installation of solar panels for cold water feed to calorifier (20% savings on fuel for hot water);

• All external lighting will be in accordance with light pollution guidelines and, where possible, will be controlled by timers;

• Sensors on centralised lighting for public areas;

• Implementation of a Building Management System (BMS) to optimise the use of all plant and equipment;

• The roof slabs and panelling will be insulated to minimize energy losses; and

• All apertures will have double-glazing.

4.114. It should also be noted that the Seabank Hotel intends to apply for the Malta Tourism Authority’s Eco-certification Scheme and will therefore seek to comply with as many of the eco-certification criteria related to energy use and management. These include:

• Use of automatic turn-off systems in electric hand dryers;

• Installation of a power factor corrector;

• Use of low consumption light bulbs in public areas and guestrooms;

• Use of automatic turn-off systems for external and internal illumination;

• Use of a centralised air conditioning system;

• Use of presence sensors in public toilets and corridors;

• Use of cost of energy consumption as a purchasing criterion;

• Installation of thermal insulation in building;

• Use of manual devices in kitchens;

• Application of a preventive maintenance programme;

• Use of a computer system to monitor electric installations;

loading of the supply and a load with a power factor of 0.5 will result in much higher losses in the supply system (http:l/www.Imphotonics.comfpwrfact.htm).

http://www.Imphotonics.comfpwrfact.htm)


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• Use of a constant water pressure system to save water and energy;

• Consideration of alternative energy sources for water heating;

• Alternative energy use for illumination;

• Automatic turn-off systems for room illumination;

• Automatic turn-off systems for air conditioning in rooms;

• Use of an independent temperature control in rooms; and

• Use of automatic turn-off for air-conditioning in room windows.

4.115. As can be seen from the above list and the proposed energy and water savings measures (listed below), the Scheme will already comply with a number of the Eco-Certification criteria.

Water

4.116. The current hotel has five small reservoirs, which are used to store different classes of water, as follows:

• One 48 m3 reservoir for mains water;

• One 48 m3 reservoir for RO water

• One 75 m3 reservoir for second class water;

• One 48 m3 reservoir for the make-up tank for the pool; and

• One 192 m3 transfer reservoir for mains water and RO water.

4.117. The new extension will use four classes of water, as follows:

• Mains water for kitchen and bars (30m3/day);

• RO water for cold/hot water (110m3/day);

• Second class water for irrigation and fire fighting systems (70m3/day); and

• Run-off water for irrigation purposes (see below).

4.118. The following is a list of water management measures that will be adopted, and form the framework for a water management plan:

Water Saving Measures

4.119. The Scheme will incorporate the following water saving measures:

• Production of 100% of cold/hot/toilet water by sea water RO system;


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• Re-use of 100% of grey water waste. The treated grey water will be reused for flushing and irrigation systems. (This saves 63m3 of water per day);

• 100% of rain water to be used for irrigation or flushing water system;

• Aerators in all showers and tap mixers to reduce the volume of water used in sinks and showers by 50%;

• The use of a hybrid system of vacuum tube solar panels and heat pumps for the hot water production thus reducing heating through boilers by 80%;

• Gas boilers to be used as back up for the production of hot water. This has a cleaner flue than light gas oil boilers; and

• Indoor pool heating to be carried out through use of solar panels.

4.120. Use of grey water and rain water translates to a 30% savings on water consumption.

4.121. No groundwater will be abstracted by the Scheme. Existing boreholes are used to pump up seawater for treatment in the RO plant. These will continue to be used.

Storm water management

4.122. The Scheme comprises one large storm water reservoir with a capacity of 5,400 m3. Rain water falling on the roofs and paved areas within the Scheme Site will be channelled into this reservoir.

4.123. This water will be used for irrigation and as second class water (see above).

Sewage

4.124. The existing hotel is linked to the main sewer in Triq il-Marfa; this will be the case for the extension too. This sewer is linked directly to the new Sewage Treatment Plant at Ic-Cumnija and is adequate to cater for the needs of the Scheme.

4.125. The sewage generated will depend on the number of residents and the number of employees on Site and the activities thereon. All effluent that is to be discharged to the sewerage system must conform to the requirements of Legal Notice 139 of 2002. The vast majority of the sewage produced by the Scheme will be domestic in nature. Trade effluents would only emanate from the catering areas, which would have their own grease traps as a requirement of their own licensing.

4.126. The hotel considered the feasibility of installing a sewage treatment plant on site to cater for the sewage generated by the Scheme; however this idea was discarded for financial reasons and the fact that the Scheme is very close to one of the main sewage treatment plants of the island.


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Emergency Plans

4.127. The hotel will have its own internal emergency plans in the case of utility failures. These include:

• Presence of stand-by generators in the event of a power outage; and

• Mains water back-up in the event of RO plant failure.

4.128. Fire fighting evacuation will be controlled through appropriate signage and on going training of personnel.

Lighting

4.129. Lighting in hotels is one of the most expensive cost centres, which compels hotels to control consumption and take energy saving measures (see above). The Scheme will not be an exception and the use of energy efficient lighting, including measures to minimise light pollution. All internal light fittings will have energy saving lamps both for guest rooms and public areas. Corridor lights will be sensor controlled to cut down on light consumption whereas landscape lighting will be specifically chosen to cut down on any light pollution.

4.130. The impact of lighting will obviously be most felt at nighttime. These effects are assessed in the nighttime view in Chapter 11.

Other 4.131. MEPA’s Terms of Reference require a framework for an Energy and Water

Management Plan that will take into account the energy performance of the building, integration of low/ zero carbon technologies to meet the building’s energy needs and energy efficiency / consumption. A framework for these plans has been described above and illustrates that the Scheme is incorporating energy and water saving measures at the design stage. A detailed Management Plan outlining specific targets can only be submitted when the Scheme is operational. Water and energy conservation can further be addressed through the setting up of an Environmental Management System, which would ideally be certified to a standard such as ISO 14001 or Eco-Management and Audit Scheme (EMAS). The hotel management will be aiming to apply for Eco-Certification of the hotel and its operations within one year of re-opening. This is a voluntary local eco-label scheme that can serve to facilitate the eventual implementation of an EMS.


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5. WASTE MANAGEMENT

INTRODUCTION 5.1. The ToR call for a Waste Management Section (WMS) to address the handling of

waste generated by the Scheme.

Terms of Reference 5.2. The ToR require a WMS to be formulated:

1.4 Waste Management

1.4.1 The Waste Management Section (WMS) is aimed at identifying the waste management requirements which will arise from the project, as well as proposing solutions how this waste should be managed using the Best Practicable Environmental Options available.

1.4.2 The WMS should cover all waste streams and target the following stages of the project:

Site Clearance and Demolition;

Excavation;

Construction phase; and

Operational phase (this section shall address waste management infrastructure required during the operational phase).

All information and waste analysis estimates requested below under section

1.4.3 ‘General Requirements’, shall be presented separately for the different phases of the project, as listed above.

General Requirements

1.4.3.1 A general policy statement and commitment by the developer to reduce waste generation and minimise landfill disposal where possible. Every possible effort should be made to minimise waste generated and to divert waste generated from the project to reuse/recycling, rather than disposal.

1.4.3.2 Identify processes or activities (resulting from the project in question) that would result in waste generation.

1.4.3.3 The identification of all possible waste streams expected to be generated. This section shall also include wastes generated from any


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ancillary facilities required on site and wastes which may arise in the form of accidental spillages and leakages from the operation of on-site machinery.

1.4.3.4 The relevant European Waste Catalogue Code for each waste stream identified, as per schedule 1, and the corresponding H code (if applicable) for each waste stream as per schedule 2, of the Waste Management (Permit and Control) Regulations as published by LN 337 of 2001, should be submitted.

1.4.3.5 The projected quantities (estimates) for each type of waste (details of assumptions made and the methodologies adopted for achieving such estimates should also be included).

1.4.3.6Impacts of the waste streams to be generated;

1.4.3.7 An assessment of alternatives for proposed management of the waste streams identified which should include:

Measures to be taken for the separation of the different waste streams identified, on site of the scheme;

Infrastructural elements required for any temporary storage and management of waste on site of the scheme;

Measures to be adopted to ensure protection of the surrounding environment from such wastes whilst these are being stored on site of the scheme;

Measures to be adopted in the event of accidental spillages occurring on site;

An assessment of alternatives for the proposed offsite management/disposal of waste streams identified. This shall include an assessment of the environmental implications of such alternatives, which shall aid in the recommendation of the best practicable environmental options for waste management. Information on waste management facilities and waste contractors/operators proposed shall also be provided. It must be shown that all waste streams will be disposed of in sites duly permitted for that particular waste stream. Any agreements reached with permitted waste management facilities including WasteServ Malta Ltd shall also be included in the EIA;

A description of the means of transportation to be used to remove waste from site of the scheme. This should also include information on measures to be taken to protect the surrounding environment during transport of waste/s.


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1.4.3.8 Layout plan (to scale) of site indicating and adequately labelled:

- all temporary/permanent waste management infrastructure required including bunded areas for storage of waste fuels, wheel-wash facilities, ablution facilities etc. as applicable;

- flow of surface water runoff, as laid to falls to containment tanks etc, as applicable.

1.4.3.9 Cross-section (to scale) of all waste management infrastructure required.

5.3. This chapter contains the waste management strategy to be adopted during the construction and operational phases.

5.4. In accordance with the ToR, the following section describes each type of waste, the nature of the waste and its European Waste Catalogue code16, the volumes arising, its storage and the requisite infrastructure for on-site management, the disposal facility and / or recycler, and the method of disposal and means of transportation to the disposal facility. Volumes of excavation and construction waste are based on the plans submitted to MEPA as part of the current application.

WASTE STREAMS 5.5. The waste generated by the Scheme falls into the following categories:

• Inert waste from the excavation of the Site and construction;

• Runoff (during construction) that is likely to contain sediments from the Application Site;

• Foul water arising from ablution facilities; and

• Waste arising from the operation of the Scheme.

Excavation and Construction Waste

Excavation waste

5.6. The total volume of material to be excavated from the site is estimated at 31,400m3. The depth of excavation varies in different areas; the site gradient also contributes to this variation in excavation depth. The projected height of excavation is expected to vary from a minimum of 6.0 metres close to the existing hotel building and increases to 13.5 metres further uphill along Triq Dawret il-Mellieha. Excavation is expected to take 2 months (see Chapter 4).

16 As transposed by Legal Notice 337 of 2001. Environment Protection Act (Act No. XX of 2001) Waste

Management (Permit and Control) Regulations, 2001.


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5.7. Geo-technical studies on the material to be excavated were carried out in December 2007. Preliminary results show that the uppermost layers are of very high quality whereas lower layers are of poorer quality; it is likely that the material can be reused. The material will be taken off site for storage in a quarry17. The material will eventually most likely be crushed and reused in construction.

5.8. Soil present on site within the areas to be excavated will be stripped and stored in a specially dedicated area on site (see Figure 4.18) and subsequently used in the landscaping scheme. Any extra soil will be carted away in accordance with instructions to be given by the Department of Agriculture in line with the Fertile Soils (Preservation) Regulations.

5.9. Rubble walls extant on the Application Site will be dismantled and the stones stored for re-use (see Figure 4.18) in the landscaping scheme on site. Construction of new rubble walls will be necessary to re-create boundary walls and to provide other rustic features in the landscaping scheme. Any extra stones will not be dumped; they will be used to maintain rubble walls in the fields behind the hotel or re-utilised in other areas off site.

5.10. Some construction materials may be generated during the construction phase – the amounts are variable and cannot be estimated at this stage. It will be the responsibility of the building contractor to them cart away. However, it should be noted that most materials will be reused as far as possible on Site as they are considered a resource rather than a waste. In addition, material that will be generated from removal of the existing pool and restaurant (approximately 7,300m2) will be reused within the Site itself, mainly for backfilling and is therefore not considered waste.

Runoff

5.11. The surface water catchment reservoir (see Chapter 4) will be constructed at the beginning of the construction phase and will, therefore, be used during both the construction and operation phase. This reservoir will be the first to be excavated and will be used to collect run-off water from the site during the construction phase.

5.12. Figure 5.1 provides a schematic layout for the collection of run off.

Foul Water

5.13. Portaloo facilities will be provided in the contractor’s compound and managed through a contractual agreement.

17 In its comments on the first draft of the EIS, MEPA commented that there are no quarries in Mellieha that

have a waste management permit. Given the fast rate at which inert landfills are filled, it is recommended that once a waste management plan is prepared for this development the details of the inert quarry are provided at that stage.


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5.14. Table 5.1 describes each waste stream and assigns the European Waste Catalogue Codes, as found in Legal Notice 337 of 2001, to the different waste streams. It is noted that soil and rubble walls are not considered as waste streams and are therefore not included in the table.

Wheel washing facility

5.15. During construction a wheel washing facility will be located near the temporary gate at Site access next to the southern perimeter of the Site (see Figure 4.18). This will consist of a ramp up, plateau, ramp down facility beneath which water storage tanks and drains will be constructed. Construction vehicles leaving the Site will pass through this ramp where they will be washed down with water jets. Both the sludge and water are collected and recycled. The sludge is dried and reused as backfilling material, whilst the water is filtered and reused to wash the next vehicle to prevent the formation of mud / debris on the access paths. The access ramp will be covered in a layer of concrete or tarmac.


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Figure 5.1: Collection of runoff including reservoirs and channelling


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Table 5.1: Solid Construction18 Waste

Waste Description

Internal handling, disposal & storage

Treatment by waste contractor

Quantity projected

Method of transport to disposal site

Current Disposal Site / Waste Management

Company

European Waste Catalogue Codes

Non-Hazardous Excavated material

Disposal to landfill or as directed by the Competent Authority

Transportation off Site

31,400 m3 HGV Stored for reuse; 30% to be reused on Site

01 01 02 waste from mineral non-metalliferous excavation

Mixed building waste19

Recyclable materials stripped from the building and taken off site by building contractor.

Depending on the nature of the material the waste will either be sent to the Sant’ Antnin Waste Management Facility or disposed as indicated by the Competent Authority / WasteServ Malta ltd

Variable - none

HGV Recycled / reused or as directed by the Competent Authority

17 02 01 wood 17 02 02 glass 17 02 03 plastic 17 04 07 mixed metals 17 04 02 aluminium

18 Construction includes excavation 19 The term “mixed building waste” is not used in the physical sense i.e. that the material is mixed on site, Rather it refers to the different components that have not

been individually identified at this stage in view of the low amounts expected to be generated,


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Operational Waste 5.16. The operational waste stream includes mainly municipal waste, sewage & grey water,

and surface water runoff. Since the Scheme comprises a hotel with food and beverage establishments, it is expected that packaging waste and waste oil will be produced. Some hazardous waste may be generated from refrigerants, use of solvents, and oils in the plant room. These will be kept in a bunded area in the maintenance stores.

5.17. As a waste producer and holder, the management of the Scheme must ensure that waste does not escape from its control before being collected by an authorised person / waste company.

5.18. While the EIS provides a general framework for waste management during operation, it is noted that waste management infrastructure associated with the operation consists of a cooled garbage room. This is standard practice for all hotels and is acknowledged as good practice by the Malta Tourism Authority’s Eco-Certification Scheme for hotels (see below). The EIS will only provide the general framework – detailed waste management issues are purely operational and cannot be regulated by planning permission.

Municipal Solid Waste

5.19. The Scheme is to accommodate the following mix of uses:

• Construction of 340 rooms;

• Extension and upgrading of the existing gym;

• Creation of an indoor pool area at the upgraded Spa centre;

• Enlargement of the outdoor pool and pool deck area;

• Creation of an adequate conference centre;

• Inclusion of new catering facilities;

• Provision of adequate car parking facility;

• Re-location and upgrading of the existing plant room; and

• Provision of extensive landscaped areas.

5.20. Waste generation figures have been derived from the waste currently generated at the existing hotel. They are based on an average annual occupancy of 70%. It is noted that the extension does not include kitchens – those in the existing hotel will be used.


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Table 5.2: Municipal waste generation figures Waste Amount / day Cooking Oil 18 Litres Other waste including swill, packaging and glass 1,400 kg

5.21. Grease traps are installed in all the kitchens and the oil is collected on a regular basis by E.O.R.C. Ltd. of Marsa. Waste collection is currently sub-contracted to a firm. All waste is placed in the garbage room in 6 skips holding 1,100 litres each. Collection is done daily. Most of the glass bottles are returned to the suppliers.

5.22. The developers are committed to (a) reducing amount of waste generated; and (b) providing the necessary infrastructure to facilitate waste separation. The disposal of waste will be managed in accordance with best practice and will include waste segregation.

5.23. The operators have also committed to implementing the Malta Tourism Authority’s Eco-Certification Scheme.

5.24. The Scheme comprises a total of 130 criteria split into 10 areas of assessment; there are 40 compulsory criteria and 90 non-compulsory ones. In order to join the Scheme, a hotel would need to demonstrate good environmental management systems and practices and, in particular, it would have to meet all 40 compulsory criteria and a minimum of 85 of the total criteria (65%).

5.25. The 10 areas of assessment are shown in Table 5.3.

Table 5.3: Scheme criteria

Sector Number of Compulsory Criteria

Number of Non-Compulsory Criteria

Environmental Management 7 2 Waste Management 5 15 Product Procurement 10 13 Energy 0 24 Water 6 7 Air Pollution 0 4 Noise Prevention 0 7 Buildings and Green Areas 7 7 Local Culture 3 6 Guest Information 2 5 TOTAL 40 90 Total Number of Criteria 130

5.26. The waste management criteria are shown in Table 5.4


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Table 5.4: Waste management criteria

The hotel uses separated containers for organic wastes

The hotel uses separated containers for glass.

The hotel uses separated containers for papers.

The hotel uses separated containers for oil.

The hotel uses separated containers for batteries.

The hotel uses separated containers for cans.

The hotel uses separated containers for other wastes.

The hotel uses garbage room in a good state.

The waste room is air-conditioned.

The hotel respects containers collecting time.

The hotel guarantees final destination of goods with CFC or similar

The hotel guarantees final destination of voluminous solid wastes.

The hotel guarantees final destination of toxic waste.

5.27. Implementation of the above criteria will ensure that the hotel adheres to best practice.

5.28. The following waste reduction protocols are recommended:

• Request suppliers to pack items with as little packaging material as possible;

• Request suppliers to take back packaging boxes for reuse and recycling;

• Serve carbonated drinks from a beverage gun or dispenser (i.e. postmix);

• Buy in bulk containers rather than smaller units;

• Use refillable condiment bottles;

• Serve straws from health-approved dispensers rather than offering them pre-wrapped;

• Use re-usable coasters (or none at all) when serving beverages from the bar;

• Use reusable linen ware;

• Purchase cleaning supplies in concentrate;

• Use cloth cleaning towels rather than paper equivalent;

• Use biodegradable bin liners;

• Carry out regular maintenance of equipment / appliances to extend their life time; and


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• Ask suppliers for and purchase paper products made from recycled materials. Available items include toilet tissue, paper towels, napkins, place mats, bags, and menus20.

Other waste

5.29. As described above, the bulk of the waste generated by the Scheme is municipal solid waste. However, the operation of the Scheme such as heating and cooling equipment, refrigeration, and general maintenance may produce certain hazardous wastes such as waste oils, solvents, and spent refrigerants. These wastes will be kept on-site, in the stores used by maintenance staff and removed by a licenses contractor.

Sewage effluent

5.30. Normal household-type effluent will be produced by the Scheme; it will be channelled to the sewerage system. No on-site treatment is foreseen; it is noted that the Scheme is close to the Malta North Sewage Treatment Plant.

5.31. The sewage effluent generated by the completed development is estimated to be 160 m3 per day.

Water

5.32. As described in Chapter 4 all storm water incident on roofs and surfaced areas will be channelled into a reservoir that has a capacity of 5,400 m3. The water will be reused as second class water including in pools and for irrigation.

5.33. Currently the hotel operates an RO plant; the reject from this plant (brine at 37,000 µs) is discharged to sea via a pipeline. Rate of discharge is approximately 6 m3/hr.

5.34. Other discharges to the marine environment consist of seawater obtained from a borehole; it is used to cool the chillers. This is discharged at a maximum rate of 300m3/hr at 21°C at the discharge point and with a maximum velocity of 2.35m/s.

5.35. No new discharges will be added as a result of the Scheme.

20 Adapted from California Environmental Protection Agency’s Integrated Waste Management Board, Food for

Thought: A Restaurant Guide to Waste Reduction and Recycling accessed from www.ciwmb.ca.gov/Publications/BizWaste/44198016.pdf

http://www.ciwmb.ca.gov/Publications/Biz


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Table 5.5: General Waste generated by the hotel

Waste Description


Treatment by waste

contractor

Quantity projected

Frequency & Method of

transport to disposal site


Company


Non-Hazardous Municipal solid waste

Organic / non-organic non-hazardous waste will be separated and disposed of in general waste bins located within the premises. The bins are emptied into a general waste skip as appropriate located in a specially assigned waste storage area.

Landfilled / Composted

1,400 kg daily

Once daily using scammel in accordance with Government’s waste separation / collection scheme once operational

Ta’ Zwejra Landfill Site / Sant’ Antnin Composting Facility

20 01 01 paper and cardboard 20 01 02 glass 20 01 08 biodegradable kitchen and canteen waste 20 01 10 clothes 20 01 11 textiles 20 01 25 edible oil and fat 20 01 28 paint, inks, adhesives and resins other than those mentioned in 20 01 27 20 01 30 detergents other than those mentioned in 20 01 29 20 01 34 batteries and accumulators other than those mentioned in 20 01 33 20 01 36 discarded electrical and electronic equipment other than those mentioned in 20 01 21, 20 01 23 and 20 01 35 20 01 39 plastics 20 01 40 metals 20 02 01 biodegradable waste 20 02 03 other non-biodegradable wastes 20 03 other municipal wastes 20 03 01 mixed municipal waste 20 03 03 street-cleaning


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Waste Description


Treatment by waste

contractor

Quantity projected

Frequency & Method of

transport to disposal site


Company


residues 20 03 06 waste from sewage cleaning 20 03 07 bulky waste 20 03 99 municipal wastes not otherwise specified

Packaging waste The protocols for handling such waste must be agreed between the operator and the licensed contractor.

Landfilled / Composted

Unknown as depends on operator

Once daily using an appropriate waste transport vehicle.

A licensed waste carrier will take the packaging waste to landfill or to a recycling facility.

15 01 01 paper and cardboard packaging; 15 01 02 plastic packaging; 15 01 03 wooden packaging; 15 01 04 metallic packaging; 15 01 05 composite packaging; 15 01 06 mixed packaging; 15 01 07 glass packaging; 15 0 09 textile packaging.

Maintenance waste Storage on site in the plant room in a bunded area, until they are removed by a licensed contractor

Ghallis hazardous waste landfill.

Variable When enough is accumulated.

A licensed waste carrier will take the waste to Ghallis hazardous waste landfill or the incinerator at Marsa

13 07 01* Fuel oil and diesel 15 02 absorbents, filter materials, wiping cloths, and protective clothing 16 06 03* mercury containing batteries 20 01 21* Fluorescent tubes and other mercury-containing waste 20 01 27 * Paints, inks, adhesives, and resins containing dangerous substances 20 01 28 Paints, inks, adhesives, and resins other than those mentioned in 20 01 27*


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POLICY & LEGISLATIVE CONTEXT 5.36. The Waste Management Plan must have regard to national legislation and policies

including the Solid Waste Management Strategy for the Maltese Islands, the Structure Plan for the Maltese Islands, and Space for Waste (the Waste Management Subject Plan). Relevant legal notices include: Legal Notice 139 of 2002: Sewage Discharge Regulations, 2002, and Legal Notice 337 of 2001: Waste Management (Permit and Control) Regulations, 2001.

5.37. The Application Site lies within the area designated by the Malta Resources Authority as a Drinking Water Safeguarded Zone, and within the surface catchment area of Malta’s mean sea level groundwater body, which is protected under the Water Policy Framework Regulations (L.N. 194 of 2004). Water Services Corporation Drinking Water Galleries are also within 40m of the Site boundary (see Chapter 7).

Solid Waste Management Strategy 5.38. The Solid Waste Management Strategy (SWMS) provides a policy and decision-

making framework for the future management of wastes generated in the Maltese Islands, and for the preparation of detailed implementation plans. It is also the means by which the various requirements and targets contained in European Directives on waste will be implemented, in particular the Waste Framework Directive (75/442/EEC as amended by 91/156/EEC), the Hazardous Waste Directive (91/689/EEC as amended by 94/31/EEC), the Disposal of Waste Oils Directive (75/439EEC as amended by 87/101/EEC), and the Landfill Directive (99/31/EC).

5.39. The key areas arising from the SWMS in respect of waste arising from the Scheme include sustainable waste management, producer responsibility, segregation at source, and the minimisation of waste generation.

5.40. Sustainable waste management means using resources more efficiently, reducing the amount of waste produced and, where waste is generated, dealing with it in a way that will help to achieve the goal of sustainable development.

5.41. The principle of ‘Producer Responsibility’ generally refers to waste produced by the commercial / industrial sectors. In the context of waste arising from the Scheme, it implies that the operator should take responsibility for minimising waste arisings.

Meeting the Requirements of the SWMS

5.42. The Scheme will follow best operating practices in respect of waste including reusing where possible, excavation material, and re-using the soil that is on-site.

Structure Plan for the Maltese Islands 5.43. The Structure Plan provides a framework for the continued working of important

mineral deposits and the exploitation of future deposits in an environmentally acceptable way. In this respect, the Structure Plan speaks of the need to optimise the


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use of the nation’s mineral resources. Should any good quality rock be found beneath the site during excavation, it will be harvested in line with Structure Plan policies.

5.44. The public utility policies of the Structure Plan highlight the disposal of solid waste as an area of major concern. Of relevance to the Scheme is Policy PUT 13.

POLICY PUT 13: Development involving processes likely to give rise to the generation of wastes, especially hazardous wastes will only be permitted where the Planning Authority is satisfied that:

There are no practicable or reasonable alternatives to the process proposed

All reasonable measures and procedures have been adopted to minimise the generation of waste

Wastes will be treated, stabilised or neutralised on site as far as practicable

Appropriate measures for safe transport, handling, and disposal can be implemented and enforced.

5.45. Hazardous material will not be generated during the Scheme’s construction phase.

Space for Waste: the Waste Management Subject Plan 5.46. The Waste Management Subject Plan21 provides strategic long-term direction and

context to guide both Government and the private sector in waste management issues. Its policies guide the strategic planning of waste and the determination of development permit applications for developments and land use changes related to waste management facilities. The policies relevant to the Scheme have regard to recycling of construction and demolition waste.

5.47. The following policies are relevant:

• Policy SWM2: The Planning Authority will support public, private and voluntary sector initiatives to reuse, recover and recycle waste in accordance with the Policies in this Plan.

• Policy SWM3: The Planning Authority will support measures that encourage separation of waste at source for reuse or recycling.

• Policy SWM7: The Planning Authority will require Applicants of proposals that have the potential to generate large quantities of waste to provide specific information on measures to minimise waste generation and how waste will be managed in keeping with the principles of sustainable development. Proposals should also include provision for the separation and storage of different types of waste for recycling as appropriate.

21 MEPA October 2001.


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• Policy SWM10: The Planning Authority will support proposals for temporary facilities on demolition and construction sites for the recovery, separation and where appropriate processing of waste materials generated by the on-site demolition or construction works provided that:

(i) no waste materials are to be imported to the facilities at the site from elsewhere unless prior written authorisation is obtained from the Planning Authority and the Environment Protection Department;

(ii) the proposal will not give rise to unacceptable impact on local communities or the environment; and

(iii) the facilities are removed on completion of the demolition or construction project.

5.48. The Scheme is congruent with the above policies: waste is to be separated at source; the Waste Management Plan described in this EIS provides, to an extent, the information required under SWM7, an environmental permit will be required to ensure details of waste management during operation; and the removal of construction and demolition waste from the site will satisfy SWM10.

Legal Notice 139 of 2002: Sewage Discharge Regulations, 2002 5.49. Legal Notice 139 of 2002, Environmental Protection (Sewer Discharge Control) Regulations

regulates the nature of discharges into public sewers. All grey and foul water discharges will be to the sewer as described in Chapter 4.

Legal Notice 337 of 2001: Waste Management (Permit and Control) Regulations, 2001

5.50. Legal Notice 337 of 2001 regulates the production and disposal of hazardous and non-hazardous wastes and aims to control all operations relating to the production and management of waste, and to promote sound waste management practices so as to safeguard human health and the environment. Through these Regulations the Competent Authority seeks to:

ensure that waste is produced and managed without endangering human health or harming the environment, in particular: (a) without risk to water, air, soil, plants and animals; (b) without causing a nuisance through noise or odours; (c) without adversely affecting the countryside or places of special interest or value.

5.51. In so doing, the Competent Authority endeavours to encourage:

the prevention and reduction of waste or the harmfulness thereof, among other means through: (a) the use or development of clean technologies which are more sparing in their use of natural resources; (b) the use or development of products designed to minimise the amount or harmfulness of waste or the pollution hazard arising therefrom in their manufacture, use or final disposal;


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(c) the use or development of appropriate techniques for the final disposal of dangerous substances contained in waste destined for recovery; (d) the recovery of waste, including its use as a source of energy; (e) the safe disposal of waste or the residues remaining from its recovery.

5.52. The Regulations also prohibit the mixing of different categories of hazardous wastes or hazardous with non-hazardous wastes. Hazardous waste is to be properly packaged and labelled, whether for storage, collection, or transport.

5.53. The Applicant, subsequent to the approval of the Full Development Planning Application, will need to demonstrate that a set of protocols has been established that prevent the escape of waste, and to identify the places where waste is to be stored. In respect of the collection of waste, it is noted that the Applicant is aware of the need to comply with the relevant permitting system.

5.54. In accordance with Article 19 of the Regulations, the Applicant, as described herein, has to make provision for the separation of non-hazardous and hazardous waste, and the separation of distinct waste streams thereof.

5.55. The inert waste arising from the construction of the Scheme has to be handled and disposed of in accordance with a Waste Management Permit issued by the Director of Environment Protection.

5.56. Waste arising from the operation of the Scheme is expected to include municipal waste, packaging waste, and hazardous waste, the precise nature of which cannot be determined at this stage. Since municipal solid waste, including small quantities of hazardous waste generated by households, is listed in Schedule 5 of the Legal Notice, its disposal does not require a waste management permit. Other hazardous wastes, such as waste oils and chemicals, are classified as hazardous waste in Chapters 13 and 14 of Schedule 1 of the Legal Notice. The Scheme will include dedicated waste area for these wastes so as to conform to the provisions of this Legal Notice. The wastes will be collected in appropriate containers and stored in designated areas for each waste stream. A licensed waste carrier will remove the waste from Site for disposal.

5.57. The recommendations given above for the safe storage of these hazardous wastes are in line with the requirements of the Legal Notice.

Legal Notice 98 of 2004 Waste Management (Packaging and Packaging Waste) Regulations, 2004

5.58. These Regulations are aimed at

preventing the production of packaging waste and, as additional fundamental principles, at reusing packaging, at recycling and other forms of recovering packaging waste and, hence, at reducing the final disposal of such waste.


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5.59. The Regulations apply to all packaging placed on the market in Malta and all packaging waste at industrial, commercial, and household level. The Regulations require that producers must import, manufacture, supply or use packaging material and packaging only if it complies with the requirements contained in the Regulations. Targets for recovering and recycling packaging waste in Malta are also prescribed in the Regulations. They distinguish between packaging made from glass, metals, plastics, and paper and paperboard. These targets affect all producers of packaging waste including the Applicant. The Applicant will have to adhere to the Regulations once procedures are in place for the management of such waste.

MONITORING 5.60. Monitoring of waste management during operations is unlikely to be required. Waste

management practices will be verified through an auditor if the hotel participates in the MTA’s Eco-Certification Scheme.


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6. POLICIES & LEGISLATION

INTRODUCTION 6.1. This chapter considers the relevance of international and national legislation and

Maltese planning policy, its compatibility with the proposed Scheme, and the impact of the Scheme on them. It highlights and assesses the policies of Government Ministries where relevant, and outlines those European Union Directives and Regulations and other international obligations that are applicable to the Scheme.

6.2. The legal basis for MEPA’s request for the preparation of an Environmental Impact Assessment stems from the Environment Impact Assessment Regulations, 200722 (LN 114 of 2007).

INTERNATIONAL LEGISLATION 6.3. International legislation relevant to the Scheme arises from International Treaties and

Conventions to which Malta is a signatory. In view of Malta’s accession to the European Union in 2004, EU Directives are also relevant.

6.4. The International Conventions relevant to the Scheme include:

• The European Cultural Convention, 1954 (Paris, 19.XII.1954)23;

• The European Convention on the Protection of the Archaeological Heritage (Revised), 1992 (Valletta, 16.I.1992)24;

• The Convention on Biological Diversity, 1992 (the Rio Convention); and

• The Convention on the Conservation of European Wildlife and Natural habitats (the Bern Convention).

The European Cultural Convention

6.5. This Convention was adopted in Paris on the 19th December 1954 and entered into force on 5th May 1955. The objective of the Convention is to develop mutual understanding among the peoples of Europe and reciprocal appreciation of their cultural diversity, to safeguard European culture, to promote national contributions to Europe's common cultural heritage respecting the same fundamental values and to encourage in particular the study of the languages, history, and civilisation of the Parties to the Convention.

6.6. The Convention requires the Contracting Parties to “regard the objects of European cultural value placed under its control as integral parts of the common cultural heritage of

22 Repealing LN 204 of 2001 23 See Council of Europe web site: http://conventions.coe.int/Treaty/en/Treaties/Word/018.doc. 24 See Council of Europe web site: http://conventions.coe.int/Treaty/en/Treaties/Word/143.doc.

http://conventions.coe.int/Treaty/en/Treaties/Word/018.doc

http://conventions.coe.int/Treaty/en/Treaties/Word/143.doc


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Europe”, and “shall take appropriate measures to safeguard them and shall ensure reasonable access thereto”.

Implications for the Scheme:

6.7. The construction of the Scheme will need to take account of the cultural heritage value of the proposed site and its environs, including the features themselves and their cultural setting / cultural landscape. Refer to Chapter 10 and Technical Appendix 5 for the assessment of impacts on cultural heritage features.

The European Convention on the Protection of the Archaeological Heritage (Revised)

6.8. This Convention, which was agreed in Valletta on 16th January 1992, amends the original Convention (agreed in London in 1969) on the protection of archaeological heritage. The aim of this (revised) Convention is “to protect the archaeological heritage as a source of the European collective memory and as an instrument for historical and scientific study”. This revision was brought about through the acknowledgement that European archaeological heritage is under serious threat from deterioration as a result of “major planning schemes, natural risks, clandestine and unscientific excavations, and insufficient public awareness”. In the context of the Convention, archaeological heritage includes “structures, constructions, groups of buildings, developed sites, moveable objects, monuments of other kinds as well as their context, whether situated on land or under water”.

6.9. The Convention requires the Contracting Parties to institute a legal system for the protection of archaeological heritage, including:

• The creation and maintenance of a heritage inventory;

• The creation of archaeological reserves; and

• Mandatory reporting to competent authorities of the chance discovery of archaeological material.

6.10. The Convention also requires the Parties to apply procedures for the authorisation and supervision of excavations and other archaeological activities to ensure that they are undertaken by qualified persons and in a scientific manner.

6.11. Other provisions of the Convention include: • The physical protection of archaeological heritage;

• Integrated conservation of the archaeological heritage (including through reconciliation with development plans and other planning processes);

• Resourcing rescue archaeology;

• Collection and dissemination of scientific information;


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• Public awareness; and

• Prevention of illicit circulation of elements of archaeological heritage.

6.12. Malta ratified this Convention on 24th November 1994 and it entered into force on 25th May 1995. The provisions of this Convention have been transposed into local legislation by the Cultural Heritage Act of 2002 (see below).


6.13. The development of the Scheme will need to abide by the provisions of this Convention and of the Cultural Heritage Act 2002 with particular regard to the protected historic structures within the area. Impacts on cultural heritage are assessed in Chapter 10.

The Convention on Biological Diversity

6.14. The Convention on Biological Diversity, also known as the Rio Convention, was enacted in 1992. Its objective is to “conserve the maximum possible biological diversity for the benefit of present and future generations and for its intrinsic value“. This pact between the vast majority of the world's governments sets out commitments for maintaining the world's ecological underpinnings as we go about the business of economic development. The Convention establishes three main goals: the conservation of biological diversity, the sustainable use of its components, and the fair and equitable sharing of the benefits from the use of genetic resources. The conservation element of the Convention focuses initially on the gathering of information through National Surveys and Inventories, and then moves on to address the benefits arising from the sustainable use of biodiversity. In particular, States are to undertake Biodiversity Country Studies detailing what is currently known about the status, threats, costs, and benefits of biodiversity in their territory. The Country Studies will then form the basis for the development of the National Plans for the Conservation and Sustainable Use of Biodiversity. One important aspect of the Convention is the requirement for EIA and the inclusion of biodiversity issues.


6.15. Issues of biodiversity and the impact of the Scheme thereon must be addressed (see Chapter 9).

The Bern Convention

6.16. The Convention on the Conservation of European Wildlife and Natural Habitats, better known as the Bern Convention, was promulgated by the Council of Europe in an attempt to protect Europe’s natural heritage. It is widely seen as the counterpart of the EU’s Habitats Directive. The Convention was adopted on September 1979 in Bern (Switzerland) and came into force on 1 June 1982. It has 45 Contracting Parties including 39 member States of the Council of Europe, as well as the European


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Community, Monaco and four African States. The Convention includes a number of Appendices listing protected species.


6.17. The effects of the Scheme on protected species, as identified through the ecology baseline surveys, must to be addressed in the EIS (see Chapter 9).

European Legislation 6.18. Although Malta is signatory to a number of Conventions, none is relevant to the

Scheme per se.

6.19. The Treaty establishing the European Community (Article 174) indicates that members should pursue the preservation, protection and improvement of the quality of the environment, aim at a high level of environmental protection and apply policies “….based on the precautionary principle and on the principles that preventive action should be taken, that environmental damage should as a priority be rectified at source”.25

6.20. The relevant EU Directives include Directive 85/337/EEC (amended by Directive 97/11/EU) on the assessment of the effects of certain public and private projects on the environment, that has been transposed by the Environmental Impact Assessment Regulations 2007, and various Directives that relate to waste, water, air quality, habitats, environment protection, and noise.

6.21. Since the European Union’s Environment Acquis has been transposed into national legislation, the Directives per se shall not be assessed.

25 Article 174 (ex Article 130r) 1. Community policy on the environment shall contribute to pursuit of the following objectives:

- Preserving, protecting and improving the quality of the environment; - Protecting human health; - Prudent and rational utilisation of natural resources; - Promoting measures at international level to deal with regional or worldwide environmental problems.

2. Community policy on the environment shall aim at a high level of protection taking into account the diversity of situations in the various regions of the Community. It shall be based on the precautionary principle and on the principles that preventive action should be taken, that environmental damage should as a priority be rectified at source and that the polluter should pay. In this context, harmonisation measures answering environmental protection requirements shall include, where appropriate, a safeguard clause allowing Member States to take provisional measures, for non-economic environmental reasons, subject to a Community inspection procedure.


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NATIONAL LEGISLATION

The Constitution of Malta

Declaration of principles

6.22. The Constitution of Malta (Section 9) declares that the State shall safeguard the landscape and the historical and artistic patrimony of the Nation.

6.23. These are the only aspects of the environment referred to in the Constitution, underlining the importance of the landscape and historical heritage, both important aspects in the environment of the Scheme.

The Development Planning Act, 1992 6.24. This Act regulates and controls the use of land, and in particular requires that

changes of use and development of land be subject to permission granted by the Planning Authority26; such permissions may be subject to conditions.

6.25. MEPA validated development application PA 00720/05 on 28th February 2005. The Environmental Impact Assessment Regulations, 2007, as promulgated under the Development Planning Act, 1992 are relevant.

6.26. In determining an application for development permission MEPA is required to apply:

• Development plans; and

• Planning policies;

and have regard to:

• Representations from the public; and

• Any other material consideration that the Authority may deem relevant.

6.27. The Structure Plan Policies relevant to the Scheme are identified in the Section on “Relevant Structure Plan Policies” below, and their implications on the Scheme are highlighted.

6.28. In his application for development permission the applicant must, apart from providing a full description of the proposed project, certify to MEPA that he is the owner of the site or, alternatively, that he has notified the owner of his intention to apply for development permission.

6.29. The Act also empowers MEPA to:

• Schedule areas, buildings, structures and remains of geological, palaeontological, archaeological, architectural, historical, antiquarian or artistic importance as well as areas of natural beauty, ecological or scientific value;

26 Now the Malta Environment & Planning Authority (as of May 2002).


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• Schedule individual trees, groups of trees or woodlands, which it considers should be protected, and may in respect of all or any one or more of them make tree preservation orders regulating such protection. The Act provides that no scheduled tree may be cut down, lopped, topped or wilfully damaged or destroyed without the permission of MEPA (similar provisions are included in the Trees and Woodland (Protection) Regulations, 200127, see below).

6.30. No scheduled property is included within the Site area. However, a number of protected features exist in its immediate surroundings.

6.31. Approximately 100m from the Site, is a Level 1 Area of Ecological Importance (the Il-Hofra marshland – GN 288 of 1995). This same marshland is also located within the Special Area of Conservation (Habitats Directive & LN 311 of 2006) and Special Protection Area and Natura 2000 site (Birds Directive) for Ghadira.

6.32. The agricultural land is all designated as an Area of Agricultural Value in the North West Local Plan (MEPA, 2006).

6.33. The beach at Mellieha Bay is also protected as a Level 4 Site of Scientific Importance (GN 491 of 2006).

6.34. Other designated sites within 500 metres of the Application Site28 include:

• Maritime Garrigue at id-Dawra tat-Torri – Level 2 Area of Ecological Importance [GN895 of 2002];

• WWII Beach Post at Id-Dwara tat-Torri – Grade 2 Historic Building [GN 895 of 2002]; and

• WWII Defence Post at Ta’ San Niklaw – Grade 2 Historic Building [GN 895 of 2002].

6.35. The most important protected features beyond the 500m buffer area include the Ghadira Nature Reserve and Ramsar Site and the Coastal Cliffs on the west coast (Level 2 Area of Ecological Importance and Special Area of Conservation).

6.36. The regulations currently in force under the Development Planning Act that are relevant to the Scheme include:

• Environmental Impact Assessment Regulations 2007, which establish the criteria for EIAs and the procedures to be followed. In this respect, it is confirmed that this EIS has been undertaken in conformity with the Regulations; and

• Environmental Management Construction Site Regulations 2007, described hereunder.

6.37. The aim of the Regulations is to limit environmental degradation through appropriate construction management practices that cause least nuisance to neighbours,

27 Trees and Woodland (Protection) Regulations, 2001 – Legal Notice 12 of 2001. 28 Source: Planning Factbook, MEPA website & MEPA’s National Protective Inventory.


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minimizing risk to workers and safeguarding private and public property. The Regulations entered into force on 1st November 2007.

6.38. These regulations apply to “any construction, water mining, or any other disturbances to the soil, including land clearing, scraping, ground excavation, land levelling, grading, cut and fill operations, and ancillary activities that include travel to the construction site, travel on access roads to and from the construction site and demolition activities”.

6.39. The Schedules within the Regulations provide requirements for reducing nuisance to neighbours through:

• Erection of a site notice containing details of the owner, site manager, architect, and contractor;

• Conditions for cutting of stone and bricks on site;

• Transportation of loose material;

• Obstruction of pavements;

• Hazards to vehicular traffic;

• Cleaning of the site and its immediate vicinity;

• Rodent control;

• Hoardings around development sites;

• Covered ways and barricades;

• Safe passage past the site;

• Nuisance abatement including construction times; and

• Control of dust emissions.

6.40. Technical guidelines and specifications are also provided for minimisation of noise and vibration levels, health and hygiene including waste management, hazardous materials handling, and point source pollution from storm water.

6.41. These Regulations apply to any construction site unless the Minister exempts such development under the provisions of Schedule VI “Exemptions”. Throughout the EPS the regulations have been used to address construction impacts. The requirements of the Regulations apply in their entirety to the construction of the Scheme.


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Environment Protection Act, 200129 6.42. The Environment Protection Act requires everyone together with the government to

protect the environment and to assist in the taking of preventative and remedial measures to protect the environment and manage natural resources in a sustainable manner. Various duties that fall to the government are established, those relevant to the Scheme are:

4(a) to manage the environment in a sustainable manner by integrating and giving due consideration to environmental concerns in decisions on socioeconomic and other policies;

4(b) to take such preventive and remedial measures as may be necessary to address and abate the problem of pollution and any other form of environmental degradation in Malta and beyond, in accordance with the polluter pays principle and the precautionary principle;

4(e) to apply scientific and technical knowledge and resources in determining matters that affect the environment;

(f) to ensure the sustainable management of wastes and to promote its reduction and the proper use, reuse and recovery of matter and energy;

4(g) to safeguard biological diversity;

4(h) to combat all forms of pollution;

4(i) to consider the environment as the common heritage and common concern of humankind; and

4(j) to provide incentives leading to a higher level of environmental protection.

6.43. The Act also empowers the Minister responsible for the Environment to appoint an Authority30 whose principal duties include:

• Providing advice to the Minister on environmental standards, guidelines and the making of regulations;

• Issuing licenses or permits;

• Establishing threshold discharges;

• Monitoring the quality of the environment; and

• Ensuring that Environmental Impact Assessments are properly carried out.

6.44. In addition, the Minister is empowered to make regulations for the better carrying out of the provisions of the Act, such regulations including prescription of fees and charges,

29 The original Environment Protection Act 1991 [Act V of 1991] has been repealed and replaced by the

Environment Protection Act 2001 [Act XX of 2001]. 30 In March 2002, the Planning Authority (subsequently the Malta Environment & Planning Authority) was

appointed the Competent Authority in terms of the Act (LN 57 of 2002 superseded by LN 107 of 2002).


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establishment, co-ordination and enforcement of environmental quality control systems, making provision for carrying out environmental risk assessments, prescribe techniques for environmental monitoring, and set various objectives, issue directives and establish codes of practice relating to waste management, integrated pollution prevention and control, and the protection of biodiversity.

6.45. The Act also empowers the Authority to issue licences for handling waste, including its storage, treatment, collection, and management.

6.46. In respect of Environmental Impact Assessment, the Act provides for the Minister to promulgate regulations on various aspects of the EIA process, however, this section of the Act has not been brought into force, mainly in view of the earlier publication of the EIA Regulations, with which this section overlaps. The new EIA Regulations were promulgated under the Development Planning Act and the Environment Protection Act.

6.47. The regulations currently in force under the Environment Protection Act that are relevant to the Scheme include the Legal Notices listed hereunder.

Nature Protection

• Legal Notice 1 of 1994: Environment Protection (Preventative and Remedial Measures) Regulations, which empowers the Director of the Environment Protection Department31 (EPD) to inspect the development area or any vehicles on the site for suspected violations of the Act.

• Legal Notice 12 of 2001: Trees and Woodland (Protection) Regulations protect a number of tree and shrub species present in the Maltese Islands (and listed in Schedules I to III of the Legal Notice), as well as declaring various areas containing important trees as “Nature Reserves”32. The Regulations prohibit uprooting of or other damage to individual trees of the species listed in the various Schedules, except on written permission from the Department for Environment Protection33 and the Department of Agriculture. There are some trees present within the Application Site that are protected by these Regulations. A permit from MEPA must be sought to uproot these trees.

• Legal Notice 79 of 2006: Conservation of Wild Birds Regulations manages hunting and trapping and establishes Bird Sanctuaries. There are no bird sanctuaries at the proposed site. There is the Ghadira Nature Reserve, which is a bird sanctuary, in the vicinity – approximately 550 m away. Please refer to Chapter 9.

• Legal Notice 311 of 2006: Flora, Fauna and Natural Habitats Protection Regulations provides for the establishment of a network of ecologically important

31 Now the Director of Environment Protection at the Malta Environment & Planning Authority. 32 This was the only designation possible under the EPA of 1991. We understand that these areas are now

being called (and will eventually be designated as) “Tree Reserves” (Stevens, D. (MEPA), pers. comm.). 33 Now the Environment Protection Directorate of the Malta Environment & Planning Authority (MEPA).


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areas (Special Areas of Conservation – SAC) on the basis of selected criteria with a view to protecting the habitats and species therein through the prohibition of activities that may threaten them and the formulation of management plans. The site contains some trees that are protected under these regulations. The trees will be uprooted.

Air Quality

• Legal Notice 224 of 2001 (as amended by L.N. 231 of 2004): Limit values for Sulphur Dioxide, Nitrogen Dioxide and Oxides of Nitrogen, Particulate Matter and Lead in Ambient Air Regulations, 2001 sets out air quality standards for Particulate Matter (PM10), SO2, NO2, NOx, and Lead.

• Legal Notice 163 of 2002: Limit Values for Benzene and Carbon Monoxide in Ambient Air Regulations, 2002 sets out air quality standards for Benzene and Carbon Monoxide.

Of relevance to the Scheme are emissions from vehicles – namely, nitrogen oxides, particulate matter (PM10), carbon monoxide, carbon dioxide, and hydrocarbons. Whereas it is acknowledged that the Scheme will attract a number of vehicles, it is also true that the number of vehicles in Malta will not increase as a result of the Scheme. This implies that the national level of emissions from vehicles will not be affected by the Scheme. Furthermore, on a local level, the Scheme is located on an arterial road (part of the TEN-T Network), which attracts substantial car travel as it is the only road to the northern coast and Gozo. During summer, the number of cars travelling along this road further increases due to the increase in number of visitors to the adjacent beach. The impact of the Scheme-generated traffic on air quality is therefore deemed not to be significant. This issue is further addressed in Chapter 12.

Waste Management

• Legal Notice 337 of 2001: Waste Management (Permit and Control) Regulation, 2001, and Legal Notice 98 of 2004 Waste Management (Packaging and Packaging Waste) Regulations, 2000 have been discussed in Chapter 5. The Waste Management Plan for the construction of the Scheme conforms to the requirements of these Regulations as do the guidelines for the formulation of the WMP for the operation of the Scheme.

Water

• Legal Notice 194 of 2004: Water Policy Framework Regulations, 2004 is issued under both the Environment Protection Act and the Malta Resources Authority Act. It establishes a framework for the protection of inland surface waters, transitional waters, coastal waters, and groundwater. It states that there is one water catchment district for Malta and Gozo, and that catchment area management plans must be prepared. The framework is intended to prevent


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further deterioration to, and to protect, enhance, and restore the status of, aquatic systems. It aims to promote sustainable water use based on the long-term protection of available water resources, and to enhance the protection and improvement of the aquatic environment through specific measures to combat polluting discharges. The Regulations also deal with floods and the progressive reduction of pollution of groundwater. This Legal Notice, in combination with Legal Notice 23 of 2004 and Legal Notice 203 of 2002, issued under the Malta Resources Authority Act (see below), provides the basis for the assessment of the effect of the Scheme on the water quality of the mean sea level aquifer. As shown in Chapter 7, the effect of the Scheme on groundwater is considered to be insignificant and the application of appropriate mitigation measures will help to ensure that no surface water runoff leaves the site. The Water Policy Framework Regulations also deal with water bodies; one of which is Mellieha Bay. The impact of the Scheme on the quality of the marine environment at Mellieha Bay is also addressed in Chapter 7.

Noise

• Legal Notice 193 of 2004, Assessment of Environment Noise Regulations, 2004 sets the scene for a survey and report on noise; it does not set levels or detail measurement / assessment methodologies. For the assessment of noise impacts, UK guidance is used as described in Chapter 13.

Other

• Legal Notice 217 of 2001: Freedom of Access to Information on the Environment Regulations, 2001, which ensure freedom of access to and the dissemination of information on the environment held by public authorities.

o The EIS and its supporting documents fall under this Legal Notice and are to be made public.

Fertile Soil (Preservation) Act, 1973 6.48. This Act (Act XXIX of 1973) requires that, before undertaking excavations, the

Director of Agriculture must be informed to ensure that the soil is removed and is deposited in a manner approved by the Director. Further details governing the transport and reuse of soil are included in the Preservation of Fertile Soils Regulations (LN 104 of 1973) issued under this Act.

o The removal of soil from the Scheme site will be managed as indicated by local authorities34. The impacts are described further in Chapter 8.

34 Soil that can be used on site (e.g. for landscaped areas) should be stockpiled properly and moved in the

appropriate seasons to minimise damage to the soil texture.


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Legal Notice 160 of 1997 (Rubble Walls and Rural Structures (Conservation and Maintenance) Regulations

6.49. Rubble Walls and Rural Structures (Conservation and Maintenance) Regulations as amended by LN 169 of 2004 protects all rubble walls and non-habitable rural structures in view of their historical and architectural importance, their exceptional beauty, their affording a habitat for flora and fauna, and their vital importance in the conservation of the soil and water. Walls may be sensitively repaired without MEPA’s prior authorisation. Certain areas may also be declared to be Rubble Wall Conservation Areas in which no alterations to the location or construction of rubble walls and the traditional methods of their repair and maintenance will be permitted without the written approval of MEPA. In such Conservation Areas, the Minister for the Environment may order the owner or occupier to repair and re-erect all the rubble walls within the area, and to continue to maintain them. The dismantling of the wall requires a permit from MEPA. The Scheme Site has a number of rubble walls; their dismantling will require a permit.

Cultural Heritage Act, 2002 6.50. This Act provides overall protection to all movable or immovable objects of artistic,

architectural, historical, archaeological, ethnographic, palaeontological, and geological importance and includes information or data relative to cultural heritage pertaining to Malta or to any other country (section 2). It also includes archaeological, palaeontological, or geological sites and deposits, landscapes, groups of buildings…which have an historical value. In section 3 it also specifies that For the purposes of this Act, an object shall not be deemed to form part of the cultural heritage unless it has existed in Malta, including the territorial waters thereof, or in any other country, for fifty years, or unless it is an object of cultural, artistic, historical, ethnographic, scientific or industrial value, even if contemporary, that is worth preserving.

6.51. No person shall make any interventions on such cultural property or classes thereof without first having obtained a permit thereof from the Superintendent (Section 44.3). Applications are determined subject to the results of prior investigation: Before determining an application under subarticle (3) hereof the Superintendent may require such information including the results of such tests, examinations or inspection by such persons accredited under this Act for the purpose as may be required by the Superintendent (Section 44.4).

6.52. The restrictions on archaeological excavations is stated in Section 43(1) whereby Archaeological or palaeontological excavations or explorations on land as well as in the territorial waters or in the contiguous zone of Malta can only be made by the Superintendent, or with written permission of the Superintendent. Chance discoveries of archaeological remains are also regulated by Section 43(2), Any person who, even accidentally, discovers any object, site or building to which this Act applies in accordance with article 3, shall immediately inform the Superintendent, keep the object found in situ, and shall not for a period of six working days after informing the Superintendent proceed with any work on the site where the object of cultural property is discovered. The details about rights and obligations by all parties in the eventuality of an archaeological discovery


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are described in Sections 43(3), 43(4), 43(5), 43(6), 43(7). The Act is of particular relevance to the cultural heritage survey carried out as part of this EIS.

Malta Resources Authority Act, 2001 6.53. The Malta Resources Authority Act, 2001 established the Malta Resources Authority

and assigns to it a number of functions relating to the regulation of the water, minerals, and energy sector. The Minister responsible for resources may, among others, also make regulations for the granting, renewal, transfer, suspensions, and cancellation of licences, permits, or other authorisations.

6.54. The regulations currently in force under the Malta Resources Authority Act that are relevant to the Scheme include the Legal Notices listed hereunder.

• Legal Notice 203 of 2002: Protection of Groundwater against Pollution caused by certain Dangerous Substances Regulations, 2002 focuses on the protection of groundwater and introduces the concept of List I and List II substances. The purpose of the Regulations is to eliminate pollution from List I substances and to reduce the pollution from List II substances. They provide detailed measures to control the direct and indirect discharge of List I and List II substances.

• Legal Notice 23 of 2004: Quality of Water intended for Human Consumption Regulations, 2004 aims to protect human health through the provision of water that is wholesome and clean. It provides the parametric threshold values for a number of contaminants and sets standards required for water that is fit for human consumption. It introduces reporting obligations and obligations on consumer information.

6.55. These two regulations together with the Water Framework Regulations provide the basis against which the impact of the development on groundwater was assessed (see Chapter 7). The requirements of these regulations are met as the Scheme will not contaminate groundwater resources.

• Legal Notice 139 of 2002: Sewage Discharge Regulations, 2002 repeals Legal Notice 8 of 1993. It controls the discharge of effluents to the sewerage system and prohibits the discharge of effluents containing substances listed in Schedule A of the Regulations. All trade effluent must be covered by a permit and no effluent that can damage the sewerage system can be discharged. The municipal sewage produced on site will be discharged into the sewers in accordance with a Public Sewer Discharge Permit. Hazardous and contaminated waste will be kept separate from uncontaminated waste and treated in accordance with waste management regulations (see Chapter 5).

The Water Services Corporation Act, 1991 6.56. This Act (Act XXIII of 1991) established the Water Services Corporation (WSC).

Among other functions, the WSC was charged with the conservation of water resources and with the promotion of safe disposal of wastewaters and the reasonable


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use of water. Following the establishment of the Malta Resources Authority (MRA), most of the regulatory functions of the WSC have been assumed by the MRA.

Solid Waste Management Strategy 6.57. The Solid Waste Management Strategy (SWMS) provides a policy and decision-

making framework for the management of wastes and for the preparation of detailed implementation plans. The key areas arising from the SWMS in respect of waste arising from the Scheme are discussed in detail in Chapter 5.

PLANNING POLICY 6.58. Planning policy relevant to the Scheme comprises policies embodied in the Structure

Plan for the Maltese Islands, Space for Waste: The Waste Management Subject Plan, the North Harbours Local Plan, the draft Planning Policy on the Use and Applicability of the Floor Area Ratio (FAR) and the Policy & Design Guidance 2007.

Relevant Structure Plan Policies 6.59. This section reviews the Structure Plan Policies relevant to the Scheme.

Settlement Pattern

6.60. POLICY SET 6: As soon as practicable after the commencement date of the Structure Plan, Local Plans will be prepared for all existing built-up areas as specified in Section 4 of Part 1 of this Statement, together with contiguous Temporary Planning Schemes, with the objective of substantially improving the environmental quality of such areas and providing for all suitable uses. All Local Plans will be the subject of environmental impact analyses.

The Application Site falls within the North West Local Plan area. The Local Plan was approved by MEPA Board in May 2006 and received Ministerial approval in August 2006. A more detailed analysis of the relevant Local Plan policies is given below.

6.61. POLICY SET 11: No form of urban development will be permitted outside existing and committed built-up areas and primary development areas as designated in the Structure Plan even where roads and public utilities are available. Permitted forms of non-urban development outside such areas are restricted to the categories referred to in Paragraph 7.6

6.62. POLICY SET 12: Notwithstanding the policy against any form of urbanisation outside areas designated for urban uses in the Structure Plan, the Planning Authority will consider applications for permission to develop which ostensibly infringe Policy SET 11. In any such case the onus will be on the applicant to present evidence as to why the policy should be infringed, giving reasons why from a planning point of view such proposed use cannot be located in areas designated for development. The Planning Authority will additionally require the applicant to submit at his own expense a full Environmental Impact Assessment of a form and content satisfactory to the Authority. This policy is not a means of evading policy SET 11 or any other policy. An Environmental Impact Assessment which adequately demonstrates acceptable impacts will not be a reason for the granting of a development


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permit if the proposed use can be located in an area intended for its development under the Structure Plan or any subsequent approved Planning Authority document.

Although SET 11 prohibits development ODZ, the Local Plan identified the area where the Scheme is proposed for restrained redevelopment. The preparation of this EIS is congruent with the requirements of policy SET 12.

Built Environment

6.63. POLICY BEN 1: Development will not normally be permitted if the proposal is likely to have a deleterious impact on existing or planned adjacent uses because of visual intrusion, noise, vibration, atmospheric pollution, unusually high traffic generation, unusual operating times, or any other characteristic which in the opinion of the Planning Authority would constitute bad neighbourliness.

The matters raised under BEN 1 are considered separately in Chapters 4, 11, 12, and 13. Traffic generation is also considered in the Traffic Impact Statement. In terms of noise and vibration, it is expected that during the excavation and construction phase there will be disturbance and nuisance to neighbours. Although a number of mitigation measures will be put into place, some disturbance is still expected. The noise generated by the Scheme during operation is expected to be minimal. Emissions from traffic generated by the Scheme are not significant. The impact on visual amenity is judged to be of minor to no significance (see Chapter 11).

6.64. POLICY BEN 2: Development will not normally be permitted if, in the opinion of the Planning Authority, it is incompatible with the good urban design, natural heritage, and environmental characteristics of existing or planned adjacent uses, and is unlikely to maintain the good visual integrity of the area in which it is located. There will be a presumption against development which does not generally observe the design guidelines issued by the Planning Authority for built-up areas.

BEN 2 is only applicable in respect of its reference to the environmental characteristics of the existing or planned adjacent uses, and the maintenance of good visual integrity. The Scheme, as described in Chapter 4 and 11is likely to disrupt the visual integrity of the area to a minor extent during construction because of cranes and the unfinished building, and when operational is likely to result in changes to the visual integrity of the area, some of which are judged to be of minor significance.

6.65. POLICY BEN 3: Permission for development will normally be given only if provision is made in the proposal for the installation of underground ducts to link electricity and telecommunications distribution networks to the development, the ducts to be utilised immediately if underground supplies are available or held in reserve for subsequent use if only overhead supplies are available at the time of the development.

All utilities will be underground.


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6.66. POLICY BEN 4: During the interim period between the commencement date of the Structure Plan and the adoption of any particular Local Plan, permission for development in Temporary Provisions areas will be subject to Policies BEN 1, 2, and 3. Additionally, permission will not normally be given unless the Planning Authority is satisfied that such permission would be unlikely to compromise the objectives of the review forming part of Local Plan preparation. Within this overriding concern the Authority will also have regard to the location of the proposed development, with more favourable consideration being given to development close to developed areas and already provided with roads and services, and less favourable consideration to development relatively remote from existing buildings and infrastructure.

This policy is no longer applicable as the North West Local Plan has been adopted by Government. Policies BEN 1, 2, and 3 have been assessed in the preceding paragraphs.

6.67. POLICY BEN 5: Applications for development permits outside urban areas will be judged against the policies and design guidelines of the Local Plans for Rural Conservation Areas, and in the interim period, to Structure Plan policies and guidelines contained in the Explanatory Memorandum.

The Scheme falls within the North West Local Plan area, which is partly rural in character. Local Plans solely for rural areas were not produced; instead, the territory was divided into regions, which included both urban and rural areas. The NWLP identifies the Scheme area as suitable for development (see relevant section below) with conditions, although located in a rural area and outside the development zone.

6.68. POLICY BEN 12: The Planning Authority will decide if an Environmental Impact Assessment of a form and content satisfactory to the Authority is required to accompany any application for permission to develop. The environmental impact of proposed development will be carefully assessed through development control procedures, and where development permits are granted any adverse impacts will be mitigated through permit conditions and any other necessary legal measures.

MEPA has requested a full Environmental Impact Assessment for the Scheme since it constitutes an extension to an existing hotel outside the development zone and having a capacity of more than 250 beds (Section 3.3.1.1 of Schedule IA of LN 114 of 2007). This EIS has been prepared in line with the ToR issued by MEPA for this assessment.

6.69. POLICY BEN 17: Development permit applications shall include proposals for hard and soft landscaping, and measures by which their maintenance will be undertaken.

Landscaping (soft and hard) constitutes an integral and substantial part of the Scheme proposal. The landscaping proposals are sensitive to the location of the Scheme, the presence of the saline marshland nearby, and, as much as possible, follow MEPA’s Planting and Landscaping Guidelines for rural areas. Landscaping proposals are described in Chapter 4.


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Agriculture (soils)

6.70. POLICY AHF 3: A survey of the inherent agricultural quality of all land will be undertaken to supplement the 1989/1990 survey of existing agricultural land use.

Although not part of the survey mentioned in this policy, this EIS has surveyed the agricultural land that could be impacted by the Scheme and the different fields classified for their agricultural quality.

6.71. POLICY AHF 4: Soil conservation and soil saving measures will continue to be mandatory on all occasions. Soil replenishment measures will be adopted where there are suitable opportunities.

Any soil that there is on site will be reused in the landscaping scheme. Soil will be stored as indicated by the Department of Agriculture until it is required at the Scheme.

6.72. POLICY AHF 7: The removal of visual intrusion in the landscape, the reinstatement and maintenance of random rubble walls, and the establishment of rights of way will be a condition of development permits.

6.73. POLICY AHF 8: Further measures will be developed to promote the reinstatement and maintenance of random rubble walls throughout the countryside with priority given to walls alongside rural roads, and for the removal of visual intrusions.

A number of rubble walls will be dismantled for the Scheme to be developed. However, the stones will be salvaged and re-used to rebuild or maintain the rest of the existing rubble walls on site and for the construction of new rubble walls on the Scheme.

Minerals

6.74. POLICY MIN 19: The use of underground space in urban areas for vehicle parking will be encouraged. Adequate ventilation, damp proofing, and safety measures shall always be included.

The provision of extensive underground parking for residents and visitors of the Scheme is congruent with this policy. Ventilation, damp-proofing, and safety measures are included.

Tourism and Recreation

6.75. POLICY TOU 3: The Planning Authority will, within the provisions of the Structure Plan, give favourable consideration only to those development proposals that contribute to the achievement of stated tourism objectives.

The Scheme proposal is in line with the stated objective of upgrading the Mellieha Bay area, providing superior quality tourism accommodation, and has been issued with a Tourism Compliance Certificate by the Malta Tourism Authority.


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6.76. POLICY TOU 4: The Planning Authority will give favourable consideration to the development of further tourist accommodation within the built up areas and Temporary Provisions area as amended by the relevant Local Plans at Mellieha ……. Within these areas development will comply wit the Secretariat for Tourism’s Accommodation Projects and Policy Guidelines in respect of new provisions, and upgrading and extensions to existing premises.

The Scheme is located within Mellieha and therefore conforms to the general approach of this policy. The Scheme has also been issued with a Tourism Compliance Certificate by the Malta Tourism Authority (which has succeeded the Secretariat for Tourism).

Transport

6.77. The Transport Structure Plan Policies relevant to the Scheme are:

POLICY TRA 2: The promoters of major developments will be required to prepare traffic impact statements illustrating the likely impact of their proposals on the highway network.

POLICY TRA 3: Agreements will be required with prospective developers for the funding of the necessary remedial highway works required to accommodate their proposals.

POLICY TRA 4: The following vehicle parking principles will be adopted in different areas for new developments…:

3.Rest of Malta:: accommodating standards for all developments

POLICY TEM 1: The design of traffic management measures will conform to agreed standards for road design and construction.

POLICY TEM 4: Parking on the arterial and distributor networks will be strictly controlled at any location where it interferes with traffic flow or presents a safety hazard.

These policies are all addressed in the Traffic Impact Statement. Structure Plan Policy TRA 4 mandates the application of parking standards that meet the needs of the proposed development, including public parking for cars and other vehicles as described in Circular 3/93. The design of any traffic management measures will conform to the standards set by the Regulator. The indication that parking demand studies will be undertaken is noted, and the design of the Scheme will take account of the import of TEM 4.

Cultural Heritage

6.78. Policy UCO 7 establishes a protection classification for listed buildings within Urban Conservation Areas (Grade 1 to Grade 3). The policy describes each category and identifies what development is allowed by each category. Although not located within an Urban Conservation Area, this EIS grades all cultural heritage features within the A of I according to the same classification given here, as adapted by the specialist consultants. Details on the cultural heritage of the area are given in Chapter 10.


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Rural Conservation Areas

6.79. POLICY RCO 1: Rural Conservation Areas are designated as illustrated in the Key Diagram. Within such areas the following sub areas will be designated, using World Conservation Union definitions and criteria where relevant:

1. Areas of Agricultural Value: areas comprised of high-grade agricultural land including irrigated and partially irrigated land

2. Areas of Ecological Importance: relatively large areas designated to protect typical and rare habitats

3. Sites of Scientific Importance: sites containing individual species, groups of species, and geological features

4. Areas of Archaeological Importance: concentrations of valuable archaeological sites

5. Sites of Archaeological Importance: individual and/or isolated archaeological sites

6. National Parks: relatively large areas of national significance not materially altered by human use, with managed visitor access and amenities

7. Areas of High Landscape Value

The Site lies within an Area of Agricultural Value as identified in the North West Local Plan and close to an Area of Ecological Importance and Site of Scientific Importance (the Il-Hofra Marshland and the beach at Mellieha Bay); several other designated or protected areas exist in the vicinity of the Site as described in Chapter 4 and discussed in the relevant Chapters of the EIS.

6.80. POLICY RCO 2: Within Rural Conservation Areas and in accordance with Policy SET 11 no form of urban development will be allowed. However, in accordance with Policy BEN 5, applications for permission to develop structures or facilities essential to agricultural, ecological or scenic interests will be favourably considered as long as the proposed development does not infringe the principles set out ion RCO 4 as subsequently detailed in the relevant Local Plan (Policy RCO 3). ……

The Scheme is not a type of development that is allowed in Rural Conservation Areas by this policy.

6.81. POLICY RCO 3: As soon as is practicable after the adoption of the Structure Plan, the Planning Authority will draw up Local Plans covering all the areas designated by the Plan as Rural Conservation Areas. The purpose of these Local Plans will be to:

1. Specify the precise boundaries of areas having different forms of scenic value, Areas of Agricultural Value, Areas of Ecological Importance, Sites of Scientific Importance, Areas and Sites of Archaeological Importance, National Parks, and Areas of High Landscape Value

2. Specify in detail the measures of protection and enhancement to be adopted with respect to the various uses and activities


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3. Consider the results of the assessment of mineral deposits initiated by the Planning Authority (Policy MIN 2) and the implications for the further working of minerals and the sterilisation of land

4. Resolve conflicts between the various uses and activities

The NWLP was approved in August 2006. Restrained Redevelopment at the Site is contemplated in the Local Plan.

Scenic Value

6.82. POLICY RCO 4: The Planning Authority will not permit the development of any structure or activity which in the view of the Authority would adversely affect scenic value because it would:

1. Break a presently undisturbed skyline

2. Visually dominate or disrupt its surroundings because of its mass or location

3. Obstruct a pleasant and particularly a panoramic view

4. Adversely affect any element of the visual composition - for example, cause the destruction or deterioration of traditional random stone walls

5. Adversely affect existing trees or shrubs

6. Introduce alien forms, materials, textures, or colours

Impacts on the landscape arising from the Scheme are assessed in Chapter 11.

6.83. POLICY RCO 5: In Rural Conservation Areas, permission for the development of new or extended infrastructure (roads, reservoirs, overhead electricity and telephone cables, pipelines, tipping sites, etc.) will only be given if the Planning Authority is satisfied that all possible measures have been taken to mitigate the visual impact of the proposed development.

Impacts on the landscape and visual amenity arising from the Scheme are assessed in Chapter 11.

6.84. POLICY RCO 12: In Local Plans, the Planning Authority will give protection ratings to Areas of Ecological Importance and Sites of Scientific Importance as follows:

1. LEVEL 1 zones will include important habitat types present only in small areas and/or sites with unique species or features

2. LEVEL 2 zones will include important habitat types present in relatively large areas and/or sites with rare species or features

3. LEVEL 3 zones will include areas where control is necessary to preserve habitats/species/features in adjacent sites


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4. LEVEL 4 zones will include habitats and/or features of general interest

These are addressed in Chapters 7 and 9.

6.85. POLICY RCO 15: There is a general presumption against developments in urban and other built-up areas which are insensitive to the continued existence of identified features of scientific importance and significant elements of the country's natural heritage present within the area.

A number of designated and protected sites exist in the vicinity of the Site. Part of the site itself is identified as an Area of Agricultural Value in the NWLP. Protected sites in the vicinity of the Scheme site include the Il-Hofra marshland Level 1 Area of Ecological Importance and Level 1 Site of Scientific Importance, the Level 4 Site of Scientific Importance (Ghadira Beach), the Maritime Garrigue at Id-Dawra tat-Torri, a Level 2 AEI, the Ghadira Special Area of Conservation, Special Protection Area, and Natura 2000 site, and the Beach Post at id-Dawra tat-Torri and the Defence Post at Ta’ San Niklaw. The EIS assesses the impacts of the Scheme; no significant negative environmental impacts have been predicted at any of these sites.

6.86. POLICY RCO 28: Valleys will continue to be protected as important water catchment areas.

Although close to a shallow valley, the Scheme is not expected to negatively impact the valley. Hydrology impacts are addressed in Chapter 7.

6.87. POLICY RCO 29: No new physical development will normally be allowed on the sides of valleys and especially on valley watercourses except for constructions aimed at preventing soil erosion and the conservation and management of water resources. …..

The Scheme is not proposed within a watercourse or the valley proper. Measures aimed at collecting the added surface water run-off as a result of the development have been included in the design and are expected to mitigate any hydrological impacts of the Scheme.

6.88. POLICY RCO 31: Afforestation project sites in non urban areas will make use of indigenous archaeophytic (brought by man in prehistoric times, and now naturally occurring) species. The use of exotic (not native to the country) species will be limited to urban areas

6.89. POLICY RCO 32: The planting of appropriate species of trees will be encouraged where they enhance the landscape, particularly along roadsides, where they provide a screen to visually unattractive areas, and alongside footpaths where they provide shade. Species which attract birds will be encouraged in suitable locations.

Although not an afforestation project, the Scheme includes substantial landscaped areas that require an appropriate and sensitive approach to landscaping in view of the sensitive location of the Site. The provisions of these policies, though not directly applicable, will be taken into consideration, together with the relevant guidelines in formulating the landscaping plan.


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Archaeology

6.90. POLICY ARC 1: In Local Plans for Rural Conservation Areas, the Planning Authority will identify and designate Areas and Sites of Archaeological Importance. …..

6.91. POLICY ARC 2: In making designations referred to in Policy ARC 1, the Planning Authority will give protection ratings as appropriate to local circumstances as follows:

Class A: Top Priority Conservation. No development to be allowed which would adversely affect the natural setting of these monuments or sites. A minimum buffer zone of at least 100m around the periphery of the site will be established in which no development will be allowed

Class B: Very important to be preserved at all costs. Adequate measures to be taken to preclude any damage from immediate development.

Class C: Every effort must be made for preservation, but may be covered up after proper investigation, documentation and cataloguing. Provision for subsequent access shall be provided.

Class D: Belonging to a type known from numerous other examples. To be properly recorded and catalogued before covering or destroying.

6.92. POLICY ARC 6: In the interim period all sites recorded in the National Protective Inventory will be protected in accordance with Development Planning Act powers and by reference to the ratings in Policy ARC 2.

6.93. POLICY ARC 7: The Planning Authority will adopt, maintain, and extend the National Protective Inventory by initiating a programme of further investigation for all ratings of Areas and Sites of Archaeological Importance.

These Policies deal with the protection of archaeological artefacts. No Areas or Sites of Archaeological Importance have been designated on the Scheme site or its surroundings, however, a number of features exist in the area, some of which have been included in the National Protective Inventory as an interim protection measure. The impacts of the Scheme on the archaeological heritage are described in Chapter 10 of this EIS.

Water Conservation

6.94. POLICY PUT 8: In order to conserve potable water resources, the feasibility of using seawater and second class water systems in appropriate circumstances will be investigated. The efficient use and reuse of water will be maximised and integrated, including:

1. Controlled aquifer recharge from surface water runoff

2. Use of treated sewage effluent (TSE) for appropriate industrial, irrigation, and other uses

3. The management of road storm water runoff.


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This Policy focuses on the conservation and reuse of water resources. The water harvesting described in Chapter 4 of this EIS would be congruent with this Policy.

Space for Waste: the Waste Management Subject Plan 6.95. The Waste Management Subject Plan35 provides strategic long-term direction and

context to guide both Government and the private sector in waste management issues up to 2010. Its policies guide the strategic planning of waste and the determination of development permit applications for developments and land use changes related to waste management facilities. The policies relevant to the Scheme have been assessed in detail in Chapter 5. The Scheme is congruent with the Subject Plan policies.

The North West Local Plan 6.96. The Application Site falls within the North West Local Plan area. The Local Plan was

approved in August 2006.

6.97. The policies relevant to the Scheme are especially those that make up the Ghadira Isthmus Strategy. They are reviewed in the following sections.

6.98. The NWLP identifies the major issues that need addressing in this area as:

• Competing and conflicting demands on limited land and sea space;

• Over development on existing land;

• Congestion; and

• Environmental impacts.

6.99. In order to address these issues, the Local Plan calls for a broad policy framework that sets out the strategy for the area and which will be used as a guide to future development. This Strategy will then be followed up by detailed management plans on a site-specific basis, which plans will identify the actions required for the implementation of the Strategy.

6.100. Policy NWML 18 Strategy for Ghadira Isthmus

To resolve competing spatial demands on Ghadira Bay and its environs by giving priority to the conservation and management of the natural and cultural environment of the area, including the landscape, and protecting it from environmentally unsustainable development whilst reducing congestion and its adverse environmental impacts, and improving the overall environmental quality of the area.

6.101. The Local Plan will seek to achieve this strategy by requiring any planning proposal to:

35 MEPA October 2001.


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• Protect and enhance the natural and cultural environment;

• Improve transportation problems;

• Control tourism related development; and

• Manage recreation activities.

6.102. All applications for development within the strategy area of the Ghadira Isthmus will be assessed in the context of this strategy.

6.103. The proposals seek to conform to the spirit of the strategy through the improvement of the tourism and recreational product of the Mellieha Bay area by upgrading and consolidating the existing facilities in an area identified in the Local Plan as for “restrained redevelopment”. The development is not expected to adversely affect statutory protected areas; rather the applicant proposes to contribute to the rehabilitation and effective protection/management of existing environmental assets. The proposal will also include adequate car parking provisions in line with policy.

6.104. The Strategy Plan for Ghadira designates the majority of the Application Site as “Restrained Redevelopment”, and the remainder of the Application Site as “Enhancement of Areas of Agricultural Value”. The latter is shown as an “Area of Agricultural Value” on Map 34 of the Plan: Protected Areas.

Minerals Subject Plan Policies 6.105. The Minerals Subject Plan deals with the activities of the mineral industry as a whole

and provides planning guidance for the next 10 years. The Subject Plan’s policies of relevance to the geological resources are:

• HS 3, HS 4, HS 5, HS 6, HS 7, and HS 8 dealing with the safeguarding and extraction of mineral resources; and

• DC1 to DC 22 dealing with the impacts of such practice.

6.106. These policies are applicable to the Scheme insofar as mineral rock will be extracted during the excavation phase. Details of tests carried out on the material to be excavated to determine its quality are included in Appendix 1.

Policy & Design Guidance 2007 6.107. MEPA’s Policy and Design Guidance 2007 is relevant to the Scheme in terms of

building design, building height, access, parking requirements, and residential amenity.

o Design issues, access, and parking have been considered in detail in Chapter 4.


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OTHER STANDARDS

British Standards Institute 6.108. BS4142:1997 – Method for Rating Industrial Noise Affecting Mixed

Residential and Industrial Areas provides, in the absence of EU guidance, the basis for measuring and assessing noise levels in the vicinity of the Scheme.

o This standard is used in the assessment of noise because of the lack of guidance from the EU and Maltese legislation / standards.


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7. GEO-ENVIRONMENTAL RESOURCES

INTRODUCTION 7.1. This chapter focuses on the geo-environmental characteristics of the Application Site

and its surroundings.

7.2. The description of the geo-environmental characteristics of the Application Site sets the background against which the likely effects on the surroundings of excavation and construction works in the Application Site will be assessed.

7.3. This assessment draws on the baseline report prepared by Dr Aaron Micallef concerning geo-environmental resources as described in this chapter. Most of the baseline report is reproduced in this chapter given the technical nature of the studies carried out and the importance of the findings on the Scheme and its surroundings.

7.4. The potential key issues associated with the Scheme are outlined below:

Key Issues:

• Changes to geo-environmental features • Changes to hydrological regime • Pollution of aquifer • Pollution of run-off

Terms of Reference 7.5. The Terms of Reference (ToR) issued by MEPA required that the geo-environmental

description of the proposed development included consideration of the aspects outlined below:

2.0 A DESCRIPTION OF THE PROPOSED SITE

This description is identified by the area of influence for each relevant parameter. The area of influence for each parameter shall be determined by the consultants who shall also justify the extent of the chosen area of influence. This must be approved by the Malta Environment & Planning Authority prior to commencement of the EIA. This description should include:

2.4 Geology, Geomorphology, Hydrogeology and Hydrology

This should include a survey and characterisation of the sites’ geology, geomorphology and soils, palaeontology and the site’s hydrogeological conditions, ground water body (MT009 – Mellieħa coastal) with an emphasis on any special features or protected areas.


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Details, baseline surveys and characterisation of sites’ hydrological conditions should also be provided. Baseline surveys on characteristics of aquifers including aquifer properties, thickness of the unsaturated zone, depth to the permanent water table, sources of recharge of groundwater, pumping and abstraction, groundwater quality; characteristics of watercourses including discharges and withdrawals, water quality; catchment areas and drainage patterns, run-off including volume and route taken by run-off, dispersion characteristics and established groundwater protection zones including proximity to water catchment areas particularly those used for drinking water and irrigation and proximity to groundwater abstraction sources, wells, springs etc. should be carried out.

Geo-Technical Survey

A geo-technical survey of the material to be excavated and rock mass forming the foundation of the proposed structure shall be submitted. A number of core samples shall be carried, the number and location of which shall be as approved by MEPA prior to carrying out of any in situ tests. Rock sampling and testing shall comply with the relevant BS Standards. This description shall extend to at least 3 m below the deepest level of the proposed development (taking into consideration any facilities proposed underground).

This section shall provide the information required for establishing the economic feasibility for the reuse of the excavated material (including any necessary studies to determine such feasibility) required in Section 4.2.

4.0 ASSESSMENT OF ENVIRONMENTAL IMPACTS & RISKS OF THE PROPOSED DEVELOPMENT

All significant impacts of and risks posed by the proposed project, during construction and operation should be assessed, given the environmental characteristics of the site outlined in Sections 1 and 2 and the policies outlined in Section 3. A descriptive and quantitative analysis (including significance, magnitudes and timing) of the impacts of the proposed development should be made, and presented in summary chart format. The various techniques, methods and assumptions used in the analysis and predictions should be outlined. It is recommended that impact assessment should include:

(i) description of impact; (ii) magnitude and significance; (iii) duration (temporary and permanent); (iv) extent (in relation to site coverage and surroundings and associated

features); (v) whether direct or indirect; (vi) adverse or beneficial;


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(vii) reversible or irreversible effects of the impact and extent or irreversibility as well as description of any associated conditions / assumptions for irreversibility;

(viii) sensitivity of resources to impacts; (ix) probability of impact occurring; (x) confidence levels/limits to impact prediction; (xi) scope of mitigation / enhancement; and (xii) residual impacts Worse case scenarios should be assessed where relevant.

The impacts shall include:

4.4 Effects on Geology, Hydrogeology and Hydrology

This should address palaeontological, geomorphological, and physiographic aspects. The assessment of significance of impacts (positive and negative) should also include soil and coastal erosion, impacts on aquifers and water resources, permanent and/or temporary changes to the hydrologic regime of watercourses which may traverse the site, permanent and/or temporary changes to the hydrogeological regime of site including changes to the Mellieha coastal aquifer and its recharge. The impact on the surface water drainage pattern shall also be mapped and illustrated if the proposed development is constructed. The impacts on the surrounding area and property due to the resulting change in surface water drainage pattern shall be clearly described. If the impact assessment predicts potential hazards like slope instability or subsidence a risk assessment should be carried out.

Effects on soil should not be limited to the top and subsoil, but should include underlying drift deposits and, in some circumstances, solid geology.

This assessment shall include the impacts of the geology including the economic feasibility of the reuse of the excavated material, giving due consideration to all possible alternative uses. The assessment shall also investigate the effects and risks of excavations on the stability of the surrounding land.

5.0 DESIGN OF MITIGATION MEASURES

5.1 Mitigation Measures

This should include a description of the measures envisaged to prevent, minimise and where possible offset any significant adverse effects on the environment of the project during both construction and operational phases (including reference to consideration of alternatives in section 2 above). Such measures could include technological features; alternative technological features; operational management techniques; enhanced site-planning and management; aesthetic measures; conservation measures; reduction of magnitude of project; and health and safety measures.


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5.2 Residual Impacts

Any residual impacts, that is those impacts that cannot be mitigated or those remaining impacts following implementation of mitigation measures, should also be described, quantified and presented in tabular format.

5.3 Monitoring

Consultants must propose a monitoring framework which should take into account monitoring of those features considered to have a negative or an uncertain impact. The program must be proposed at different stages: before, during and after construction. Details regarding type of and frequency of monitoring must also be given. This program shall include an audit and evaluation of forecasts, predictions and mitigation measures made in the EIS. It should spell out (to the degree possible) the nature and extent of additional steps that should take place when unanticipated impacts or impacts larger than the projections occur.

Objectives of Assessment 7.6. In meeting these ToR the Geo-environmental study describes and assesses:

• The geology, geomorphology, and soils of the area;

• The quality and quantity of the mineral resources underlying the Application Site;

• The hydrology of the area including surface water drainage patterns, flows, and quality;

• The hydrologic and hydrogeologic features of the area;

• The impacts that may arise from the proposed Scheme on the geo-environmental resources of the A of I; and

• Proposes mitigation measures to minimise any adverse impacts and describes residual impacts.

ASSESSMENT METHODOLOGY

Standards and Guidance 7.7. The principle sources of guidance for the Impact Assessment are the Structure Plan for

the Maltese Islands, the North West Local Plan, and The Earth Conservation Strategy of the Nature Conservancy Council (UK), 1991. Additionally, the following legislation is relevant: The Malta Resources Authority Act (Act XXV of 2000), L.N. 194 of 2004 Water Policy Framework Regulations, 2004, L.N. 203 of 2002 Regulations for the Protection of Groundwater against Pollution caused by Certain Dangerous Substances, 2002, L.N. 337 of 2001 Waste Management (Permit and Control) Regulations, 2001, and the Fertile Soil (Preservation) Act (Act XXIX of 1973). The relevance of each of these is described in Chapter 6.


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AREA OF INFLUENCE 7.8. Different Areas of Influence (A of I) are used for the geology / geomorphology, and

for the hydrology/hydrogeology aspects of the study. These are reproduced in Figures 7.1 and 7.2.


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Figure 7.1: Area of Influence for Geology and Geomorphology


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Figure 7.2: Area of Influence for Hydrology and Hydrogeology


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METHODOLOGY

Competence of Surveyor 7.9. The Geo-environmental study was carried out by Dr Aaron Micallef, as approved by

MEPA.

Field Survey – Geology and Palaeontology 7.10. A field geological survey was undertaken to identify, map, and describe structural

features, outcrop formations, members or bed sub-divisions present in the A of I. Geomorphology was mapped according to component geomorphologic units. This survey was undertaken in 2004 as part of a wider study for the Ghadira Isthmus area36. The findings from this survey have been used in this EIS.

Subsurface investigation

7.11. The field geological survey was supplemented by a subsurface investigation to determine the thickness of the strata beneath the site and assess their mineral resource potential by examination of the rock core samples recovered.

7.12. For this purpose, five continuously cored holes were drilled to a depth of 3m below the lowest excavation level. The location of the boreholes is shown in Figure 7.3.

Field Survey - Hydrology and Hydrogeology 7.13. A hydrological / hydrogeological survey was undertaken to map the catchment area

and surface drainage patterns. A surface water flow study was carried out to estimate the water balance of the catchment area relevant to the Site.

36 Adi Associates Environmental Consultants, 2004. Mellieha Bay Regional Environmental Assessment. Vol 1;

68pp + 4 Appendices. San Gwann, September 2004.


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Figure 7.3: Location of boreholes


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POLICY CONTEXT 7.14. The principal sources of policy and legislative guidance for the Geo-environmental Study

are the Structure Plan for the Maltese Islands37, the North West Local Plan38, and the policies relating to development sites. Reference was also made to legislation concerning the pollution of groundwater resources.

General Overview 7.15. The conservation importance of the geo-environmental features was established by

reference to local legislation, the Structure Plan for the Maltese Islands (1990) and the guidance of the Nature Conservancy Council (UK) on Earth Conservation.

7.16. The extent of the vulnerability of the water resources was evaluated in the light of the above conservation policies and in accordance with L.N. 194 of 2004 - Environment Protection Act, 2001 (Act. No. XX of 2001) Water Policy Framework Regulations, 2004.

7.17. The excavation of the Application Site and hence the exploitation and conservation of mineral resources, as well as their vulnerability were assessed in the light of Structure Plan policies as well as the Minerals Subject Plan39.

7.18. The disposal of the excavated material is regulated by LN 337 of 200140, and the reuse of the soil is governed by the Fertile Soil (Preservation) Act 1973, as amended in 1980.

7.19. These Regulations have been discussed in detail in Chapter 6.

European Union Directives 7.20. The European Union does not have any directive that protects the geo-environment per

se. Of relevance to the proposed development, however, are the directives on the protection of groundwater resources against pollution events:

• Directive 80/68/EEC: On the protection of groundwater against pollution caused by certain dangerous substances;

• Directive 98/83/EC: On the quality of water for human consumption;

• Directive 2000/60/EC: The Water Framework Directive.

7.21. These Directives have been transposed into national legislation and are described in Chapter 6.

37 Planning Services Division, 1990a. Structure Plan for the Maltese Islands: Written statement and key diagram. Ministry for Development of Infrastructure, Government of Malta; xiii + 125pp + map.

38 Malta Environment and Planning Authority, 2006. The North West Local Plan. Floriana, August 2006. 39 Planning Authority, 2001. Minerals Subject Plan for the Maltese Islands. Draft for Public Consultation, August

2001. 40 Waste Management (Permit and Control) Regulations, 2001.


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Guidance 7.22. Conservation profiles are intended to prevent future potential damage to sites. Since

no earth conservation model exists for the Maltese Islands, it has been suggested in past studies (e.g. Debono & Scerri, 199641, Mallia et al., 199942) that until such a model is formulated, models used in other countries could be adopted for local use. The conservation model proposed is that adopted by the Earth Conservation Strategy of the Nature Conservancy Council (UK). In this model, sites of geological importance are classified into two groups: Exposure Sites and Integrity Sites. The conservation of the two groups is treated differently.

• Exposure Sites are those whose scientific or educational importance lies in providing exposures of a deposit that is extensive or plentiful underground but that is otherwise accessible only by remote sampling. Exposure Sites include outcrops, stream and foreshore sections, and exposures in quarries, pits, cuttings, ditches, mines and tunnels.

• Integrity Sites are those whose scientific or educational values lies in the fact that they contain finite and limited deposits or landforms that are irreplaceable if destroyed. These deposits or landforms are usually of limited lateral extent. Examples include caves, karst, glacial and fluvial deposits, and unique mineral, fossil, stratigraphic, structural, or other geological deposit and features (NCC, 199143).

41 Debono, G. and Scerri, S., 1996. North Harbours Local Plan Geology Survey Report. Prepared by Malta

University Services for the Planning Authority, Floriana, Malta; 72pp + 210 data cards + 15 figures + 20 plates. 42 Mallia, A., Briguglio, M., Ellul, A.E. and Formosa, S. 1999, Population, Tourism, Land-Use and Non-Renewable

Resources in the “State of the Environment Report for Malta 1998” commissioned by the Environment Protection Department, Government of Malta, Malta Council for Science and Technology, Malta.

43 Nature Conservancy Council, 1991. “Earth Conservation Strategy”, Peterborough, UK; 1991.


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GEO-ENVIRONMENTAL CHARACTERISTICS

GEOLOGY

Stratigraphy 7.23. The five Late Tertiary rock formations exposed on the Maltese Islands are, from base to

top:

• Lower Coralline Limestone (oldest);

• Globigerina Limestone;

• Blue Clay;

• Greensand; and

• Upper Coralline Limestone (youngest).

7.24. In addition to these formations, Quaternary continental deposits are also known to occur sporadically on the Maltese Islands. An unconformity and an erosional surface separate this unit from the underlying marine sedimentary succession

7.25. The only rock formation outcropping at the Scheme Site is the Upper Coralline Limestone.

Upper Coralline Limestone Formation 7.26. The geology of the Scheme Site is entirely composed of the Late Tortonian to early

Messinian (Miocene) Upper Coralline Limestone Formation, although the outcrop surfaces are covered by a layer of soil. Upper Coralline Limestone is also the only exposed Formation in the Area of Influence44. Upper Coralline Limestone is the youngest Tertiary formation in the islands reaching a thickness of approximately 160m in the Bingemma area. Local tectonic activity appears to have resulted in the brief emergence of the formation above the sea. The strata are very similar to the lowest stratum in the Maltese Islands (the Lower Coralline Limestone) both chemically and palaeontologically; indicating deposition in shallow waters. The transition from the underlying greensands is gradual, sometimes merging into red and black granular sandstone; or red and white coralline rich limestone, which passes into a white calcareous sandstone-compact, soft or porous but always rich in organic remains. Though some layers are completely crystalline and have lost traces of the organisms from which they originated, other portions are highly fossiliferous containing casts of shells and other organisms. The Upper Coralline Limestone is sporadically overlain by terrestrial, Aeolian, and alluvial deposits laid down following the emergence of the Maltese Islands above sea level.

7.27. The Formation can be sub-divided into four Members:

44 Blue clay exposures are present along the slopes of Mellieha Ridge to the southeast of the Area of Influence.


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• The Gebel Imbark Member;

• The Tal-Pitkal Member;

• The Mtarfa Member; and

• The Ghajn Melel Member.

Gebel Imbark Member

7.28. The Gebel Imbark Member is the youngest of the four Members of the Upper Coralline Limestone Formation. It is a hard, pale-grey carbonate having sparse faunal remains. Deposits of this Member are now restricted to erosional outliers and synclinal cores. This Member has a thickness ranging between 4 and 25m and consists of three different beds (Tat-Tomna, San Leonardo, and Qammieh)

Tal-Pitkal Member

7.29. This is a pale grey and brownish-grey coarse grained wackestone and packstone containing significant coralline algal, mollusc, and echinoid bioclasts. Mesophyllum and Lithophyllum rhodoliths are abundant in the lower beds, whereas the upper beds contain patch reefs and biostromes (e.g. the Depiru Beds) dominated by peloidal and molluscan carbonate mudstones with crustose coralline algae and scattered corals. Thickness of the Member varies from 30 to 50m, thinning eastward.

Mtarfa Member

7.30. The Mtarfa Member is a massive to thickly bedded carbonate mudstone and wackestone. It is yellow in the lower levels. Carbonates become white and chalky in the upper two-thirds of eastern outcrops. The lowest levels contain a facies independent brachiopod bed up to 1m thick. The thickness of this Member varies from 12 to 16m, thinning eastward.

Ghajn Melel Member

7.31. This is a massive bedded dark to pale brown foraminiferal packstone containing glauconite. Large Clypeaster echinoids and Macrochlamis pectinid bivalves are common. Much of the Member is composed of abraded Heterostegina foraminifer bioclasts. Thickness ranges from 0 to 13m. This is the oldest member of the series.


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Figure 7.4: Geology of the site and the surrounding area


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Faulting 7.32. Tectonic processes associated with the Great Fault system have had a major structural

control on the morphology of the Study Area. The Study Area is located in one of the downthrown blocks (grabens) formed by the Great Fault. It is not intersected by any faults; the nearest is located around 100m northwest of the site and passes through the adjacent valley (Figure 7.4). Two other faults, both striking ENE have been recorded in the Ghadira Isthmus area. All faults are normal, and the faults striking at the margins of the valley have had the most striking effect on the landscape, with the area in between subsiding into a graben tilting ENE. The ENE faults are also associated with coves located in Il-Qammieh and Ic-Cumnija, while the NE third fault line is linked with the formation of the Il-Prajjet inlet. The tectonic framework has a dominant control over the geomorphology of the area, although some fault scarps have been smoothed by denudation, particularly in the middle of the valley.

Site Investigations

Fieldwork

7.33. The Scheme includes a substantial amount of excavation to accommodate the lower levels and the pools. To determine the quality of the material on Site, five boreholes were drilled at locations agreed with MEPA (see Figure 7.3).

7.34. The cores recovered were logged, photographed and taken to the laboratory of Civil Engineering and Architecture of the University of Malta for testing.


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GEOMORPHOLOGY 7.35. The Application Site is a relatively flat site, with the terrain immediately South of it

sloping to a slightly higher level, such that the slope between the Mellieha By-Pass and the current hotel is of the order of 10º (see Figure 7.5).

7.36. The elevation of the terrain within the Application Site varies between 5m and 12m above sea level, with a gradient across the site of 0.07º.

7.37. The Area of Influence exhibits a varying morphology, with stepped / rolling land to the south, southeast, and east as the terrain rises towards Mellieha Ridge and flat gentle terrain to the southwest, west and northwest. To the north of the Application Site is the existing hotel, beyond which is Mellieha Bay.

Shore Platform 7.38. A small shore platform of Upper Coralline Limestone exists at Mellieha Bay, northwest

of the Application Site. This is restricted to a couple of metres and its elevation less than 1m above sea level. The surface of the shore platforms is extremely rugged, mainly as a result of wave pounding and salt weathering.

Sandy Beach 7.39. Mellieha Bay is the only depositional feature in the study area. It consists of a sandy

beach 460 m long, separated by a narrow shore platform (see above), making it the longest beach on the Maltese Islands.

7.40. The beach is a “pocket beach”45, and the absence of sand ridges on the beach surface excludes lateral outbuilding, or progradation, of strata in a sea-ward direction. Any transfer of sediment to the beach from the valleys behind has been cut off by the construction of the road and the cultivation of the land, leaving the beach as a relict feature. Thus there is no significant continuous input of sediment, and any loss of sand due to storms or human intervention can hardly ever be recovered. Wind transport of sediment further constitutes a slow but continuous mechanism through which sand is lost from the beach, particularly when it is harvested and removed from the system.

7.41. The part of the beach closest to the Application Site is located south of the shore platform and is the smaller of the two parts.

Valleys 7.42. The Ghadira Isthmus area drains a number of valleys; some are part of the Great Fault

horst and graben system, including the shallow valley adjacent to the application site, whereas others are set at right angles to the latter and incised in the Upper Coralline Limestone of the Mellieha Ridge (see Figure 7.5).

7.43. Valleys or widien are water cut valleys formed in the Pleistocene period. Water generally only flows during the wet season through these valleys. However, as a result

45 See alter section on beach dynamics.


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of the perched aquifers lying on the Blue Clay underlying the Upper Coralline Limestone, springs and/or seepage often ensures a flow of water well into the dry season. For this reason they are important natural and agricultural areas. The bulk of local plant and animal species associating with water during some part of their life-cycle are found in widien environments, while where the terrain permits, the widien sides are terraced and cultivated.

7.44. There are two important watercourses in the Mellieha Bay Region, both of which drain into the marshland at Il-Hofra: Il-Wied ta’ San Niklaw and its associated catchment that drains Il-Halqun and Qasam Barrani, and Wied ta’ Gnien Ingraw, the catchment of which extends from the fields at Ic-Cens to the Gnien Ingraw highlands. The latter is the catchment that is affected by the proposed project.

Quaternary Valley Deposits 7.45. Two small areas of Quaternary valley deposits are present within the Ghadira Isthmus

area; one at the Ghadira Nature Reserve to the northwest of the site, and a smaller one in the cultivated area behind the Il-Hofra marshland. Both are likely to date back to the Late Pleistocene and are composed of alluvium and local clays. The scarcity of Quaternary deposits in the Maltese Islands qualifies them as important heritage items, particularly the area which has been transformed into an ornithological reserve. The smaller deposit close to the Application Site is threatened by agricultural activity and inappropriate interventions (mostly due to lack of knowledge on its importance). This feature should be adequately protected and studied before further damage is inflicted on it.

Soil 25. The Alcol Series, a Xerorendzina, dominates the terrain at Ghadira and the Study Area.

The parent material is valley loams composed of alluvial, marine alluvial, and colluvial material. The soils at Ghadira have developed on a combination of Quaternary valley deposits and marine sands. The Alcol Series has a low organic content, high water-table, and an indicative thickness of 19cm. It lacks well developed horizons. Salinisation of the soil due to sea-water intrusion makes the soil uneconomic for agricultural production.

7.46. Terra soils, on the other hand, are relic soils formed during the Pleistocene that are little affected by the present climatic regime. They are mature and extensively weathered with low calcium carbonate content and low organic content. They have developed on the karst slopes of the northern Mellieha Ridge to the south of the Study Area and have an indicative thickness of 30cm.


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Figure 7.5: Geomorphology of the site and the surrounding area


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HYDROLOGY AND HYDROGEOLOGY 27. The hydrologic and hydrogeologic features identified within the Area of Influence

comprise:

• Perched aquifers;

• Wied Gnien Ingraw; and

• Il-Hofra saline marshland.

Perched Aquifers 28. An aquifer is a porous layer of rock capable of storing, filtering, and releasing water.

The rock layer contains many pore spaces which, when connected, make the rock permeable and allow movement of water through it. Aquifers are the Maltese Islands’ primary source of natural water as there are virtually no perennial surface water streams. 16 million m3 of water are extracted every year from such aquifers. 98% of this water volume is extracted from the mean sea-level aquifer, which lies in the pores and fissures of the Lower Coralline Limestone where this formation subcrops at sea-level. The remaining 2% of the extracted water volume comes from perched aquifers. The supply from these perched aquifers comes largely through springs and underground galleries. The flow is seasonal, intermittent, and highly variable. The Rabat-Dingli plateau has the most extensive of the perched aquifers found in the Maltese Islands.

29. The geology of the Study Area is conducive to the formation of perched aquifers. The terrain is predominantly composed of Upper Coralline Limestone underlain by the Blue Clay Formation. The superposition of these two formations provides strongly contrasting zones of permeability; these are the ideal conditions for the formation of a perched aquifer at the base of the Upper Coralline Limestone. Infiltration of surface water and subterranean flow during the wet season are the predominant forms of aquifer recharge and they are facilitated by the highly porous and permeable nature of the limestone. The soil cover within the Study Area and the adjacent fields also allows the gradual infiltration of water. The impermeable Blue Clay Formation acts as an aquitard and traps the percolating rainwater. The perched aquifer is dissipated by springs or through extraction.

7.47. The Area of Influence of the project has a high potential for aquifer recharge. Two distinct perched aquifers, separated by a west-south-west to east-north-east trending fault, can be identified:

• The Mellieha Coastal Aquifer (Groundwater Body MT 009); and

• The Mellieha Perched Aquifer (Groundwater Body MT 008).

The Mellieha Coastal Aquifer

7.48. The Mellieha coastal aquifer is located within the Ghadira Bay isthmus, which joins Marfa Ridge to the Mellieha Ridge (Figure 7.6). The geology hosting the aquifer is predominantly the Tal-Pitkal Member of the Upper Coralline Limestone Formation. The


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top of the Blue Clay Formation is below sea-level. The Mellieha coastal aquifer covers a total area of 2.9km2, which includes the Study Area. The base of the aquifer is synclinal at a number of places, providing limited storage. Its thickness is, however, unknown.

7.49. 92 boreholes are known tap the Mellieha coastal aquifer; with a mean annual volume extraction of 0.38hm3. The mean annual recharge, both natural and artificial, is 0.69hm3, resulting in a mean annual positive balance of 0.31hm3. The mean hydraulic conductivity of the Mellieha coastal aquifer is 2.93×10-6m/s. The Mellieha coastal aquifer gives rise to 2 ephemeral gravity springs.

The Mellieha Perched Aquifer

7.50. The Mellieha perched aquifer is located within the slopes of the Mellieha Ridge, to the south of the Mellieha coastal aquifer (Figure 7.6). The outcropping aquifer formations are the Tal-Pitkal and Mtarfa Members, which dip 3º to the north-west. The Upper Coralline Limestone Formation in this region varies considerably in thickness due to erosion and attains a maximum thickness of 62m. The outcrops of the Upper Coralline Limestone acts as a generalised recharge area for the underlying groundwater body.

7.51. The Mellieha perched aquifer is 27.5m thick and covers a total area of 4.5km2. 7 boreholes extract 0.53hm3 of water annually from the perched aquifer. The annual natural and artificial recharge volume is 0.75hm3, resulting in a positive annual water balance of 0.22hm3. The mean hydraulic conductivity of the Mellieha perched aquifer is 2.93×10-6m/s. Water seeps from the perched aquifers wherever the Upper Coralline Limestone-Blue Clay contact is exposed. This situation gives rise to 8 gravity springs that drain into valley watercourses in a north-west direction. Many of these springs used to flow all year round, although nowadays most of them have been tapped by farmers for irrigation. One of these springs, the Madonna spring, is used by the Water Services Corporation.

Anthropogenic disturbances

7.52. Both aquifers are vulnerable to pollution by leaching. The principal sources of pollution affecting the Mellieha coastal and perched aquifers are:

• Intensive agriculture;

• Leaks from the sewerage network;

• Animal husbandry activities; and

• The petrol station.

7.53. In the case of the Mellieha perched aquifer, this has resulted in high nitrate and chloride contents, which exceed 100mg/l and 250mg/l, respectively. No data on pesticide content is available, although the karstic nature of the aquifer makes it highly vulnerable to pesticide pollution. The Mellieha perched aquifer is at risk of failing both the Environmental Objectives of the Regulations related to the qualitative status of groundwater and the objectives set in the Nitrates Regulations. No chemical data exist for the Mellieha coastal aquifer. However, if the conditions of this body are assessed on


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the basis of the Pwales coastal aquifer, with which it shares many characteristics, the Mellieha coastal groundwater body is probably at risk of failing to achieve the Water Framework Directive’s objectives. An increasing demand for fresh water, mostly for agricultural purposes, has led to an over-abstraction of water from the perched aquifers through boreholes, which in turn has led to saline intrusions from the bounding seawater.

Wied Gnien Ingraw 7.54. A series of valleys, orientated south-east to north-west, dissect the northern side of the

Mellieha Ridge (Figure 7.6). The valleys are drainage channels formed by stream erosion into the Mtarfa Member during the Pleistocene during a much wetter climatic regime. The valleys are dry, and only carry water along their watercourse during the wet season.

7.55. Run-off from Wied Gnien Ingraw flows across the Study Area before discharging into il-Hofra saline marshland and Mellieha Bay. The Study Area is located 350m to the north-west of the mouth of Wied Gnien Ingraw. Wied Gnien Ingraw has a typical V-shaped cross-section with very steep sides, reaching a depth of ~30m. The valley floor becomes progressively more sharply incised upstream. The valley slopes have gradients that reach values of up to 40º and host a combination of steppe, garrigue, and maquis vegetation. The highest elevation in Wied Gnien Ingraw is 110m, dropping to 45m at the mouth. The axial watercourse of the Wied Gnien Ingraw is 500m long, up to 270m wide and is generally orientated south-south-east to north-north-west.

Il-Hofra Saline Marshland 7.56. Saline marshlands form an interface between the marine, freshwater, and terrestrial

environments. Il-Hofra saline marshland, 4,200m2 in area, is characterised by a muddy substratum on which a pool of brackish water collects in the wet season (Figure 7.6). It is maintained by seasonal fluctuations in precipitation, run-off, evaporation, and groundwater seepage, whereas coastal tidal fluctuations have an insignificant control. During the dry season the water in the saline marshland becomes progressively more brackish until it becomes hypersaline and finally disappears completely, leaving the marsh dry until the following wet season. Saline marshlands are locally very scarce and vulnerable, and most of them have either been obliterated or degraded by human activities. They support a highly specialised flora and fauna. The ecosystem hosted at il-Hofra saline marshland depends significantly on groundwater from the Mellieha coastal aquifer, as does the nearby Ghadira Nature Reserve.

Water Catchments 7.57. The Study Area is located within a water catchment that is 2.4 km2 in area. The geology

is comprised of the Upper Coralline Limestone and Blue Clay Formations. The limits of the watershed are the eastward pitching anticline of il-Bisqra to the north, the crest of Mellieha Ridge to the south, and the ridge between Wied Gnien Ingraw and Wied Ghar tal-Madonna to the east (Figure 7.6). The highest topographic unit within the watershed is 150m above sea-level on the Mellieha Ridge.


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Surface Water Flow and Water Balance Estimations 39. Malta experiences an average of 578mm of rain per year. Precipitation occurs in

sufficient quantities to produce run-off from October till February. The dry season stretches from May to September. On reaching the ground, the rainfall is absorbed by the soil and rocks at the surface. Part of the water flows as run-off (6%), whereas another part percolates downwards until it reaches an aquifer as recharge (24%). The run-off is either harvested or directly lost to sea. A substantial part of the rainfall is returned to the atmosphere via evapo-transpiration, which during the dry season is very high (70%).

7.58. The sub-catchment associated with the Study Area has been mapped in Figure 7.7. It represents the area of terrain the run-off from which would pass through the Study Area. The sub-catchment has an area of 0.30438 km2 that includes Wied Gnien Ingraw and the adjacent slopes. To estimate the water balance for the sub-catchment area where the Study Area is located, the area of the watershed is multiplied by the rainfall, giving the amount of water that is initially available. This is then further subdivided into run-off, evapo-transpiration, and percolation.

7.59. As shown in Figure 7.7, the sub-catchment is characterised by a variety of surfaces and land uses (Table 7.1). 0.006km2 of the sub-catchment is used for agricultural purposes, whereas 0.038km2 consists of abandoned fields. The high values of run-off co-efficients used for these two land uses are explained by the fact that the infiltration capacity of the soil cover has been reduced by repeated ploughing that has modified the soil structure. 0.121km2 of the sub-catchment is covered by karst pavement, which provides a direct route for the water to the underlying aquifer. Due to the high intensity nature of rainfall in the Maltese Islands, however, the karst pavement is unable to absorb all the incoming volume of rain water, which results in overland flow. This explains the run-off co-efficient of 30% used for this type of terrain. 0.0622km2 and 0.0172km2 of the sub-catchment are covered by steppe and garrigue vegetation, respectively. The topsoil supporting this vegetation may absorb water before saturation, allowing water to percolate into the underlying Upper Coralline Limestone. This explains the low values of run-off co-efficients attributed to these two habitat types. 0.060km2 of the sub-catchment is covered by urban land-use. Whereas previously the Upper Coralline Limestone that comprises the north-facing slopes of the Mellieha Ridge provided an area where rainfall could slowly percolate into the underlying geology, the building of roads and residences in Mellieha have reduced aquifer recharge considerably due to their low infiltration capacities.


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Table 7.1: Land uses and associated run-off co-efficients for the sub-catchment associated with the Study Area.

Land use Area (km2) Run-off co-efficient (%) Agriculture 0.006032 75

Abandoned agriculture 0.037813 70 Urban 0.060193 90

Steppe vegetation 0.062214 20 Garrigue vegetation 0.017199 25

Open land 0.120929 30 Total area 0.30438

Sub-catchment run-off co-efficient

45.4

7.60. The direction of surface water flow in the water catchment is predominantly northwards across Mellieha Ridge and southwards across il-Bisqra ridge (Figures 7.6and 7.8). The two water flows converge along the syncline that separates the two morphological units, where the water flows north-east towards il-Hofra saline marshland. Surface water flow is predominantly in a north-north-west direction within the Study Area (Figure 7.8).

7.61. The estimated annual water balance for the sub-catchment is shown in Table 7.2. The total annual volume of percolation for the sub-catchment is estimated at 28,817m3. The volume of run-off reaching the Study Area is estimated at 23,961m3 annually. The total annual volume of run-off and percolation for the Study Area at present is estimated at 2,367m3 and 789m3, respectively.

Table 7.2: Annual water balance for the sub-catchment associated with the Study Area.

Catchment Area m2 Run-off m3

Percolation m3 Evapo-transpiration m3

Total m3 (annual rainfall of 578 mm)

Sub-catchment 304,380 23,961 28,817 123,152 175,931 Study Area (present)

18,200 2,367 789 7,364 10,520

Study Area (operation)

18,200 2,613 542 7,364 10,520

7.62. After the proposed development is completed, the water balance of the Study Area will change (Table 7.2). 5,700m2 of the Study Area will consist of buildings or a swimming pool, which are attributed a run-off co-efficient of 100%. The remaining 12,500m2 of the Study Area will be landscaped. This will result in an annual increase of 246m3 of run-off from the Study Area and an equivalent decrease in aquifer recharge. It is likely that the on-site reservoir will capture all the runoff.


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Figure 7.6: Digital elevation model of the Study Area (marked by a solid black line) and the surrounding terrain

Note: The interpreted watercourses and the direction of overland flow are represented by the blue arrows. The watersheds are marked by a dotted black line and the perched aquifers by a solid blue line.


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Figure 7.7: Watershed and sub-catchment area at the Site and the surrounding area

The Study Area is represented by a solid green line (contours at 2.5m intervals)


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Figure 7.8: Surface water flow across Site


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MINERAL RESOURCE ASSESSMENT

Quality 7.63. The quality of the stone material was assessed on the basis of visual assessment and

logging of rock cores recovered from the site investigation and laboratory testing.

Visual assessment

7.64. The limestone core samples recovered from the Site revealed that the Site geology consists of a thin soil layer up to 1.3m deep underlain by Upper Coralline Limestone. Two different types of bed wee sampled:

• A top bed about 7m to 8m thick consisting of cream to light brown coloured, calcirudite, very coarse, massive, moderately strong limestone with fractures cemented by indurated red clay or laminated calcrete. The presence of gastropod moulds was noted; and

• A lower bed over 7m thick consisting of cream coloured calcarenite (reef) very porous, massive, moderately weak limestone grading downwards to a weak friable massive calcarenite, fracture planes are generally clean, and clay or calcrete filling fractures are absent.

7.65. Refer to Appendix 1 for further details on the core samples.

Laboratory testing

7.66. Visual assessment of the stone was supplemented by laboratory testing, which comprised the following tests:

• Uniaxial compressive strength;

• Water absorption;

• Wet and dry density; and

• Determination of resistance to fragmentation by the Los Angeles test method.

Results of the Investigation

7.67. The results of the investigation are detailed in Appendix 1, and summarised in Table 7.3.

Table 7.3: Summary of Laboratory Analysis Results

Sample ID. Diameter Failure Compressive Bulk Specific Gravity Water Absorption %

Load Strength

mm / kN / N/mm2

BH 1 Run 1 @ 1.2 m 72.2 35.70 8.73

BH 1 Run 1 @ 2.2 m 72.1 90.57 22.18


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Sample ID. Diameter Failure Compressive Bulk Specific Gravity Water Absorption %

Load Strength

mm / kN / N/mm2

BH 2 Run 1 @ 1.0 m 72.3 51.23 12.48 1.9

6.5

BH 2 Run 1 @ 2.0 m 72.3 38.81 9.45 2.0 5.6

BH 2 Run 2 @ 3.5 m 71.9 14.80 3.64 1.7 12.9

BH 2 Run 3 @ 6.4 m 72.0 12.25 3.01 1.6 17.7

BH 3 Run 1 @ 0.5 m 72.4 72.82 17.69

BH 3 Run 1 @ 1.5 m 72.2 36.89 9.01

BH 4 Run 1 @ 0.9 m 72.1 121.09 29.65 2.3 1.4

BH 4 Run 1 @ 2.35 m 72.2 27.66 6.76 2.1 4.2

BH 4 Run 2 @ 3.5 m 72.3 74.45 18.13 2.3 2.0

BH 5 Run 1 @ 1.6 m 72.3 120.73 29.40 2.3 1.2

BH 5 Run 1 @ 2.6 m 72.3 132.86 32.36 2.4 1.1

BH 5 Run 1 @ 3.6 m 71.8 127.32 31.44 2.5 0.9

BH 5 Run 2 @ 7.5 m 72.2 48.85 11.93 2.3 1.9 7.68. The test results show that the rock is of a mixed quality. The Los Angeles resistance to

fragmentation test indicated that both poor quality and good to fair quality rock is found on Site. The average uniaxial compressive strength for the samples tested is 16.4Nmm-2. The rock is, on average, moderately strong although still relatively low for a hardstone.

ASSESSMENT OF IMPACTS 7.69. The following criteria have been used to assess the significance of the impacts on the

geology, hydrogeology, and hydrology within the A of I during the Scheme’s operation:

• Not significant

o Little or no change to the hydrologic regime or geological / geomorphological regime and no significant change to the quality of the aquifer;

• Minor significance

o Geology / Geomorphology: changes to the geological / geomorphological regime that may affect neighbouring properties but which may be offset by mitigation measures;


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o Hydrology: changes to the hydrologic regime but no impact on the aquifer; modifications to the surface water drainage pattern that will not negatively affect downstream users, or with potential for substantial changes to be offset by mitigation.

• Major significance

o Geology / Geomorphology: changes to the geological / geomorphological regime that may affect neighbouring properties that may not be offset by mitigation measures (if negative) or may be enhanced by mitigation measures (if positive);

o Hydrology: changes to the hydrologic regime that impact the aquifer or adjacent water-based features (e.g. wetlands) with little opportunity for changes to be offset by mitigation (if negative) or may be enhanced by mitigation measures (if positive).

Prediction and Significance of Impacts

Changes to geo-environmental features

7.70. As described in Chapter 4, substantial excavation is envisaged as part of the Scheme, hence the impact on the geology of the Site is considered to be of major significance. The preliminary mineral resource assessment revealed that the rock to be excavated is of relatively good quality and it will therefore be excavated and recycled for use in concrete or other construction products.

7.71. No significant geomorphological feature will be affected by the excavation of the site and the construction of the Scheme.

Aquifer recharge

7.72. A substantial part of the Application Site will consist of landscaped grounds, especially in the western part of the site. The water falling on the rest of the site (buildings and hard landscaped areas) will be collected and channelled to an on site reservoir for re-use as second class water and in irrigation (see Chapter 4). This has been calculated as a reduction of 246 m3 in percolation. From Table 7.2, this represents a loss of recharge of approximately 0.85% (of the total sub-catchment area) and is considered to be insignificant.

Pollution of run-off and the aquifer

7.73. The entire Site lies on Upper Coralline Limestone, which is a porous and fissured limestone. This rock type therefore facilitates the passage of water reaching the aquifer. In this case, since the site lies in a graben, the aquifer in question is the mean sea level aquifer. However, since the site is so close to the coast, the quality of the aquifer in this location is poor, with significant amounts of chlorides due to seawater infiltration. Indeed, the quality of agricultural land close to the coast in this location is limited by the salinity of the groundwater. The Scheme Site in fact lies outside the groundwater protection zone.


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7.74. Nonetheless, it is important that all utility infrastructure on site is properly constructed and adequately serviced to ensure against leakages into the ground.

7.75. Likewise, all surface water run-off generated on Site post-construction, should be collected and stored in on site reservoirs for re-use in irrigation, fire fighting, and as second class water. To this end, as described in Chapter 4, a 5,400 m3 rainwater reservoir will be constructed beneath the new extension in which the rainwater falling on the building and the hard landscaped areas will be collected. Run-off from the roads will not be allowed to enter the site and instead will continue to be diverted into a road-side culvert and diverted to sea as at present.

7.76. Management of run-off water during construction is based on the use of sumps where the water will be collected and pumped out for disposal. This silt-laden water will not be allowed to flow out of the site so as not to affect the nearby marshland, agricultural land, and the sea. These measures are described in Chapter 4.

7.77. With these mitigation measures in place, i.e. measures that ensure that water landing on or passing through the Site will be collected; impact on the aquifer is predicted to be not significant.

MITIGATION 7.78. The following mitigation measures are proposed to mitigate the impacts of the Scheme

on the geo-environmental resources of the A of I:

• The soil on the Application Site will be removed when dry in order not to negatively affect its structure. The soil will be stored in a specially dedicated area on site for use in the Landscaping Scheme. Any soil that will not be required on site will be reused as directed by the Director of Agriculture, possibly within the surrounding area;

• Hazardous waste deposit containers (especially for oily rags, oils, and similar polluting materials) will be provided on-site within the Temporary Construction Camp and emptied regularly to approved disposal sites;

• No servicing of vehicles or machinery will be carried out on site;

• The existing road side culvert to be retained and maintained to ensure its continued use;

• As much of the excavated material as possible should be recycled into construction products or re-used in the landscaping scheme; and

• A Construction Management Plan and Environmental Management Plan must be formulated and implemented from the start of the project; the contents of the plan must be communicated to all personnel and training provided where necessary.


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RESIDUAL IMPACTS 7.79. The above mitigation measures should mitigate most of the impacts identified above;

however impacts on the geology of the site as a result of excavation cannot be mitigated.


143

Table 7.4: Summary of Impacts on the Geo-environmental Resources

Predicted Impact

Beneficial/ Adverse Nature, Scale and Type of Impact Policy

Importance

Probability of impact occurring

Significance of Impact (Major, Minor, Not

significant)

Proposed Mitigation Measures

Significance of Residual

Impact

Constr’n / Oper’n

Extent of impact

(Nat/Local/ Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers/ Irrevers

(Inter / National/

Local)

(Likely, Unlikely, Remote,

Uncertain)

Legislation

In context of Scheme

(Major, Minor, Not significant)

Changes to geo-environmental features

Adverse Both Local Direct L term Perm Irrevers Local Likely Major Minimise excavation footprint to bare minimum

Major

Aquifer recharge

Adverse Oper’n Local Direct L term Perm Revers. Local Likely Not significant None Not significant

Pollution of aquifer

Adverse Constr’n Local Direct S term Temp Revers. Local Unlikely EPA Minor All water falling on the Site will be collected and will therefore not reach the aquifer

Not significant

Pollution of runoff

Adverse Constr’n Local Direct S term Temp Revers. Local Remote EPA Minor All water falling on the Site will be collected

Not significant


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PA 00720/05: Extension to Seabank Hotel: Environmental Impact Statement

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8. AGRICULTURE

INTRODUCTION 8.1. This chapter considers the likely impacts on agricultural activities as a result of the

proposed Scheme.

8.2. The assessment draws on the baseline report prepared by Mr Joseph Buhagiar concerning agricultural land. Most of the baseline report is reproduced in this chapter given the importance of the findings on the Scheme and its surroundings.

8.3. The potential key agricultural issues are outlined below:

Terms of Reference 8.4. The agricultural assessment has been undertaken in accordance with the Terms of

Reference issued by MEPA. The relevant sections of the ToR include:

2.0 A Description of the Proposed Site

This description is identified by the area of influence for each relevant parameter. The area of influence for each parameter shall be determined by the consultants who shall also justify the extent of the chosen area of influence. This must be approved by the Malta Environment & Planning Authority prior to commencement of the EIA. This description should include:

2.3 Land Cover and Agriculture

This should include a survey with details of crops, trees and vegetation in general. The survey shall also describe the quality, value, productivity of

Key Issues:

• Loss of good quality agricultural land

• Adverse effects on agriculture in the surrounding area

• Loss of protected trees

• Social impact on farmers


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agricultural land including a description of soils and whether the agricultural land qualifies as High Nature Value Farmland (HNV)46.

4.0 Assessment of Environmental Impacts & Risks of the Proposed Development

All significant impacts of and risks posed by the proposed project, during construction and operation should be assessed, given the environmental characteristics of the site outlined in Sections 1 and 2 and the policies outlined in Section 3. A descriptive and quantitative analysis (including significance, magnitudes and timing) of the impacts of the proposed development should be made, and presented in summary chart format. The various techniques, methods and assumptions used in the analysis and predictions should be outlined. It is recommended that impact assessment should include:

i. description of impact; ii. magnitude and significance; iii. duration (temporary and permanent); iv. extent (in relation to site coverage and surroundings and

associated features); v. whether direct or indirect; vi. adverse or beneficial; vii. reversible or irreversible effects of the impact and extent or

irreversibility as well as description of any associated conditions / assumptions for irreversibility;

viii. sensitivity of resources to impacts; ix. probability of impact occurring; x. confidence levels/limits to impact prediction; xi. scope of mitigation / enhancement; and xii. residual impacts

Worse case scenarios should be assessed where relevant.


4.3 Effects on Agriculture

Impacts on the agriculture in the locality and the surroundings, including the impact of loss of land on the viability of the holding and the effect on agricultural operations in the locality.



46 This aspect of the Terms of Reference were scoped out during the scoping stage.


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This should include a description of the measures envisaged to prevent, minimise and where possible offset any significant adverse effects on the environment of the project during both construction and operational phases (including reference to consideration of alternatives in section 2 above). Such measures could include technological features; alternative technological features; operational management techniques; enhanced site-planning and management; aesthetic measures; conservation measures; reduction of magnitude of project; and health and safety measures.



5.3 Monitoring


8.5. Malta has not yet designated High Nature Value (HNV) Areas. In order to address this lack of data, in 2006 the Department of Contracts issued a Tender (Tender Reference CT 2445 / 2006) that was funded under the Rural Development Programme 2004-2006 entitled “Integration of Environmental Concerns into Malta’s Agriculture on the basis of the IRENA Operation”. One of the aims of the project was to compute the IRENA indicators for a particular area (a Special Area of Conservation) in Malta. One of the indicators (Indicator number 26) is the designation of High Nature Value Farmland. The terms of Reference of the Tender require the Consultants to “develop a set of suitable criteria, parameters and methods for the identification and classification of High Nature Value Farmland in the Maltese Islands in accordance with IRENA Indicator No. 26”. The IRENA project has not yet been completed and, therefore, the chosen criteria, parameters and methods for the identification and classification of High Nature Value Farmland are not publicly known. Until these criteria and parameters are published, the EIS cannot provide an indication of whether the agricultural land within the Application Site and its A of I qualifies for High Nature Value Farmland47.

47 It is noted that Technical Appendix 3: Agriculture Baseline Survey includes criteria that were set by the

consultant, Mr J Buhagiar. It should be noted that these criteria are unofficial.


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ASSESSMENT METHODOLOGY 8.6. A preliminary desk study of existing maps and surveys and retrieval of existing

baseline data was carried out. This was followed by standard compilation of data following surveying, photography, and on-site interviews.

Desk Study 8.7. A literature search was carried out for previous survey work and reports related to

the study area, in addition to the old ordinance survey maps that show the military installations around the Site. From the literature search, it was concluded that no previous agricultural survey work has been carried out in the area. The sources of information used included Ordinance and Geology survey maps for the physical characteristics of the site and recent aerial photos of the site namely:

• MEPA map server site maps;

• Geological survey map (Oil Exploration Directorate, 1993);

• Aerial photographs and orthophotos of the Site (MEPA, 2004); and

• Satellite photos.

Area of Influence 8.8. The Area of Influence (A of I) is illustrated in Figure 8.1. The A of I is divided into

two – an inner core that will be impacted by the development and its immediate surroundings (the land bound by existing roads) and the agricultural land in the wider area. The field survey was carried out over the inner core A of I. Existing data of the agricultural land cover over the wider area was used to inform the study.

Mapping of Field Structures, Crops, and Trees 8.9. During the field survey, wherever possible, interviews were held with farmers or

tenants. The following are the survey parameters that were observed:

• Height and condition of retaining walls;

• Presence of field structures, reservoirs, wells, irrigation equipment, etc;

• Standing and seasonal crops by type and variety where identifiable, quantity and stage of maturity;

• Current cropping pattern for seasonal crops;

• Previous cropping pattern where this could be discerned from residues or gathered from interviews; and

• Growth condition of the crops.


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Figure 8.1: Agricultural Area of Influence


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FIELD SURVEY RESULTS

The Application Site and A of I 8.10. The Site is subdivided into a number of small terraced fields, labelled 1-49 on Figure

8.2. The Site includes a number of reservoirs and boreholes as illustrated in Figure 8.3. The fields on the survey site also have a high concentration of old stone irrigation channels indicating access to a good water source in the past.

8.11. Figure 8.4 illustrates agricultural land cover over the wider A of I48. The Application Site is classified as irrigated land.

8.12. Figure 8.5 presents the results of the field survey.

Soil

8.13. An understanding of the underlying rock substratum is usually important to identify the type of soil present on the site. The underlying rock substratum in the survey area as given in the Geological Survey Map (Oil exploration directorate, 1993) is an Upper Coralline Limestone Tal-Pitkal member. This type of substrate usually gives rise to the in situ formation of Terra soils though this may be modified from admixture of other types of substrates brought to the site by colluvial action or through anthropogenic activity. The site is located at the base of a steep hill, with strata at higher elevations including Upper Coralline Limestone as well as Blue Clay and Greensands. The soil over the survey site is in the majority a Terra Rossa with a tendency for the formation of a hard surface crust characteristic of Terra soils after heavy rain. However it is not an intensely red coloured soil nor is it the chocolate brown coloured soil typical of Terra Fusca. Terra soils are typically formed on Coralline limestone with a tendency to be clayey and consequently not free draining. The indications over the entire site are that the soil is one formed from in situ Terra soil mixed with other substrates including globigerina limestone flakes and flour possibly during field formation and terrace building. Indeed the soil in this area has been classified as showing characteristics similar to the L-Iklin complex. The soil also contains elements partly accumulated by colluvial action from the surrounding steep sided hills such as Greensands which give the soil a gritty texture. There are some fields where the colour of the soil and its characteristics are different and more typical of a Xerorendzina. Such a situation is accounted for by importation and spreading of soil taken from another site. Xerorendzina occurs on nearby fields in the vicinity of the Ghadira nature reserve. One field namely the inner half of field No 32 has a very pale coloured soil that is conspicuous compared to the more typical red coloured soil of the same and surrounding fields.

8.14. The soil is estimated to be of variable depth ranging from less than 10 cm in some areas to over 50cm deep in most fields especially in the outer reaches of the terraces. In some parts of the survey area, the terraces from the soil surface are close to 1m high though not necessarily all is soil since some would be rock infill.

48 Taken from the Regional Environmental Assessment (2004), Adi Associates Environmental Consultants Ltd.


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There are some areas where bare rock is visible especially on the higher reaches of the site (ie near the south border adjacent to the road) attesting to a poor soil cover here.

8.15. These soils have been worked for a long time, though some are recently abandoned. They are typically very fertile, retain a good amount of water, and though they have a certain clay content this is not sufficiently high to impede drainage and make the soil difficult to work. A cursory assessment of the nutrient status of the soil on the site indicates that there are no major nutrient deficiencies especially for nitrogen, which is considered as the major nutrient. Indeed some of the abandoned fields had a good cover of large leaved stinging nettle, (Urtica dubia = U. membranaceae, Hurrieq Komuni) which is typically a highly nitrophilous species. Given that some of the fields have not been recently worked and manured, the nitrogen nutrient load must be very high. Other nutrients such as phosphorous are usually available as a mineral in these types of soils especially if limestone flour from phosphatic nodule-rich beds was added in the past.

Field Structures, Wells and Reservoirs

8.16. There are several old structures as well as recently converted or extended buildings on the site. Some of the old structures qualify as large field rooms as those present on field 49 and field 5. The structure present on field 10/20 is a large converted farmhouse currently serving as a residence for the owner of the site. The fields in the immediate surroundings have been converted into a garden mostly for ornamentals but there are also olive and citrus trees.

8.17. Several wells and reservoirs as well as boreholes were recorded on the survey site. The position of the boreholes is shown in Figure 8.3. Water storage appears to have been a priority for this area with at least eight open reservoirs present on the site. Four are quite large and in a good state of repair, the others are smaller and are holding little water due to structural damage. The presence of this large number of reservoirs comes as no surprise given that the site is in a water catchment area and that it is located at the edge of Gnien Ingraw. The latter has been known since antiquity to have been sourced by fresh water springs from the perched aquifer on the Mellieha uplands. There are also extensive networks for water distribution some of which are based on the traditional stone canals. The stone canals are shown in Figure 8.5. A distinction is made between two sets of canals as illustrated in Figure 8.5. One set of canals is found at the bottom of the terrace walls i.e. completely shaded and very close to the soil surface feeding water from the inner reaches inwards. There are also canals that are found both at the top and bottom of the rubble wall. In this case these are feeding the outer reaches of a terrace and the lower reaches of the terrace directly below. The use of modern irrigation techniques with metal and black plastic distribution pipes (40 and 65mm) as well as drip lines, sprinklers with risers have also been observed on the site. The degree to which the old systems and the new system is being used depends on which fields were being worked at the time of the survey. Fields that were abandoned at the time of the survey invariably had canals that were clogged with weeds and debris.


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But a good number of the canals still in use have signs of neglect with algal growth where water is dripping or leaking. The use of clay to seal leaks, which is very time consuming does not seem to be practised extensively.

Boundary Walls and Plantings along Field Margins

8.18. The boundary walls for most of the fields on the site are in a very good state of repair. Wall heights are indicated on the survey maps and given as a measurement above soil level (upward facing arrow) or below soil level to the next terrace level (downward facing arrow). The highest wall observed was around 2m on field 24. The walls are in their main not planted with fruit trees as the practice for most fields in Malta but still there is a substantial number of fruit trees including the prickly pear, figs, peaches, almonds and other stone fruits as well as vines, pomegranate, olives, citrus and even 4 banana mother plant clumps on field 48, which has a large water reservoir. The position and number of these fruit trees are indicated in Figure 8.5.

8.19. Planted along part of the length of this wall there are a number of fruit trees. One area has the highest concentration of fruit trees including:

• Grape vines (Vitis vinifera);

• Fig trees (Ficus carica);

• Prickly pears (Opuntia ficus indica);

• Bitter almonds (Amygdalus communis);

• Peaches (Prunus persica);

• Pomegranates (Punica granatum);

• Banana (Musa x paradisiaca);

• Olives (Olea europaea); and

• Citrus (Citrus aurantium and Citrus limon).

8.20. Other areas have a high concentration of prickly pears and some areas also have large carobs or reeds. These are planted to give protection from the north winds given that the upper reaches are prone to exposure though the current hotel building offers some protection.

Agricultural Land Classification

8.21. Land can be classified according to the land capability and land suitability for a particular management system. In carrying out agricultural land capability assessments, broad land use is ranked according to the limiting values of a number of soil and site properties which restrict or prevent activities under consideration. This is in contrast to land suitability assessment where a clearly defined homogenous practice on a particular site is classified on the basis of positive features associated


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with the success of that particular land use. For the purposes of this study, agricultural land capability assessment is relevant.

8.22. The USDA system was used to classify the Site. The classification system is summarised in Table 8.1.

Table 8.1: Classification of agricultural land according to the USDA system of classification

Criterion Class 1 Class 2 Class 3 Class 4 Permanent Physical Limitations Soil textural characteristics

No/Slight Moderate Severe Severe

Soil depth Deep Moderate Moderate Fairly good Slope angle Nearly level Gentle slope Moderately steep Steep slope Overflow damage & gully erosion

Not subject Subject Moderate Severe

Temporary Physical Limitations Nutrient status - fertility erosion

Need manure or fertilisers

Moderate Low fertility Severe erosion

Poor drainage - puddle erosion

Subject Need drainage N/A N/A

Cultivation & crop production limitations Land quality for agriculture

Good Good Restricted Restricted

Risks of damage in cropland use

No/Slight Moderate Severe Severe

Productivity Good Moderate Low Low Cultivation cycle Rotation beneficial May need rotation Need special

rotation Occasional cultivation only

Cultivation method Ordinary Ordinary to Special tillage

Restricted tillage special handling needed

8.23. In accordance with Table 8.1, this site can be classified as Class 1 and though currently it is being underutilised, it is still to be considered as one of the few examples of prime agricultural land. This is in terms of its soil quality, depth, location, accessibility, water availability as well as irrigation and water storage facilities. The major site limitation is exposure to high north and northwest winds which, considering the exposed nature of the site and its proximity to the sea, can lead to losses from wind and salt burn. This situation is now partly offset with the shelter afforded by the existing hotel.

8.24. Given that there are few limitations, this site is ranked at a high land capability level namely Class 1 with partial exposure limitation (since this can be offset with use of suitable wind shelters). Its setting in relation to adjacent land that shares equal land capabilities and is equally intensively farmed because of the availability of good quality irrigation water, gives it additional standing.


154

Figure 8.2: Fields within A of I


155

Figure 8.3: Reservoirs and boreholes


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Figure 8.4: Agricultural land cover recorded in the Regional Environmental Assessment


157

Figure 8.5: Field survey


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ASSESSMENT OF IMPACTS

Determining Impact Significance 8.25. In assessing the significance of potential negative impacts, the following criteria have

been used:

• Not significant - no material change in agricultural quality and/or extent;

• Minor significance - small-scale loss/disturbance of agricultural land that is unlikely to affect the agricultural integrity of the site; and

• Major significance - large/small scale loss/disturbance to agricultural land that is likely to affect the agricultural integrity of the site.

Potential Impacts 8.26. Potential impacts could include:

• Permanent loss of good quality agricultural land through permanent land take, leading to loss of agricultural production;

• Dust impacts reducing agricultural productivity in the Area of Influence;

• Loss of protected trees; and

• Social impact on farmers.

Loss of Agricultural Land 8.27. Good quality (Class 1) agricultural land will be lost as a result of the Scheme

resulting in a major negative impact.

Dust Impacts on Agriculture in the Area of Influence 8.28. Dust impacts on agriculture to the east, west, and south of the Site during

construction are expected to be of minor significance because these fields do not lie downwind of the prevailing northwesterly wind. Fields lying downwind of the prevailing wind (i.e. southeast) are over 200m away from the Application Site. Dust arising from globigerina limestone has been shown to return to the ground within 100 metres49 of its release. Although the rock on the Application Site is Coralline Limestone (hardstone) since there will be no crushing on the site, it is expected that dust particles will be similar or larger than that observed for Globigerina. Therefore, the majority of the dust arising from the Site during construction will not reach these fields. Consequently, impacts from dust on agriculture within the Area of Influence

49 This has been demonstrated by monitoring emissions in a softstone quarry area in Environmental Planning

Statement: PA 05616/01 To sanction a softstone crusher and a concrete block making machine at Triq il-Belt Valletta, Mqabba, Planning Services Consultancy, 2003.


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are expected to be minimal. Moreover, the construction phase, and consequently, impacts from dust are temporary.

Loss of Protected Trees 8.29. Three protected tree species were recorded on the Application Site, namely Olea

europea (Olive), Chamaerops humilis (Dwarf Fan Palm), and Pinus halepensis (Aleppo Pine) (1 specimen). All of these species were planted for landscaping. These trees are protected under LN 12 of 2001; their uprooting requires a permit from MEPA. Loss of these trees from the Site is considered to be of minor significance given that they are few in number on Site and are not part of a natural habitat.

Loss of Agricultural Land: Social Impact 8.30. The Site covers an area of 18,069m2 subdivided into 49 plots, which are worked by

over 14 farmers and their families. These plots range in size from 127m2 to 1,607 m2. While the loss of these plots could have a serious effect on the farmers’ income / livelihood if they are full time farmers, it is understood (from the Applicant) that all of those farmers have agreed to sell their fields to the Applicant (14 farmers covering approximately 85% of the Application Site). On this basis it is assumed that the relinquishment of title was beneficial to the farmers and that the impact is therefore judged to be minor beneficial.

MITIGATION MEASURES 8.31. Loss of the agricultural land cannot be mitigated.

8.32. Although it is likely that dust will be generated during construction, implementation of good construction practice can reduce fugitive dust in accordance with the draft Environmental Management Construction Site Regulations, 2007 including regular spraying with water to limit dust emissions within the Site boundary, and cleaning of the Site and the access road within 10m of the construction site at the end of each working day.

8.33. Transplantation of the protected tree species will be attempted if advised by MEPA, rendering the residual impact insignificant. If the trees cannot be transplanted, the impact cannot be mitigated and, therefore, the residual impact is also minor.

8.34. The soil still existing on the Application Site will be removed from Site when dry in order not to negatively affect its structure. The soil will be stored for use in the Landscaping Scheme.

RESIDUAL IMPACTS 8.35. Loss of agricultural land remains a major significant impact if the Scheme goes ahead.

Following implementation of the above list of mitigation measures, no other significant residual impacts are predicted.


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Table 8.2: Summary of Impacts on Agriculture

Predicted Impact Beneficial/ Adverse Nature, Scale and Type of Impact Policy

Importance


Significance of Impact



Impact Cons/Op Extent of

impact (Nat/Local/Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Reverse/ Irrevers

(Inter/National/Local)

(Likely, Unlikely, Remote)

(Major, Minor, Insignificant)


Loss of agricultural land

Adverse Cons/Op Site Direct L Perm Reverse National Likely Major None Major

Impacts on agricultural productivity in the A of I resulting from dust

Adverse Cons Local Indirect S Temp Reverse National Unlikely Minor Good construction practice

Not significant

Loss of protected trees

Adverse Cons/Op Site Direct L Perm Reverse National Likely Minor Transplantation

Not significant to minor

Social Impact Beneficial Cons/Op Site Direct L Perm Reverse Local Likely Minor None Minor


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9. ECOLOGY

INTRODUCTION 9.1. The ToR call for a description of the ecology of the Application Site and the

ecological Area of Influence (A of I), and an assessment of the impacts and risks posed by the proposed Scheme on the ecological assets therein.

9.2. This chapter considers the likely environmental impacts on the habitats, fauna, and flora as a result of the proposed Scheme. The potential key ecological issues are outlined below:

Key Issues

• Changes to the il-Hofra marshland habitat resulting from changes to the surface water drainage patterns

• Disturbance to habitats and species from increased human activity (including dust emissions, noise, lighting, and other on-site activities)

• Damage to habitats supporting legally protected species

• Escape of species used in landscaping into surrounding habitats

• Loss of protected trees within the Application Site boundary

Terms of Reference 9.3. The ToR require the following:

2.0 A DESCRIPTION OF THE PROPOSED SITE

This description is identified by area of influence for each relevant parameter. The area of influence for each parameter shall be determined by the consultants who shall also justify the extent of the chosen area of influence. This must be approved by the Malta Environment & Planning Authority prior to commencement of the EIA. This description should include:

2.2 Ecology

See Appendix 3

4.0 ASSESSMENT OF ENVIRONMENTAL IMPACTS & RISKS OF THE PROPOSED DEVELOPMENT

All significant impacts of and risks posed by the proposed project, during demolition, construction and operation should be assessed, given the environmental characteristics of the site outlined in Sections 1 and 2 and the policies outlined in Section 3. A descriptive and quantitative analysis


162

(including significance, magnitudes and timing) of the impacts of the proposed development should be made, and presented in summary chart format. The various techniques, methods and assumptions used in the analysis and predictions should be outlined. It is recommended that impact assessment should include:

(xiii) description of impact; (xiv) magnitude and significance; (xv) duration (temporary and permanent); (xvi) extent (in relation to site coverage and surroundings and associated

features); (xvii) whether direct or indirect; (xviii) adverse or beneficial; (xix) reversible or irreversible effects of the impact and extent or irreversibility as

well as description of any associated conditions / assumptions for irreversibility;

(xx) sensitivity of resources to impacts; (xxi) probability of impact occurring; (xxii) confidence levels/limits to impact prediction; (xxiii) scope of mitigation / enhancement; and (xxiv) residual impacts Worse case scenarios should be assessed where relevant.


4.2 Effects on Ecology

The effects of the proposed development on ecology. See Appendix 3.

5.0 DESIGN OF MITIGATION MEASURES, IDENTIFICATION OF RESIDUAL IMPACTS AND MONITORING PROGRAMME


This should include a description of the measures envisaged to prevent, minimise and where possible offset any significant adverse effects on the environment of the project (including reference to consideration of alternatives in section 2 above). Such measures should be realistic and could include technological features; alternative technological features; operational management techniques; enhanced site-planning and management; aesthetic measures; conservation measures; reduction of magnitude of project; and health and safety measures.


Any residual impacts, that is those impacts that cannot be mitigated or those remaining impacts following implementation of mitigation measures, should also be described, quantified and presented in a tabular format.


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5.3 Monitoring Framework and Management Plans


9.4. Technical Appendix 1: Terms of Reference and Method Statements provides the full Terms of Reference.

9.5. A separate Appropriate Assessment in accordance with the requirements of LN 311 of 2006 and the EU Habitats Directive has been prepared for the Scheme. The Appropriate Assessment is presented as a stand alone document, as required by the Term s of Reference. It is advisable that in reviewing the assessment of ecological impacts, reviewers view both this Chapter and the Appropriate Assessment.

Objectives of the Assessment 9.6. The objectives of the Ecological Impact Assessment were to:

• Identify the Ecological A of I of the Scheme;

• Describe the biotic assemblages and communities present within the A of I and evaluate their importance;

• Undertake a baseline ecological survey of the il-Hofra marshland;

• Undertake a tree survey within the Application Site and in the area south of the Application Site bordered on each side by roads;

• Identify, describe and analyse the relevant international / Maltese legislation and protocols, agreements, etc., as well as Government / MEPA policies;

• Identify the threats and opportunities posed by the Scheme in respect of the findings;

• Predict the impacts of the Scheme on the ecological value of the area;

• Assess the significance of the impacts on the ecology of the area; and

• Describe the mitigation measures designed to minimise adverse impacts on ecology and enhance any beneficial impacts on the ecological features of the area.


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Legislation, Policies and Guidance

International legislation

9.7. International legislation relevant to the ecology of the A of I is mainly that protecting specific habitat types / biotopes or individual species. Of particular relevance are:

• The Convention on the Conservation of European Wildlife and Natural Habitats (the Bern Convention);

• The Convention on the Conservation of Migratory Species of Wild Animals (the Bonn Convention);

• The European Union’s Council Directive 79/409/EEC of 2 April 1979 on the conservation of wild birds (the ‘Wild Birds Directive’); and

• The European Union's Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora (the 'Habitats Directive').

Local legislation

9.8. Local legislation relevant to the ecology of the A of I is mainly that protecting individual features, habitats, or species. Of particular relevance are:

• Act XXIX of 1973 (Fertile Soil (Preservation) Act, Cap 236);

• Legal Notice 160 of 1997 (Rubble Walls and Rural Structures (Conservation and Maintenance) Regulations, 199750);

• Legal Notice 12 of 2001 (Trees and Woodland (Protection) Regulations, 2001);

• Legal Notice 79 of 2006 (Conservation of Wild Birds Regulations, 2006); and

• Legal Notice 311 of 2006 (Flora, Fauna and Natural Habitats Protection Regulations, 2006) and its subsidiary Government Notice 112 of 2007.

9.9. The purpose and relevance of the above legislation is addressed in Chapter 6.

Protected areas

9.10. Part of the Application Site is designated as an Area of High Agricultural Value under the North West Local Plan (see Figure 9.1). Il-Hofra saline marshland is scheduled as a Level 1 Area of Ecological Importance (AEI) and includes a Level 3 AEI buffer around it. The marshland is also within the boundary of the Ghadira Area Special Area of Conservation and Special Protection Area (designated under LN 311 of 2006 and GN 112 of 2007). This SAC / SPA includes a number of habitat types such as sclerophyllous scrub (i.e. garrigue and maquis), steppe, sand dunes, and salt marshes.

50 As amended by LN 169 of 2004.


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Planning policies

9.11. The Structure Plan for the Maltese Islands includes a number of policies that deal with ecological / environmental assets and are relevant to the assessment of the ecological impacts of the Scheme. RCO 1 sets out protective designations for areas and sites of ecological and / or scientific value. RCO 3 identifies the Local Plans as the vehicle through which the precise boundaries of the various designated areas will be identified. Policies RCO 10 and RCO 11define the characteristics of Areas of Ecological Importance and Sites of Scientific Importance, respectively. Policy RCO 12 gives the grading criteria for AEIs and SSIs. Policy RCO 13 provides for the protection of wildlife and threatened species in particular. These policies have been used to designate the environs of the Scheme.


9.12. The approved North West Local Plan recognises and assigns importance to the Ghadira Isthmus in terms of its natural and cultural value and identifies the various pressures this area is under as a result of conflicting uses. Policy NWML 18 gives priority to the conservation and management of the natural and cultural environment of the area and seeks to protect it from environmentally unsustainable development. The policy also aims to contribute to actively improving the environmental quality of the area. Figure 9.1 shows the scheduled areas as illustrated in the North West Local Plan.

Guidelines

9.13. The most relevant policy guidance is MEPA’s Guidelines on Trees, Shrubs and Plants for Planting and Landscaping in the Maltese Islands. This document provides detailed guidance on the types of plants that can be used for landscaping purposes in rural, urban, or agricultural situations. The guidance includes methods of planting and lists of species suitable for the different areas.


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Figure 9.1: Scheduled areas as designated in the North West Local Plan

Source: North West Local Plan: MEPA Website


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BASELINE SURVEY METHODOLOGY 9.14. The Method Statement for the ecological impact assessment was discussed with MEPA

during a meeting held on the 4th December 2007.

Data Sources 9.15. A baseline ecological survey of the Application Site and its A of I was carried out by Ms

Krista Falzon and Mr. Edwin Lanfranco. The results of this survey are reported in full in Technical Appendix 4: Ecology Baseline Study. Avifauna data was provided by Mr John J. Borg.

Desk Study Methodology 9.16. The topographic, geographic, geologic, and ecological characteristics of the site were

determined through desk study and field survey. The desk study included:

• Analysis of aerial photographs to determine land use trends;

• Review of land use survey findings (see also Chapter 4);

• Review of existing baseline information from:

o MEPA’s National Protective Inventory and other ecological/habitats data;

o Literature searches (including the ecologists’ own data);

o Previous environmental and planning studies undertaken in the area; and

o Legislation and policy documents.

Field Survey Methodology 9.17. The field survey was carried out between October and December 2007. The findings

were supplemented by material from the literature and the consultants’ previous knowledge of the study area and its environs.

9.18. The survey area included the Application Site and the A of I, the latter being that area that could conceivably be affected by the activities resulting from the Scheme (see Figures 9.2 and 9.3). The land cover of this area was assessed on the basis of topographic features, land-use, and vegetation. Terms such as steppe, garrigue and maquis have been used to indicate grades of ecosystem development rather than specific assemblages.

Habitats

9.19. Habitats were characterised on the basis of geomorphological features and on plant assemblages using the classification proposed by Schembri, 199151 as modified by

51 Schembri, P.J. (1991) Report of survey: natural resources [Malta Structure Plan Technical Report 5.4] Beltissebh,

Malta: Colin Buchanan and Partners/Generale Progetti SpA/Planning Services Division, Government of Malta; viii + 138pp.


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Schembri et al. (1999)52. Habitats and biotic assemblages noted during the field surveys were mapped (see Figures 9.4 and 9.5).

Species

9.20. Dominant species were noted and the majority of the accompanying species were recorded. However, no attempt was made to provide a complete inventory of the flora and fauna present, as this would have entailed extensive fieldwork during different seasons, which is beyond the scope of the EIA. Indicator species and species of ecological and/or conservation importance, especially those listed in the Red Data Book for the Maltese Islands (Schembri & Sultana, 1989)53, were actively searched for during the field surveys.

9.21. Published literature and unpublished data held by the surveying ecologists and other sources (see Technical Appendix 4: Ecology Baseline Study) were also used to describe avian species known to frequent, or previously recorded from, Il-Hofra marshland.

52 Schembri, P.J., Baldacchino, A.E., Camilleri, A., Mallia, A., Rizzo, Y., Schembri, T., Stevens, D.T. & Tanti, C.M.

(1999) State of the environment report for Malta 1998: Living resources, fisheries and agriculture. pp.109-283 In: State of the environment report for Malta 1998. Floriana, Malta: Environment Protection Department, Ministry for the Environment; 448pp.

53 Schembri, P.J. & Sultana, J. [eds] (1989) Red data book for the Maltese Islands. Valletta: Department of Information; viii + 142pp.


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Figure 9.2: Habitats Survey Area of Influence


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Figure 9.3: Tree survey Area of Influence


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ASSESSMENT METHODOLOGY 9.22. Besides the EIA, an Appropriate Assessment (AA) was carried out on the Scheme. An

Appropriate Assessment is required to determine whether the effects of a plan or project will have an impact on an SAC and SPA and whether the impact will be significant. In determining impacts on the SAC and/or SPA, an Appropriate Assessment is restricted to the effects of the plan or project on the conservation objectives of the specific SAC and/or SPA. This is described in further detail in the Appropriate Assessment that accompanies this EIS.

9.23. The EIA ecology assessment is concerned with the assessment of the ecology impacts on the Area of Influence (that is, the impact on the integrity of the ecology within the A of I). The method of assessment and the definition of significance is similar for both the AA and the EIA Assessment. The EIA ecology assessment is described below. The AA is presented as a separate document.

Determining Impact Significance 9.24. The significance of the impacts of the proposed Scheme on the ecology of the A of I

depends fundamentally on the operational management at the Application Site (including the maintenance of mitigation measures. In assessing the significance of the potential negative impacts arising from the Scheme, the following criteria have been used:

• Not significant (e.g. no material change in habitat quality and/or extent);

• Minor significance (e.g. small-scale loss/disturbance of habitat that is unlikely to affect the ecological integrity of the A of I); and

• Major significance (e.g. large-scale loss/disturbance of habitat that is likely to affect the ecological integrity of the A of I).

9.25. The concept of “material change” needs to be viewed in the context of the Application, as described in Chapter 4. For a change to be material, it must affect the ecological integrity of the habitats and the interactions of the species they support more than they would be affected by the continuation of the uses already extant in the area and to which the ecology is accommodated.

9.26. Changes that would qualify as a “material change” would be a reduction in habitat size or other alteration (such as those listed below) that modifies the habitat to such an extent that the integrity of the habitat and / or ecological feature would be affected. Such changes would include fragmentation of habitats, isolation of populations, and chronic effects that may lead to long-term or permanent changes in the physico-chemical characteristics of the habitats and hence of the species they support.


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BASELINE SURVEY RESULTS: A SUMMARY 9.27. The following is a summary of the existing conditions in the A of I. The description of

the existing conditions in the A of I is based on the field survey reported in Technical Appendix 4: Ecology Baseline Study. The habitat types and biotic assemblages recorded in the baseline survey and referred to in this summary are shown on Figures 9.4 and 9.5.

9.28. The Area of Influence includes agricultural land, some natural areas that have been disturbed, including garrigue and steppe, and the Il-Hofra saline marshland. The Il-Hofra saline marshland was the main feature of interest of the ecology survey because of its proximity to the Site and its rarity in terms of habitat type.

9.29. The Il-Hofra marshland was found to be largely disturbed. Material has been dumped within the marshland. Moreover, it was noted that material that was to be used for the construction of greenhouses remains within the marshland after this project was abandoned some 13 years ago. The arterial road embankment, north of the marshland spills into the marshland area and is dominated by Arundo donax. The western edge of the marshland is interrupted abruptly by the Mellieha Holiday Complex boundary wall. A roadway used by farmers to access their fields, located west and south of the marshland, creates an artificial boundary, interrupting the marshland along its southern edge. An extensive proportion of vegetation recorded within the marshland area provides further testament to the disturbed nature of the marshland with only patches of the site being dominated by typical marshland species (see Figure 9.4).

9.30. Despite its disturbed nature, the marshland is still utilised by a number of bird species, particularly migrants, although generally in small numbers, reflecting the small size of the marshland.

9.31. A tree survey was also carried out within the A of I indicated in Figure 9.3.

9.32. Garrigue and steppe areas recorded within the A of I are largely disturbed as shown in Technical Appendix 4: Ecology Baseline Study.


173

Figure 9.4: Il-Hofra saline marshland


174

Figure 9.5: Habitats within A of I


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HABITATS WITHIN THE A OF I 9.33. This section describes the vegetation assemblages recorded within 200m of

the Application Site. As agreed with MEPA, a detailed survey was carried out at Il-Hofra Saline Marshland. A more general survey was then carried out to confirm data gathered during the desk study.

Il-Hofra Saline Marshland: Vegetation Assemblages 9.34. Figure 9.4 illustrates the vegetation assemblages recorded at the marshland.

9.35. The Il-Hofra saline marshland is relatively degraded. The Site is bordered to the south by a road used mainly by farmers to access fields located west of the marshland; however, in summer it is regularly used by bathers for parking purposes, which parking often also spills into the marshland itself. Species recorded along the road include Arundo donax (Giant Reed) and Vitis vinifera (Grape Vine) (along field boundaries), Aster squamatus (Narrow-leaved Aster), Diplotaxis tenuifolia (Perennial Wall-rocket), Salsola kali (Prickly Saltwort), Salsola soda (Smooth-leaved Saltwort), Bromus diandrus (Great Brome), Sonchus oleraceus (Smooth Sow-thistle), Oxalis pes-caprae (Cape Sorrel), Malva sp. (Mallow), Convolvulus arvensis (Field Bindweed), Galium aparine (Cleavers), and Euphorbia pinea (Pine Spurge) (along boundary with the saline marshland). Melilotus messanensis (Sicilian Melilot), a species typical of saline marshlands, was recorded in the centre of the access road as well as in the marshland proper.

9.36. The marshland is triangular in shape. The southeastern corner is dominated by the opportunistic species Diplotaxis erucoides (White Wall Rocket). A follow-up visit revealed that the Diplotaxis erucoides had been removed, suggesting that the area was being prepared for cultivation. A barren patch of soil separates the southeastern corner from the wider marshland area.

9.37. Adjacent to this area, the central marshland area is characterised by typical marshland species, namely Juncus subulatus (Somerset Rush), Juncus acutus (Sharp-pointed Rush), and Phragmites australis (Common Reed). These species grow around a depression where water collects. Dried Salicornia ramosissima (Twiggy Glasswort) and Suaeda maritima (Herbaceous Seepweed) were recorded growing in the depression. The marshland area (dominated by Juncus subulatus) creates a boundary around a central area that includes Tamarix sp. (Tamarisk) trees and a more disturbed area dominated by Dittrichia viscosa (Sticky Fleabane) and Foeniculum vulgare (Fennel). Single specimens of Urginea pancration (Sea Squill) and Anthyllis hermanniae (Shrubby Kidney Vetch) were recorded in this area. A number of species typical of coastal, salty habitats were recorded including Aetheorhiza bulbosa (Bulbous Hawksbeard), Lotus cytisoides (Grey Birdsfoot Trefoil), Atriplex prostata (Halberd-leaved Orache), and Parapholis filiformis (Slender Sea Hard Grass). Evidence of disturbance to the site included dumped material and the presence of species such as Cynodon dactylon (Bermuda Grass), Oxalis pes-


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caprae, Dittrichia viscosa, Galium murale (Yellow Bedstraw), Lagurus ovatus (Hare’s tail Grass), and Foeniculum vulgare. Inula crithmoides (Golden Samphire) and Beta maritima (Sea Beet) also grow within the marshland.

9.38. The marshland is further disturbed as a result of its interruption by the arterial road running along its northern boundary. The northern edge of the Site includes mounds of material, presumably resulting from the construction of the road embankment. This area is dominated by Arundo donax. A number of Acacia saligna (Blue-leaved Acacia) trees grow closer to the western boundary of the marshland (close to the Mellieha Holiday Complex boundary wall).

9.39. The westernmost area of the marshland (boundary with the Mellieha Holiday Complex) includes species typical of degraded habitats and segetal species including Euphorbia pinea, Foeniculum vulgare, Diplotaxis tenuifolia, Conyza bonariensis (South American Fleabane), Mercurialis annua (Annual Mercury), Antirrhinum siculum (Sicilian Snapdragon), Erodium moschatum (Musk Storksbill), Chrysanthemum coronarium (Crown Daisy) and Acacia saligna (northwest). A single Phoenix canariensis (Canary Date Palm) was also noted amongst the Tamarix africana. Specimens of the alien Chasmanthe bicolor (Chasmanthe) were also recorded.

9.40. Table 9.1 lists the species of conservation significance recorded on site.

Table 9.1: Species of conservation significance

Species Vernacular name

LN 311/2006

Trees & Woodlands

RDB status

Acacia saligna Blue-Leaved Acacia

Schedule V

Tamarix sp. Tamarisk Schedule I Juncus acutus Sharp-pointed

Rush Schedule III

Il-Hofra Saline Marshland: Avifauna 9.41. Despite the degraded nature of the marshland, the area still attracts a variety

of avian species.

Resident species

9.42. Past bird watching records provided by Mr John J. Borg indicate that the marshland supports three species of breeding birds, namely the Sardinian Warbler, Sylvia melanocephala, 1-2 pairs, Zitting Cisticola, Cisticola juncidis, 1male/2-3 females, and Spanish Sparrows, Passer hispaniolensis.

9.43. The Corn Bunting, Emberiza calandra, also used to breed in the area in previous years.


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Migrants

9.44. The marshland vegetation provides shelter for a variety of migrants, albeit in small numbers considering the limited area. Waders such as Dunlin, Calidris alpina, and Little Stints, Calidris minuta, are the most regular. Little Ringed Plovers, Charadrius dubius, which breeds in the nearby nature reserve is also known to visit this small pond. Little Bitterns, Ixobrychus minutus (listed in Schedule I and VII of LN 79 of 2006), and Squacco Heron, Ardeola ralloides (listed in Schedule I and VII of LN 79 of 2006), have been recorded on various occasions in recent years. Unlike their larger cousins these small herons prefer to skulk in thick vegetation rather than linger in the open.

9.45. Passerines, such as chats and warblers are also regular visitors during migration. The Whinchat, Saxicola rubetra, Sedge Warbler, Acrocephalus schoenobaenus, Common Whitethroat, Sylvia communis, Wood Warbler Phylloscopus sibilatrix, and Willow warbler, Phylloscopus trochilus are regular visitors to the area.

Winter visitors

9.46. The most frequent winter visitors to the area are Robins, Erithacus rubecula, and Common Chiffchaffs, Phylloscopus collybita. The shy Water Rail, Rallus aquaticus (listed in Schedule II of LN 79 of 2006), frequents the thick vegetation. Little Grebes, Tachybaptus ruficollis, may visit the pond when water level is high.

Other Habitats within the Area of Influence 9.47. The field survey included a walkover survey of the habitats located with 200m

of the Application Site. Mostly agricultural land is located within this area. A patch of garrigue, linked to a larger area, is also located within 200m of the Site. This garrigue is proposed for protection as a Level 4 AEI under Structure Plan Policy RCO 12.

9.48. Figure 9.5 illustrates the habitats map following the walkover field survey. During the field survey, it was noted that part of the area of garrigue, located to the southwest of the Application Site, has been impacted by dumping, and fly tipping. The remainder of this area is best described as degraded steppe dominated by Foeniculum vulgare and Oxalis pes-caprae.

9.49. Garrigue is located at the Qasam Barrani area, a small section of which lies within 200m of the Site. Closer to the road the garrigue shows signs of disturbance. This garrigue area is dominated by a number of species including Anthyllis hermanniae, Thymbra capitata (Mediterranean Thyme), Erica multiflora (Mediterranean Heath), Urginea pancration, Teucrium fruticans (Olive-leaved Germander), and Oxalis pes-caprae (particularly in the area close to the road).


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Agricultural Land: Tree Survey 9.50. A tree survey was carried out both as part of the ecology study as well as in

the agriculture study. The trees recorded mostly grow along field boundaries. Some species are planted in front of the farmhouse and a number of other species were planted as part of the landscaped area beside the hotel and along the route to the farmhouse.

9.51. A full list of tree species present on site is provided in Chapter 8. Protected trees recorded within the Application Site are listed in Table 9.2. It must be noted that, apart from the Carobs, none of these protected trees form part of a natural habitat and most are the result of plantations or former landscaping schemes.


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Table 9.2: Protected trees recorded on site Species English Common

Name Maltese Common Name

L.N. 12 of 2001 Red Data Book status

Olea europaea Olive Zebbuga Schedule II (Protected Trees) Rest (MI) (?)

Pinus halepensis Aleppo Pine Znuber Schedule 1 (Strictly Protected Trees)

Chamaerops humilis Dwarf Palm Gummar Safrani Schedule I (Strictly Protected Trees) X(?), Rest (MED)

Ceratonia siliqua Carob Sigra tal-Harrub Schedule II (Protected Trees)

Punica granatum Pomegranate Rummien Schedule II (Protected Trees)

Pistacia lentiscus Lentisk Deru Schedule 1 (Strictly Protected Trees)


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IMPACT ASSESSMENT

Potential Impacts 9.52. The categories of impacts that may be experienced as a result of the activities

undertaken on the Application Site (as described in Chapter 4) include:

• Habitat Loss:

o Direct habitat and associated wildlife loss as a result of site clearance and demolition;

• Disturbance and/or damage to habitats and/or wildlife within and near the Application Site:

o Effects of dust deposition, noise, and light pollution;

o Effects from trampling (including soil compaction and damage to vegetation) by heavy machinery;

o Accidental damage to habitats outside the Application Site curtilage by moving machinery; and

o Changes in water / moisture availability at Il-Hofra marshland as a result of changes in the hydrology of the A of I; and

• Invasion of alien species used for landscaping into natural habitats (or native species planted in inappropriate locations that may out-compete the local species).

9.53. The impacts that will affect the A of I as a result of the operation of the Scheme will depend on the treatment of hard and soft surfaces, runoff management, landscaping and maintenance, and the effectiveness of the mitigation measures put in place.

9.54. The following sections provide a more detailed assessment of these impacts as they relate to the various Scheme phases.

Prediction and Significance of Impacts

Construction of the Scheme

Direct habitat loss/protected species during site clearance

9.55. The Application Site consists of agricultural land. In terms of important species/habitats loss protected trees and rubble walls are the main features of interest. The baseline survey shows that a relatively small number of protected tree species were recorded within the tree survey A of I (see Figure 9.3).

9.56. In the ecological context, the loss of agricultural land located within the proposed Application Site is of minor significance since agricultural land is in itself considered to be a disturbed habitat and because the area does not support a large number of ecologically important floral species; additionally, the area lies outside scheduled areas and the SAC.


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The removal of rubble walls will most likely affect species associated with such structures and which may include protected species such as lizards, geckoes, and snakes. However, since the walls will be dismantled and the stones re-used for the construction of new rubble walls, the impact of such habitat loss is considered to be of minor significance, also since the protected fauna most likely associated with these structures is very mobile and would in all probability migrate to adjacent fields54.

9.57. Soil removed from the Application Site will be re-utilised in the landscaping scheme on site. Surplus soil will be used as directed by the Department of Agriculture.

9.58. The Scheme now includes minor widening of the existing rural road at the western boundary of the existing hotel to allow access into the proposed underground garage55. This intervention falls just inside the eastern boundary of the Level 3 buffer zone to Il-Hofra marshland. While this option eliminates construction impacts from the agricultural fields to the south of the site, it brings construction works closer to Il-Hofra marshland. The main risk to the marshland is encroachment onto and damage to the area from construction vehicles; this road is located around 50m from the eastern extremity of Il-Hofra, whose eastern boundary is circumscribed by another rural road. that must remain accessible to farmers. It is therefore unlikely that construction vehicles would encroach onto this area. Nonetheless, given the small size of Il-Hofra, further habitat loss as a result of damage by construction or other vehicles could result in a minor to major negative impact on the marshland, depending on the extent of the impact. Hence, it is important that access along this rural road is controlled or access to the marshland by vehicles prohibited through appropriate vehicle control measures. This is an urgent issue since even now the area is often used for car parking purposes and the possibility of vehicles accessing the marshland area is not remote.

Disturbance and/or damage to habitats and wildlife

9.59. The impacts of construction on the ecology within the A of I would be:

• Particulate deposition (especially during the dry season);

• Noise and vibration disturbance;

• Light pollution;

• Changes to the hydraulic regime; and

• Accidental damage to habitats supporting legally protected species.

Particulate deposition 9.60. The construction phase has potential to entrain dust. Impacts of dust deposition on

flora generally include: 54 It is noted that the classification of farmland as being of High Nature Value (HNV) is not yet available and

therefore the assessment does not refer to this designation. 55 This new access keeps the intervention on road access and service entries close to the footprint of the hotel

and minimises further land take of agricultural land.


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• Blockage of and / or damage to stomata;

• Interference with photosynthesis due to shading effects; and

• Abrasion of leaf surfaces.

9.61. The areas that would be affected by dust are those predominantly downwind of the Application Site during the prevailing wind i.e., southeast of the Application Site. This area includes degraded steppe and agricultural land. Moreover, most of this area is over 200m away from the Application Site and is separated from the Application Site by an arterial road.

9.62. All of the excavation and construction works are planned to be carried out in the wet season. This has the advantage that rain will suppress the entrainment of dust as evidenced at other construction sites. In view of the fact that dust arising from globigerina limestone has been shown to return to the ground within 100 metres56 of its release, only the closest areas will be impacted. Dust arising from globigerina limestone has been shown to return to the ground within 100 metres57 of its release. Although the rock on the Application Site is Coralline Limestone (hardstone) since there will be no crushing on the site, it is expected that dust particles will be similar or larger than that observed for Globigerina. Given that the construction phase is temporary, and in view of the degraded nature of the steppe located southeast of the Application Site, it is unlikely that the dust generated in this period will produce a material change in the habitats present. The impact on the A of I is not likely to affect its integrity and is therefore judged to be not significant.

9.63. In the event that the wind blows from a southeasterly direction towards the northwest of the site, dust may settle within the Il-Hofra saline marshland. Figure 9.6 shows a normalised wind rose of the Maltese Islands. Given that these winds are not prevailing, that the southeastern boundary of the site is largely sheltered by the Mellieha ridge, and given the temporary nature of the excavation phase (2 months), the likelihood of dust being entrained from the site and reaching Il-Hofra saline marshland in such quantities as to create a negative impact are considered remote. Hence, the impact of dust emissions on the surrounding ecology is considered not to be significant.

56 This has been demonstrated by monitoring emissions in a softstone quarry area in Environmental Planning

Statement: PA 5616/01 To sanction a softstone crusher and a concrete block making machine at Triq il-Belt Valletta, Mqabba, Planning Services Consultancy, 2003.

57 This has been demonstrated by monitoring emissions in a softstone quarry area in Environmental Planning Statement: PA 5616/01 To sanction a softstone crusher and a concrete block making machine at Triq il-Belt Valletta, Mqabba, Planning Services Consultancy, 2003.


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Figure 9.6: Wind rose for Malta

Noise and vibration disturbance 9.64. The impact of noise and vibrations on the ecology of the A of I depends on the existing

(background) noise levels and weather conditions, the type, number, and condition of machinery used on site, the time of the operations, and the distance between the site and the sensitive receptors.

9.65. The potential effects of noise (here taken to include sub-sonic vibrations) on the ecology of the A of I would be to disturb animals that can be so affected, particularly by sudden noises. Of particular sensitivity are the birds breeding and visiting the Il-Hofra saline marshland. The level of reaction varies from species to species, although many species are able to “learn” to ignore a regular noise source (MPG 1158), others have difficulty. For example, some birds may be easily disturbed while nesting. Given that most of the birds recorded from Il-Hofra are visitors, they are not acclimatised to the marshland in terms of the amount of noise that the site is currently exposed to (e.g. by passing traffic, etc) and therefore the additional noise that may be generated during the construction phase of the Scheme will add to the existing noise regime and will not in itself create a different noise climate that could affect these migrants more than noise from existing uses and activities. Noise can also interfere with communication, masking sounds of predators and prey, cause “stress” or avoidance reactions, and hearing damage.

9.66. Very little is known on the impact of noise on small animals, especially reptiles and invertebrates, such as those encountered or likely to be present within the A of I. While for some animals noise may not be a problem, it may significantly disturb others.

58 MPG 11 – Control of Noise at Surface Mineral Workings, UK


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9.67. Chapter 13 assesses the impact of noise and identifies a change in background levels (defined as LAeq 60) during excavation that will result in a major impact in the Il-Hofra area. Operational noise is of no significance. Although it is anticipated that the impact is likely to cause some disturbance that may even result in birds avoiding the marshland during the excavation phase, the limited use of the marshland by birds and the fact that a much larger and more frequented wetland is available a few hundred metres to the north of the site, together with the fact that excavation is planned to be undertaken outside the nesting / migration periods, serve to mitigate the potential impacts.

Changes to the hydraulic regime at Il-Hofra saline marshland 9.68. The hydraulic regime of the Application Site is described in Chapter 7. Run-off from

Wied Ingraw passes through the Application Site before reaching Il-Hofra marshland. Technical Appendix 2: Geo-Environmental Baseline describes the marshland as a geomorphological feature that is maintained by seasonal fluctuations in precipitation, run-off, evaporation, and groundwater seepage. It also states that the marshland depends significantly on groundwater from the Mellieha coastal aquifer. Figure 1 of Technical Appendix 2: Geo-Environmental Baseline indicates that besides receiving run-off from the Application Site, run-off from Wied il-Hanzira, Wied il-Halqun, and Wied ta’Randa travels through Il-Hofra marshland. Run-off from the Il-Bisqra area also reaches the marshland. Following construction of the Scheme, it is assumed that the Il-Hofra marshland will no longer receive run-off from Wied Ingraw59. As described, however, this is not the only water source feeding the marshland; in fact, the main source of water is the mean sea level aquifer and the main surface water flows into the marsh are from the valley and the rural road, both of which will not be affected by the Scheme. The impact on the marshland from the Scheme is therefore considered to be of minor significance.

Accidental damage from machinery 9.69. As described above the site will be enclosed by a fence so that passers-by will be

protected from any dangerous structures and moving machinery. The fence also ensures that the machinery operates within the confines of the Application Site and no habitats will be disturbed outside this area. Therefore the impact is expected to be not significant because it will not affect the integrity of the A of I. The fence along the western boundary of the site (i.e. along the rural road) will also include a 3 course wall that will stop any water flowing along the road towards the marsh from entering the Site. In this way, the water flow into the marsh will also not be affected.

Operation of the Scheme

9.70. The impacts of the operation of the Scheme on the ecology of the area are likely to be:

59 This issue is however debatable in the sense that the current flow of water from Wied Ingraw onto Ic-Cens seems to have been diverted into a roadside culvert (also often called “the watercourse” by locals) that diverts the flow of rainwater along the side of the Application Site, through a culvert under the road and eventually discharges into the sea.


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• Habitat loss / disturbance through trampling as a result of increased numbers of visitors in the area (indirect impact);

• Habitat disturbance from noise and light; and

• Escape of species used in landscaping into surrounding habitats.

Habitat Loss / disturbance through trampling

9.71. The Scheme is likely to attract more visitors to the Application Site than is the case currently. This could have an indirect effect on the SAC if more people visit the area.

9.72. Currently, there is no management plan for the SAC. During the drawing up of this plan, impacts on the SACs, zoning for potential users, etc will be taken into consideration and appropriate measures introduced to reduce any potential impacts to the SAC. In the meantime, there is no access to Il-Hofra marshland from the Scheme and no access will be created. As a result, the impact of habitat loss / disturbance as a result of the Scheme is considered to be minor if public access is not encouraged. Once a management plan has been drawn up, reference will be made to any relevant measures listed in the plan.

Noise Impacts

9.73. The impact of operational noise has been discussed in Chapter 13. In the absence of knowledge on how noise affects species, an impact could range from insignificant to major depending on the species, predicted noise levels, existing noise levels, mitigation measures, distance from the noise source, and natural attenuation. Chapter 13 predicts that operational noise will be insignificant and therefore any resulting impacts are also considered to be insignificant.

Light Impacts

9.74. Light pollution from the Scheme may disturb species frequenting the saline marshland. However, in practice the Mellieha Holiday Complex buildings and the Il-Bisqra horst act as a barrier, screening the SAC and SPA behind it. Some of the light emitted from the extension will be masked from the Il-Hofra marshland by the existing hotel. Lighting in the landscaped areas and from the lower levels of the hotel will also be shielded by the landscaping itself. The use of low intensity lighting and the incorporation of anti-light pollution devices and measures in the proposed lighting plan will go a long way to mitigate light effects on the Il-Hofra marshland as a result of the additional lighting from the Scheme. The Il-Hofra marshland is already subjected to light from the existing hotel, the adjacent Mellieha Holiday Complex and street lighting. Taking into consideration the cumulative impact, with the mitigation measures in place, it is not anticipated that the existing lighting will be significantly increased and therefore the impact from light pollution from the Scheme is considered to be of minor significance. Mitigation measures should still be put in place to ensure, as much as possible that the additional lighting effects from the Scheme on the marshland are kept to an absolute minimum. It


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is also noted that the external light fixtures on the balconies of the existing hotel will be changed (downward facing, lower intensity and energy saving) to reduce light pollution.

Species invasion

9.75. Natural habitats located in the surrounding area of the Application Site may be vulnerable to the escape of species planted as part of the Scheme. Threat of invasion from alien species is listed in the Natura 2000 data form as an important threat to the nearby SAC. Indeed, evidence of this happening in the past was recorded, particularly within the Il-Hofra saline marshland where Arundo donax and Acacia saligna now grow, probably after escaping from the planted area around the Ghadira Nature Reserve. Without appropriate mitigation, invasion by alien species could result in an impact of major significance. To this effect, it is crucial that the Scheme’s landscaping follows religiously MEPA’s planting guidance, especially within the landscaped grounds and no potentially invasive species (whether alien species or native species that may out-compete the existing marshland species) should be used.

Restoration of the marshland 9.76. Although outside the Scheme site, the importance of the Il-Hofra marshland is evident.

The Scheme itself is not expected to significantly affect the integrity if this habitat and various precautionary and mitigation measures are proposed to ensure that any effects on this fragile habitat be contained. However, there is scope to intervene to restore this marshland and its surrounding habitats, possibly including an extension of the marsh. Any such interventions should follow detailed and scientifically supported restoration plans.

MITIGATION 9.77. The following mitigation measures are proposed during the construction phase:

• Good site working methods would be employed during the entire operation (from site preparation through to operation), in order to minimise dust emissions and noise pollution. Chapter 12 describes the dust mitigation measures that will be adopted in accordance with the Environmental Management Construction Site Regulations, 2007;

• During construction of the access road to the garage, construction vehicles should not approach Il-Hofra marshland and at no time should the access road to the fields that borders the marshland be used by construction vehicles;

• During site clearance, waste material will be removed immediately and no stockpiles should be kept on the Application Site except where necessary; in the latter case they should be covered;

• All trucks leaving the Application Site should be adequately covered;


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• The entire Application Site should be fenced off and a 3-coarse wall erected along the western boundary of the Site along the rural road to channel water towards the marshland;

• Construction and operational noise mitigation measures described in Chapter 13 should be implemented; and

• A management plan for the SAC/SPA

9.78. The following mitigation measures are proposed during the operational phase:

• Active promotion by the hotel informing visitors of the importance of the surrounding habitats and discouraging trampling by encouraging the use of existing pathways. Where these do not exist, visitors should be requested to avoid sensitive areas;

• A sensitive lighting scheme with downward-facing lights to reduce the escape of fugitive light should be designed and implemented;

• No lighting should be included in the northwestern corner of the landscaped grounds closest to the marshland;

• Implementation of operational noise mitigation described in Chapters 4 and 13 should be implemented;

• The landscaping scheme should be in accordance with MEPA’s Guidelines on Trees, Shrubs and Plants for Planting and Landscaping in the Maltese Islands whilst specifically taking into consideration the nearby habitats (particularly Il-Hofra saline marshland).

9.79. Enhancement measures can also be introduced through the ecological restoration of the Il-Hofra saline marshland. The Scheme may seek to support the ecological restoration of the saline marshland thus increasing its ecological value.


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Table 9.3: Summary of Ecological Impacts

Predicted Impact


Importance

Probability of impact

occurring


significant)


Significance of Residual Impact

Extent of impact

(Nat/Local/Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers./ Irrevers.

(Inter/National/ Local)


Uncertain)

Legislation

In context of Scheme (Major, Minor,

Insignificant)

Loss of habitat Adverse Local Direct L term Perm Irrevers. Local Likely EPA, LN 311/2006, GN 112/2007

Minor to major

Carefully dismantle rubble walls and minimise impact on trees. New landscaping and rubble walls will provide alternative habitats. Construction vehicles must not use the rural road that borders Il-Hofra.

Minor

Disturbance to wildlife from dust

Adverse Local Indirect S term Temp Revers. Local Likely EPA, LN 311/2006, GN 112/2007

Not significant

Covered trucks; site fenced off; boundary at west end of the Site.

Not significant


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Disturbance to wildlife from noise & vibration

Adverse Local Indirect S term Temp Revers. Local Likely EPA, LN 311/2006, GN 112/2007

Insignificant to Major

Refer to Chapter 13. During construction, impact likely to be major. During operation, impact likely to be minor to insignificant

Minor

Disturbance to wildlife from light pollution

Adverse Local Indirect L term Perm Revers. Local Likely EPA, LN 311/2006, GN 112/2007

Minor Sensitive lighting scheme

Minor to insignificant

Disturbance to wildlife from changes to hydraulic regime

Adverse Local Indirect L term Temp Revers. Local Unlikely EPA, LN 311/2006, GN 112/2007

Minor Monitor changes in marshland hydrology

Minor

Predicted Impact


Importance


occurring


significant)



Extent of impact

(Nat/Local/Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers./ Irrevers.



Uncertain)

Legislation


Insignificant)


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Disturbance to wildlife from trampling

Adverse Local Direct S term Temp Revers. Local Unlikely EPA, LN 311/2006, GN 112/2007

Minor No facilitation of public access to the Site; reference to the Management Plan (where and if relevant) once this is drawn up

Not significant

Degradation to natural habitats from the introduction of alien or atypical species

Adverse Local Indirect L term Perm Irrevers International Unlikely EPA, LN 311/2006, GN 112/2007

Major Landscaping in accordance with MEPA guidelines

Minor – not significant

Predicted Impact


Importance


occurring


significant)



Extent of impact

(Nat/Local/Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers./ Irrevers.



Uncertain)

Legislation


Insignificant)


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10. CULTURAL HERITAGE

INTRODUCTION 10.1. This chapter addresses the potential impacts of the Scheme on the cultural heritage

features within the Application Site and its environs. It describes the existing man-made heritage and assesses how it might change through the development of the Scheme.

10.2. The potential key cultural heritage issues arising from the implementation of the Scheme are:

Key Issues

• Loss or damage to features of cultural heritage significance

• Alteration or degradation of the quality of the setting of the features as a result of the development

Terms of Reference 10.3. The assessment of cultural heritage features on and in the vicinity of the Application

Site and the potential impacts of the Scheme on them have been undertaken in accordance with the ToR and the Cultural Heritage Assessment Method Statement prepared by Adi Associates and accepted by MEPA. (See Technical Appendix 1: Terms of Reference and Method Statements). The relevant ToR are:

2.0 DESCRIPTION OF THE SITE AND ITS SURROUNDINGS


2.6 Archaeological Sites and Historical/Cultural features

Architectural and historical heritage, and other cultural assets, such as elements of vernacular or rural architecture (e.g. rubble walls, huts, wells, irrigation channels, farmhouses etc.) making reference also to scheduled property. Refer to Appendix 2 for more detailed Terms of Reference.

4.0 ASSESSMENT OF THE ENVIRONMENTAL IMPACTS AND RISKS OF THE PROPOSED DEVELOPMENT


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All significant impacts of and risks posed by the proposed project, during construction and operation, should be assessed, given the environmental characteristics of the site outlined in Sections 1 and 2 and the policies outlined in Section 3. A descriptive and quantitative analysis (including significance, magnitudes and timing) of the impacts of the proposed development should be made, and presented in summary chart format. The various techniques, methods, and assumptions used in the analysis and predictions should be outlined. It is recommended that impact assessment should include:

i. description of impact; ii. magnitude and significance; iii. duration (temporary and permanent); iv. extent (in relation to site coverage and surroundings and associated

features); v. whether direct or indirect; vi. adverse or beneficial; vii. reversible or irreversible effects of the impact and extent of

irreversibility as well as a description of any associated conditions / assumptions for irreversibility;

viii. sensitivity of resources to impacts; ix. probability of impact occurring; x. confidence levels/limits to impact prediction; xi. scope of mitigation / enhancement; and xii. residual impacts


The impacts may include:

4.6 Effects on Architectural, Archaeological and Other Human Artefacts of Historical and/or Cultural Value, and/or Scheduled Property

Impacts of the proposal on the cultural heritage features of the area including preservation within the proper landscape context. Refer to Appendix 2 for detailed Terms of Reference.



This should include a description of the measures envisaged to prevent, minimise and where possible offset any significant adverse effects on the environment of the project during both construction and operational phases (including reference to consideration of alternatives in section 2 above). Such measures could include technological features; alternative technological


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features; operational management techniques; enhanced site-planning and management; aesthetic measures; conservation measures; reduction of magnitude of project; and health and safety measures.



6.3 Monitoring


10.4. Technical Appendix 1: Terms of Reference and Method Statements provides the full Terms of Reference.


Area of Influence 10.5. The Cultural Heritage Baseline Study considers the area to be developed and an Area

of Influence as shown in Figure 10.1. This A of I surrounds the Application Site. To the North of the Application Site is the principal main road leading to Cirkewwa and Ghadira Bay. The site is surrounded from the south and east by the Dawret il-Mellieha bypass. The outskirts of Mellieha village are located to the east. Agricultural


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land is located to the south and west. The Area of Influence extends to paths, roads or boundary walls surrounding the site of the proposed development60.

10.6. The Area of Influence for the study on the Cultural Landscape61 was extended to include the whole of the Ghadira area between the Mellieha Ridge and the Marfa Ridge.

60 During a meeting with MEPA (Sylvio Farrugia, Josianne Abela Vassallo, Lawrence Vassallo and Kevin Borda)

held on 4th August 2008 with the EIA Consultants Rachel Xuereb and Krista Farrugia) and the Applicant (Silvio Debono), the A of I as proposed in the EIS was discussed. The Consultants pointed out that the A of I was sufficient for the assessment especially considering that the building was to the east of the Site and not to the west, the area MEPA indicated as being sensitive and potentially requiring further study. It was agreed that the A of I would remain the same and that in the second draft of the EIS, clear mitigation measures to reduce the possibility of overspill during construction, particularly to the west of the Site will be discussed. Such measures include no access through the path, and protective fencing. It was also agreed that MEPA would be provided with the landscaping scheme, especially in view of the proximity of landscaping to the area (west) indicated by MEPA as being of concern from a cultural heritage point of view.

61 The Cultural Landscape Study includes both a desk study and field reconnaissance.


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Figure 10.1: Area of Influence for cultural heritage survey


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OBJECTIVES OF THE STUDY 10.7. The objectives of the Study were to:

• Identify, document, and present the relevant facts about archaeological and cultural heritage features in the A of I;

• Assess the cultural heritage significance of the Site and its environs;

• Describe and assess the impact of the Scheme on the recorded cultural heritage; and

• Propose mitigation of impacts arising from the proposed development and a monitoring programme during construction and operation of the development.

Survey Methodology

Literature Search

10.8. Based on literature searches and the consultants’ knowledge of the area, a summary of previous survey work undertaken within the study area is provided as context to the results of the current survey work. This phase also included research comprising:

• Study of toponomy (place names);

• Analysis of cartographic and photographic material;

• Conservation legislation (including proposed legislation); and

• Published printed matter (including archival research) relating to the area.

Mapping

10.9. The archaeological, rural, vernacular, historical, and cultural heritage features visible within the Application Site and the A of I were mapped during field surveys based on Ground Reconnaissance. This method of investigation primarily involves fieldwork, and incorporates the consultation of documentary sources and place-name evidence [Renfrew & Bahn 1991: 63, see Technical Appendix 5: Archaeology and Cultural Heritage Baseline Survey]. The fieldwork consisted of a site-surface survey, or field-walking, in order to locate and record the whereabouts of sites and features. No aerial reconnaissance or sub-surface surveys, including excavations, were carried out.

10.10. The fieldwork was carried out on 24th November 2007.

Cataloguing

10.11. Relevant information for each feature is presented on cards and digital media in the same format as currently used and requested by MEPA. Each feature was individually


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identified with a consecutive numbered reference. The information for each feature includes:

• A short written description of the feature;

• Co-ordinates recorded up to 5 digits for each Eastings and Northings based on the local UTM grid reference;

• Locality and address;

• Site indicated on a map to a scale of 1:2500;

• Colour photograph(s);

• Wherever possible a sketch of the feature showing the most significant details;

• The conservation importance of site or feature (proposed grading following Structure Plan UCO and ARC policies);

• Existing and / or proposed legislative and physical protection;

• Current and proposed use / enhancement;

• References; and

• Name of surveyors and date of compilation.

Evaluation 10.12. An archaeological assessment and significance of the archaeological, rural, vernacular,

historical, and cultural heritage features were derived from the desk-top and field studies. Relevant legislation, standards, guidance, and practices were used to derive the conservation importance of the identified sites and features as described below.

Consultations

10.13. Where necessary, consultations were held with Adi Associates and members of the Study Team. Consultations were also held with other technical personnel, and with persons who have known the area for a long time who were encountered during the field survey.

Standards and Guidance

10.14. Planning guidance on the protection of cultural heritage was derived from the Cultural Heritage Act, 2002, Government Notice 160 of 1997 (Rubble Walls Regulations), the Development Planning Act 1992, the Structure Plan for the Maltese Islands, the North West Local Plan, and proposed legislation that has been published by Government


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Cultural Heritage Act

10.15. This Act provides overall protection to all movable or immovable objects of artistic, architectural, historical, archaeological, ethnographic, palaeontological, and geological importance and includes information or data relative to cultural heritage pertaining to Malta or to any other country (section 2). It also includes archaeological, palaeontological, or geological sites and deposits, landscapes, groups of buildings…which have an historical value. In section 3 it also specifies that For the purposes of this Act, an object shall not be deemed to form part of the cultural heritage unless it has existed in Malta, including the territorial waters thereof, or in any other country, for fifty years, or unless it is an object of cultural, artistic, historical, ethnographic, scientific or industrial value, even if contemporary, that is worth preserving.

10.16. No person shall make any interventions on such cultural property or classes thereof without first having obtained a permit thereof from the Superintendent (Section 44.3). Applications are determined subject to the results of prior investigation: Before determining an application under subarticle (3) hereof the Superintendent may require such information including the results of such tests, examinations or inspection by such persons accredited under this Act for the purpose as may be required by the Superintendent (Section 44.4).

10.17. The restrictions on archaeological excavations is stated in Section 43(1) whereby Archaeological or palaeontological excavations or explorations on land as well as in the territorial waters or in the contiguous zone of Malta can only be made by the Superintendent, or with written permission of the Superintendent. Chance discoveries of archaeological remains are also regulated by Section 43(2), Any person who, even accidentally, discovers any object, site or building to which this Act applies in accordance with article 3, shall immediately inform the Superintendent, keep the object found in situ, and shall not for a period of six working days after informing the Superintendent proceed with any work on the site where the object of cultural property is discovered. The details about rights and obligations by all parties in the eventuality of an archaeological discovery are described in Sections 43(3), 43(4), 43(5), 43(6), 43(7).

Legal Notice 160 of 1997

10.18. Rubble Walls and Rural Structures (Conservation and Maintenance) Regulations as amended by LN 169 of 2004 protects all rubble walls and non-habitable rural structures in view of their historical and architectural importance, their exceptional beauty, their affording a habitat for flora and fauna, and their vital importance in the conservation of the soil and water. Walls may be sensitively repaired without MEPA’s prior authorisation. Certain areas may also be declared to be Rubble Wall Conservation Areas in which no alterations to the location or construction of rubble walls and the traditional methods of their repair and maintenance will be permitted without the written approval of MEPA. In such Conservation Areas, the Minister for the Environment may order the owner or occupier to repair and re-erect all the rubble walls within the area, and to continue to maintain them. The dismantling of the wall requires a permit from MEPA.


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Planning Policy

10.19. Planning policy relevant to the Application Site is contained in the Structure Plan for the Maltese Islands and the approved North West Local Plan.

Structure Plan Policies

10.20. Policy ARC 1 states that in Local Plans for Rural Conservation Areas the Planning Authority may identify and designate Areas and Sites of Archaeological Importance.

10.21. Structure Plan Policy ARC 2, indicates that if the area is considered for top priority conservation Class A, no development will be allowed which would adversely affect the natural setting of these monuments or sites. A minimum buffer zone around the periphery of the site will need to be established in which no development will be allowed.

10.22. Features identified as Class B are regarded as very important and should be preserved at all costs. Adequate measures to be taken to preclude any damage from immediate development and for features that are listed as Class C, every effort must be made for preservation, but may be covered up after proper investigation, documentation and cataloguing. Provision for subsequent access shall be provided. Class E has been introduced in the North West Local Plan. This deals with a site or area in which the Superintendence of Cultural Heritage or MEPA may have some archaeological interest. Should MEPA or the Superintendence have such an interest, the applicant proposing development in that location will be required to undertake an investigation including excavation, if necessary. If, following investigation, the Superintendence of Cultural Heritage considers the site to be of archaeological value, MEPA will normally refuse development permission if the proposed development would lead to the destruction of the site, or require the development to be modified so that the archaeological value of the site is protected.

10.23. The permissible effects of the proposed development on archaeological remains are controlled by policy ARC 3 … development affecting ancient monuments and important archaeological areas and sites, including areas and sites having such potential, will normally be refused if there is an overriding case for preservation. Where there is no overriding case for preservation, development of such sites will not normally be permitted until adequate opportunities have been provided for the recording and, where desirable, the excavation of such sites.

10.24. All other archaeological features listed in the catalogue may be included in MEPA’s National Protective Inventory according to policy ARC 7 for which protection is granted by means of policy ARC 6.

10.25. Policy UCO 7 establishes the grading of listed buildings and regulates works that are acceptable in such buildings:


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• Grade 1: Buildings to be retained in their entirety. Demolition or alterations that impair the setting or change the external or internal appearances, including anything contained within the curtilage of the building, will not be allowed.

• Grade 2: Buildings assigned a Grade 2 are considered to be of vernacular architectural interest and to contribute to the visual image of the area. Permission to demolish such buildings will not normally be allowed. Alterations to the interior will be allowed if proposed to be carried out sensitively and causing the least detriment to the character and the architectural homogeneity of the building.

• Grade 3: Such buildings are usually either modern (mid-20th century onwards) and therefore have no historical importance and are of relatively minor architectural interest, or in a state of ruin and are impossible to restore. Permission may be granted for such buildings to be demolished provided the replacement buildings are in harmony with the surroundings. In the case of building ruins, it is recommended that they be dismantled and the materials re-utilised for the construction or restoration of other features.

Policy importance of archaeological and cultural features

10.26. The classification of archaeological and cultural heritage features according to their policy importance is guided by legislation, including the Cultural Heritage Act 2002, the Development Planning Act 1992, Structure Plan Policies, and Government or Legal Notices regarding specific cultural features. Table 10.1 summarises the grading of archaeological features. The same classification applies to rural heritage features.

Features of International and National Importance

10.27. Archaeological features of international or national importance are protected under all relevant legislation and planning documents, and particularly through Structure Plan Policy ARC 2 Class A. A feature graded as A in Table 10.1 would qualify for protection under Structure Plan Policy Arc 2 Class 2. Such features are considered to be top priority for conservation where no development will be allowed which would adversely affect the natural setting of these monuments or sites. A minimum buffer zone of at least 100m around the periphery of the site will be established in which no development will be allowed.

Features of National Importance

10.28. Archaeological features of national importance are also protected by the above legislation. They are graded as B or medium in Table 10.1. They include those referred to in Structure Plan Policy ARC 2 Class B, and are very important and should be preserved at all costs. Adequate measures to be taken to preclude any damage from immediate development.


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Features of Minor Importance

10.29. Archaeological features classified of minor importance are protected by the Antiquities Protection Act, and other legislation mentioned above. Structure Plan Policy ARC 3 Class C provides for … development affecting ancient monuments and important archaeological areas and sites, including areas and sites having such potential, will normally be refused if there is an overriding case for preservation. Where there is no overriding case for preservation, development of such sites will not normally be permitted until adequate opportunities have been provided for the recording and, where desirable, the excavation of such sites. The features that have been listed as Class C, are protected in so far as every effort must be made for preservation, but may be covered up after proper investigation, documentation and cataloguing. Provision for subsequent access shall be provided.

Remaining Features

10.30. All other archaeological features listed in the catalogue may be included in the National Protective Inventory of the Planning Authority according to policy ARC 7 for which protection is granted by means of policy ARC 6 which indicates that all sites listed in the NPI will be protected in accordance with the Development Planning Act powers and by reference to the ratings given in Policy ARC 2.

Table 10.1: Protection ratings & cultural significance Cultural Significance Class Grade Protection Major National Importance

A 1 Conserve plus 100m buffer zone

Medium Local Importance

B 2 Conserve

Minor C 3 Record May be covered

None D 3 May be covered, destroyed, or recycled

Uncertain E - Further investigation is required

10.31. The grading described in Table 10.1 contributes to the criteria assigned for defining impact significance when carrying out impact assessment on archaeological and cultural heritage features and is discussed below.


10.32. The Application Site falls within the North West Local Plan (NWLP) boundary. The NWLP was approved by MEPA in July 2006 and by Government in August of the same year. Map 34 of the Local Plan indicates that within the A of I there is an archaeological sensitive area to the south, Graded E. In fact, this survey has identified a conglomeration of cart-ruts described below and Technical Appendix 5: Archaeology and Cultural Heritage Baseline Survey. To the North there is another archaeologically sensitive area which starts off from the area of land known


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as il-Hofra and crosses onto the land known as Ic-Cens, which was the focus of this baseline survey (Figure 10.2).

The European Landscape Convention (Florence Convention)

10.33. The Florence Convention signed by all members of the Council of Europe, and therefore by Malta as well, clearly defines landscape and is aware that “sustainable development based on a balanced and harmonious relationship between social needs, economic activity and the environment” must be achieved (European Landscape Convention 2000: 1). It also maintains that “the landscape is an important part of the quality of life of people everywhere” and that it is a “key element of individual and social well-being and that its protection, management and planning entails rights and responsibilities for everyone” (European Landscape Convention 2000: 1).

10.34. According to this Convention, landscape “means an area, as perceived by people, whose character is the result of the action and interaction of natural and/or human factors” and covers “natural, rural, urban and peri-urban areas” (European Landscape Convention 2000: 2).

Determining Impact Significance 10.35. The significance of the impacts of the Scheme on the cultural heritage of the A of I is

dependent upon the cultural heritage importance assigned to each of the features, either through legislation or developed by Adi Associates in agreement with MEPA, and the degree of disturbance or damage likely to arise from the construction or operation of the project.

10.36. The assessment of the significance of potential negative impacts of the Scheme on the cultural heritage aspects uses three levels: not significant, minor significance, and major significance. The assessment criteria applicable to each of these levels are described in Table 10.2, which correlates protection ratings and cultural significance described in Table 10.1 with significance of impact.

Table 10.2: Impact Significance Criteria Cultural significance Potential damage or

destruction to features / class or grade of feature

Major Grade 1

Medium Grade 2

Minor Grade 3

None no grade

No material change to the cultural heritage feature or setting

Not significant

Not significant

Not significant

Not significant

Small scale changes, such as alterations to the cultural heritage feature that are unlikely to affect the integrity of the feature or its setting

Major Minor Minor Not significant

Loss of or disturbance to the cultural heritage feature that is likely to affect the integrity of the feature or its setting

Major Major Minor Not significant


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10.37. In applying the above criteria Adi Associates is mindful of the fact that the disturbance of certain features is prohibited by law, in which case even small-scale changes or alterations to a legally protected feature would be a major impact. In actuality, however, when assessed in the context of the Scheme, and taking account of proposed mitigations, the potential impact on the cultural heritage may not be that significant. An example of this could be construction of a new structure next to a cultural heritage feature in a manner that does not destroy any aspect of the heritage feature and is completely reversible. In order to provide clarity on the impact of the potential disturbance in the context of the Scheme, the Assessment Matrix (see Table 10.6) assesses the impacts both in the light of existing legislation as well as solely in the context of the Scheme (i.e. devoid of legislative considerations).

10.38. It is also noted that the above impact significance criteria do not take account of circumstances where changes to the feature or its setting outside the scope of the current project result in or imply a reclassification of its protection status.

THE BASELINE SURVEY RESULTS

Study Limitations 10.39. The area of Ic-Cens presents a varied landscape which has been utilised for different

purposes over the ages. The agricultural areas are still intensively cultivated, and as such fields were not always accessible during the survey. Some lacked visibility due to vegetation and others were worked at the time of survey. Part of the area is also being used as car park for the hotel, and therefore the land here is highly disturbed. Moreover, the area has been greatly altered by the Mellieha bypass, the Seabank Hotel itself, as well as the development of several residential units in the area. The cultural landscape of the area has therefore been greatly altered and its readability has been reduced considerably.

Scheduling 10.40. Table 10.3 describes the scheduled cultural features in the A of I of the Scheme (see

Figure 10.2)


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Table 10.3: Scheduled sites relevant to this study

Category Type Feature G.N. Level Ref on Figure 10.3

Architecture Military It-Torri l-Ahmar 729/95 1 1 Architecture Military Il-Batterija ta’ Westreme 729/95 2 2 Architecture Military Ta’ Qassisu Entrenchments 729/95 1 3 Architecture Military WW II Beach Post (il-Qammieh) 895/02 2 4

Architecture Military WW II Beach Defence Light (il-Qammieh)

895/02

2

5

Architecture Military Concealed Gun Emplacement (Is-Sdieri) 895/02

2

6

Architecture Military WW II Machine Gun Nest (Is-Sdieri) 895/02 2 7 Architecture Military WW II Defence Post (Is-Sdieri) 895/02 2 8 Architecture Military WW II Defence Post (Id-Dahar) 895/02 2 9 Architecture Military WW II Defence Post (Id-Dahar) 895/02 2 10 Architecture Military Entrenchment (Taht is-Sur) 895/02 2 11 Architecture Military WWII Beach Post (Taht is-Sur) 895/02 2 12 Architecture Military WW II Beach Post (Triq id-Dawra) 895/02 2 13

Architecture Military WW II Beach Defence Light (Triq id-Dawra)

895/02 2 14

Architecture Military WW II Defence Post (Gnien Ingraw / Ta’ Skrajda)

895/02 2 15

Architecture Military WW II Entrenchment (Triq l-Ghollieqa) 895/02 2 16

Architecture Military WW II Defence Post (Gnien Ingraw) 895/02 2 17

Architecture Military WW II Defence Post (San Niklaw) 895/02 2 18

Archaeological SAI Remains (Tas-Sellum) 681/00 B 19

Architecture Military Entrenchment (Tas-Sellum) 683/00 2 20

Architecture Military Gun Post (Tas-Sellum) 683/00 2 21

Source: North West Local Plan


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Figure 10.2: Cultural Heritage features located within the A of I


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Historical Importance of the Area 10.41. The first dated literary evidence relating to the area comes from 1436 (in Bishop De

Mello’s Rollo). However, given the area’s relatively abundant supply of natural resources including freshwater, salt, and stone the area’s archaeological importance dates back to prehistory. Troglodytic communities inhabited the caves in the area during the medieval period. During the period of the Knights of Saint John, the area became an important landing site for troops and military features were erected including the Westreme Battery.

10.42. During the British period, Ghadira Bay again acquired military importance and the coastal defence area around Mellieha was reinforced including the construction of entrenchments and pillboxes.

10.43. Technical Appendix 5: Archaeology and Cultural Heritage Baseline Survey provides a detailed description of the recorded evidence of human activities within and around the A of I including a discussion on the prehistoric and Punic/Roman period, the medieval period, the period of occupation by the Order of St John, and the British period.

Cultural Features 10.44. Figure 10.3 illustrates the cultural features recorded within the A of I. These are

described in detail in the Catalogue Sheets in Appendix I of Technical Appendix 5: Archaeology and Cultural Heritage Baseline Survey. Table 10.4 lists these features and briefly describes their present levels of protection, or in the absence of such protection, the level of protection for which they would qualify.

Table 10.4: Cultural Features that Merit Conservation: Summary of Policy Importance

Feature Ref. Number

Feature Class / Grade / Level Merits

GHDR07_001 Water Reservoir Grade 3 (proposed) Vernacular Architecture GHDR07_002 Rubble wall with large

Upper Coralline Limestone blocks

LN 160 of 1997 Vernacular Architecture

GHDR07_003 Rubble wall with large unhewn Upper Coralline Limestone blocks

LN 160 of 1997 Vernacular Architecture

GHDR07_004 Cart ruts and depressions in the bedrock

Class B (proposed over the existing Class E); within Area of Archaeological Importance

Archaeology

GHDR07_005 High rubble wall LN 160 of 1997 Vernacular Architecture


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Figure 10.3: Cultural features recorded within the A of I


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Rural features

10.45. Although the A of I has been partly developed, it still retains some vernacular elements. In fact, the Application Site and its A of I are surrounded by terraced fields, bounded by rubble walls, and dotted with a number of vernacular features such as water mills and a farmhouse.

10.46. GHDR07/001 is a reservoir built with undressed stone and also having a reutilised stone within its structure. Construction of the reservoir imitates the dry stone technique and forms part of the vernacular heritage of the Maltese Islands. A Grade 3 scheduling would provide for its recording.

Rubble walls

10.47. Rubble walls have stood in the area for centuries, delineating boundaries, offering protection from winds to man, animals, crops and trees, and even used to build field terracing. The dating of rubble walls is usually difficult. The rubble walls in the A of I were built using irregular stones that were packed together without the use of mortar.

10.48. GHDR07/002, GHDR07/003, and GHDR07/005 have been recorded in the Cultural Features Catalogue as they have particular characteristics that distinguish them from the standard rubble walls in the area. However, these features can still be considered to be rubble walls, and therefore they are protected by LN 160 of 1997.

10.49. GHDR07/002 is a wall made up of about 7 large upper coralline limestone undressed blocks measuring an average of 0.8 m. These blocks of stone are unusually large for a rubble wall, although they act in the same way.

10.50. GHDR07/003 is also a rubble wall with large upper coralline limestone unhewn blocks. The blocks are again large in size when compared to the other walls in the area.

10.51. Large undressed blocks were noticed only in 2 walls within the A of I. These were recorded given that they are of an exceptional size and given the context of the features within the cultural landscape, which includes sites such as the nearby cart ruts, San Niklaw, and a possible harbour in the area. These could either be part of an archaeological site in the area (that would be exposed, when and if works are monitored) or re-utilised from nearby sites.

10.52. GHDR07/005 is a high rubble wall built with irregular stones, except for the cornerstones, where well-dressed stone was utilised. This wall was possibly built to protect an orchard from strong prevailing winds.

10.53. The present state and length of the other rubble walls in the area are divided into three categories as shown in Table 10.5. Figure 10.4 shows the rubble walls in the A of I including their classification.


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Table 10.5: State and length of rubble walls in the A of I Grade Length

(m) Colour Code on Figure 10.5

Good to Fair Condition A 1280.5 Red Fair to Poor Condition B 39.82 Orange Bad Condition/ Slight Traces only C 18.59 Green

Grade A walls

10.54. The state of preservation of the rubble walls indicated as Grade A, ranges from good to fair condition. These walls still retain a large percentage of the original stonework, which may vary from 85% to 65% of the whole.

Grade B walls

10.55. Grade B walls range from fair to poor condition. These walls still contain part of the original stonework but have parts either restored with new blocks of stone or are still in a partly demolished state. The amount of original stonework varies from 64% to 35% of the whole.

Grade C walls

10.56. These walls are in a bad state of repair and in some cases they only consist of slight traces of wall. The amount of original stonework varies from 34% to 10% of the whole.

.


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Figure 10.4: Rubble walls


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Archaeology 10.57. As described in Technical Appendix 5: Archaeology and Cultural Heritage

Baseline Survey, the area has preserved a limited amount of archaeological remains. However, this does not exclude that archaeological remains are buried beneath undeveloped areas.

10.58. Only one archaeological feature was recorded within the A of I. GHDR07/004 includes a conglomeration of cart ruts and depressions in the bedrock. Two pairs of cart-ruts are clearly visible and there is a possibility that they were reutilised as water channels. In the North West Local Plan, this area is scheduled as a Class E and as an Area of Archaeological Importance. This study proposes a Class B level of protection for these cart ruts since this archaeological feature still poses a number of problems related to its dating and use. As such, the preservation of as many cart ruts conglomerations as possible is essential for the further investigation of the Maltese cart-rut phenomenon. Moreover, MEPA has already scheduled other cart ruts as Class B, as for instance those at T’Alla w’Ommu that have been scheduled by GN 829 of 1998.

Cultural Landscape 10.59. All archaeological and historical sites and features form part of the landscape which

surrounds them. The cultural landscape can be developed from investigating the cultural context of the area in the vicinity of the Site. The main value of the cultural heritage in the area lies in the information it might yield regarding past settlement patterns and land-use patterns.

10.60. Archaeological evidence in the area clearly shows that it has been habituated since prehistoric times. Little information remains to determine what the landscape during this period really looked like. However, the evidence available makes it clear that it was the morphology of the land that dictated the type of land use and hence the cultural landscape.

10.61. The most important cultural landscape in the area is certainly the rural landscape, although in more recent times, the popularity of the beach has increased its importance as a cultural asset. The cultural landscape is founded on elements that include rubble walls, cart ruts, tombs, troglodytic settlements, salt pans (now the bird sanctuary), rural and military structures, and the patterns of associated with agricultural and other land uses.

10.62. Each one of these elements cannot be understood on its own, but it has to be understood in terms of the relationship between the different features and the surrounding landscape. This cultural landscape preserves an important archaic way of life which has been superseded and remnants of which may not be found elsewhere on the island.


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10.63. Superimposed but without intruding on this landscape is the military landscape. From it-Torri l-Ahmar, which was built around 1647 (see above) and the Westreme Battery (1715), through to WWII, the area served an important military role (see above). Not only do the remnants of these features play an important role in informing the cultural landscape, they would not have existed had it not been for the very nature of the landscape. It is clear that land use is linked to the landscape and vice-versa. “It can be difficult to develop a specific policy for these landscapes, because it is the whole composition, not individual elements which provide the value… clear strategies mean that spatial development of the cultural landscapes can be influenced: desirable land uses are defined and others precluded” (ESDP: 75).

10.64. The cultural landscape of the RIU Seabank Hotel, therefore encompasses all of the above; it extends from the Mellieha Ridge in the south to the Marfa Ridge in the north and as far as the eye can see from the hotel towards the west and east.

10.65. The impacts of the Scheme on this cultural landscape must be assessed in the light of the existing scenario whereby in addition to cultural features the area includes a number of uses and major interventions that have been included over the last 50 years: the RIU Seabank Hotel and other two hotels (Mellieha Holiday Centre and Mellieha Bay), the extent of the urban area, the creation of the bird sanctuary (and wetlands), the major roads, and the beach concession buildings. When considered cumulatively the addition of the Scheme to the already largely urbanised/touristic landscape is insignificant. Although the Scheme will marginally increase the extent of urban development, it will not detrimentally affect the setting of the cultural features and will not result in the destruction or removal of documented cultural heritage features.

10.66. However, in the context of the cultural landscape in the immediate vicinity of the Scheme, the impact will be substantial on the features that are present. The rural context of the Grade 3 water reservoir will be lost, and the loss of rubble walls will substantially affect the context of the remaining rubble walls (rebuilding the lost walls elsewhere on the Application Site will not compensate for their loss).

10.67. Having regard to the foregoing arguments, it is concluded that the impact of the Scheme on the wider cultural landscape will not be significant, but in respect of the context of the loss of the context of the walls and the reservoir, the impact would be minor.62

62 In this respect it is noted that the water reservoir is scheduled as Grade 3 – which means that it may be

recorded and removed. Had the water reservoir been graded as A or B, the impact would have been greater.


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ASSESSMENT OF IMPACTS

Prediction and Significance of Impacts 10.68. The significance of impacts is dependent upon the importance of cultural heritage

features and the potential for damage or destruction to these features by the Scheme.

Loss of features

10.69. The Site includes rubble walls that are in various states of preservation. Most of the rubble walls, particularly in the western and southern areas of the Site are considered to be Grade A. Two rubble walls are classified as Grade B and one is classified as Grade C. Some remnants of rubble walls exist where the Site is currently used for parking, and those walls located closer to the existing hotel. The scheduled features GHDR07_002 and GHDR07_005 will be lost. Loss of Grade A and B walls, as well as the scheduled features would result in a major negative impact. Loss of Grade C walls would result in a minor negative impact. Therefore overall, the loss of cultural heritage features as a result of the Scheme is considered to be of major significance.

10.70. Feature GHDR07_001, the water reservoir, lies within the Site boundary. Loss of this feature would result in a minor negative impact.

Damage to features

10.71. Features GHDR07_003 and GHDR07_004 lie outside the Application Site. These features may also sustain damage, particularly during construction. Damage to these features, without mitigation measures in place would result in a minor to major impact, depending on the level of disturbance sustained.

Alteration of context

10.72. As identified during the baseline survey, the cultural landscape of the area and the impact the Scheme has upon it, is an important consideration. The cultural landscape of the area has been compromised by tourist and residential development, additional development as envisaged by the Scheme is expected to result in a minor impact on the cultural landscape.

PROPOSED MITIGATION MEASURES 10.73. Loss of features from the Site cannot be avoided if the Scheme goes ahead. With

reference to GHDR07_002, given the particular size of stones and the fact that one of the blocks shows signs of tool marks, it is recommended that this feature should be further investigated before being dismantled. Moreover, an archaeology monitor should be present on Site during Site preparation. Any features that are found at the Site should be documented before being removed.


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10.74. Rubble walls will be dismantled. It should be ensured that the material will be retained and used in the maintenance of other rubble walls in the area or within rubble walls that will be constructed as part of the Scheme.

10.75. It is recommended that GHDR-7_001 be retained and preserved as far as possible. The feature should be introduced as part of the soft landscaping scheme. In order to preserve the setting of the feature, the use of indigenous trees reminiscent of the rural landscape of the area should be favoured. Sensitive construction methods should be employed close to cultural features. For example the area should be delineated with high visibility tape and trenched around to prevent vibration impacts.

10.76. The cart ruts are located outside the Application Site boundary.

10.77. In order to minimise impacts on the cultural landscape, the landscaping scheme should respect the rural landscape through the planting of endemic and indigenous vegetation, particularly favouring those that grow in a maritime environment. Artificial lighting should be as minimal as possible to respect this landscape as well. The structures themselves should also reflect the rural characteristics of the area.

10.78. The Site will include two fences during construction. One fence will be within the Site and will surround the area designated for the extension building (at the eastern edge of the Site). The second fence will surround the Site boundary. These measures will reduce the potential of overspill from construction impacting any areas outside the Application Site.

RESIDUAL IMPACTS 10.79. Re-use of the material from the dismantled rubble walls will result in a minor residual

impact. If the water reservoir is retained, the residual impact will be minor.

10.80. If the remaining features that lie within the A of I are preserved, residual impacts are expected to be minor, because although the features will be retained, their setting will be affected.

10.81. Sensitive landscaping will contribute to some extent to reducing the impact on the cultural landscape though residual impacts will remain.

MONITORING REQUIREMENTS 10.82. As described above, monitoring should be carried out during the construction phase

in case archaeological features are uncovered.


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Table 10.6: Summary of Impacts on Cultural Heritage

Predicted Impact Beneficial/ Adverse Nature, Scale and Type of Impact Policy

Importance


occurring

Significance of Impact (Major, Minor, Insignificant)



Impact


Extent of impact (Nat/Local/Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers/ Irrevers

(Inter / National /

Local)


Uncertain)

Legislation


(Major, Minor,

Insignificant)

Loss of features Adverse Constr’n Site Direct L. term Perm Irrevers National Likely Cultural Heritage Act (Minor), DPA (Minor)

Major Reuse material from rubble walls; Retain water reservoir

Minor

Damage to features

Adverse Oper’n Local Direct L. term Perm Irrevers National Likely Cultural Heritage Act (Minor), DPA (Minor)

Minor to Major

Sensitive construction methods around cultural features

Uncertain

Cultural landscape in immediate vicinity of Scheme

Adverse Constr’n / Oper’n

Local Direct L. term Perm Irrevers National Likely Cultural Heritage Act (Minor), DPA (Minor)

Minor None Minor

Cultural landscape Wider area


Local Direct L. term Perm Irrevers National Likely Cultural Heritage Act (Minor), DPA (Minor)

Not significant None Not significant


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11. LANDSCAPE & VISUAL AMENITY

INTRODUCTION 11.1. Assessment of landscape and visual amenity is a complex task, involving examination

of a wide range of factors that contribute to the qualities and attributes of the existing landscape and that may contribute to the landscape of the Scheme. This involves consideration of the evolution of the landscape and the factors that have led to its current condition: from the underlying geology through to the activities of humankind.

11.2. Landscape and visual impacts are distinct, albeit strongly related. Landscape impacts result from the interaction between the proposed development and the existing landscape resource, experienced through changes to any element or combination of landscape elements. Visual impacts relate to the effect that the Scheme would have on the amenity of sensitive receptors (those experiencing views of the Scheme), relating the actual or perceived visible changes to the character and quality of the landscape.

Terms of Reference 11.3. The ToR issued by MEPA require the following:



2.5 Landscape, Topography and Visual Assessment

This should include a landscape characterisation of the area and visual amenity of the area. ‘Non-visual’ aspects of the development should also be considered and include those impacts which reduce the possibility for the public to enjoy the landscape including emissions, noise, etc.


All significant impacts of and risks posed by the proposed project, during demolition, construction and operation should be assessed, given the environmental characteristics of the site outlined in Sections 1 and 2 and the policies outlined in Section 3. A descriptive and quantitative analysis (including significance, magnitudes and timing) of the impacts of the


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proposed development should be made, and presented in summary chart format. The various techniques, methods and assumptions used in the analysis and predictions should be outlined. It is recommended that impact assessment should include:




viii. sensitivity of resources to impacts; ix. probability of impact occurring; x. confidence levels/limits to impact prediction; xi. scope of mitigation / enhancement; and xii. residual impacts.



Visual and Landscape Impact

This shall place an emphasis on any special features and/or protected areas, including landscape characterisation and visual amenity of the area.

This shall include views from and into the site and the impact of the proposed development and alternatives on the visual amenity of the site. This should refer to both the proposal and any other ancillary developments associated with it, and also any alternatives.63

A Zone of Visual Influence (ZVI) should be established and significant viewpoints identified and agreed with MEPA. Submissions required shall be made at the appropriate scale and level of detail and include colour photomontages taken from points, accompanied with base photographs and agreed with the MEPA. Photomontages, submitted on A3 are to show the proposed interventions superimposed on the existing landscape, not only adjacent to the site. One of the photomontages is to portray the site at night-time.

63 Given the absence of local guidelines on landscape assessment it is recommended to use ‘Guidelines for Landscape

and Visual Impact Assessment, 2nd Edition’, published by Spon Press, 2002 and edited by The Landscape Institute and the Institute of Environmental Management & Assessment. Reference should also be made to the MEPA’s ‘Draft Landscape Assessment Study’ that can be downloaded from the MEPA’s website (www.mepa.org.mt).

http://www.mepa.org.mt)


219

Photomontages are to show the situation from a height of 1.7m above ground level (unless specific obstacles justify heightening the viewing point - in which case this should be made clear in the document submitted or unless the MEPA asks for a different viewing height which may include aerial shots). Photomontages are to show the proposed interventions superimposed on the existing landscape, not only adjacent to the site. The landscaping scheme that is being proposed should be included in the photomontage and the maturity of the landscaping scheme as shown (which shall not be less than 5 years after planting) shall be indicated.

Apart from the photomontage itself, the following are required:

A copy of the base photograph used in the preparation of the photomontage (this should enable a comparison of the situation as existing and as proposed - hence the size of the photograph depicting the situation as at present is to be of the same size as the photomontage);

Date when the base photograph was taken;

A site map indicating the exact positions from where the photographs were taken and to which the photomontages should cross-refer; and

Height of the camera from ground level.

5.0 Design of Mitigation Measures

Mitigation Measures

This should include a description of the measures envisaged to prevent, minimise and where possible offset any significant adverse effects on the environment of the project during both construction and operational phases (including reference to consideration of alternatives in section 2. above). Such measures should be realistic and could include technological features; alternative technological features; operational management techniques; enhanced site-planning and management; aesthetic measures; conservation measures; reduction of magnitude of project; and health and safety measures.

The mitigation measures are to indicate how the project design shall take into account the need for continuous improvement with respect to GHG emissions.

Residual Impacts


Monitoring Framework and Management Plans


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Objectives of the Assessment 11.4. The objectives of the landscape and visual amenity study were to:

• Undertake a baseline survey and characterisation of the landscape and visual amenity at and around the Scheme sites using desk top and field survey techniques;

• Evaluate the landscape character of the Scheme sites and their setting;

• Establish the key factors that have led to the formation of the current landscape;

• Establish the Zone of Visual Influence (ZVI) for the Scheme and identify the key viewpoints and receptors;

• Input the potentially beneficial design measures to the Scheme;

• Predict the impacts of the Scheme on the visual amenity of the Area of Influence;

• Assess the significance of the impacts on the landscape and visual amenity of the Area of Influence; and

• Describe the mitigation measures designed into the Scheme to minimise adverse impacts and enhance any beneficial impacts on the landscape and visual amenity of the Scheme.

11.5. The key issues for the assessment are:

Key Issues:

• Effects on the landscape character and quality of the surrounding landscape

• Changes in views of key receptors: residents, roads and visitor locations

Legislation and Policies

Legislation and policies

11.6. The Constitution of Malta (Section 9) declares that the State shall safeguard the landscape and the historical and artistic patrimony of the Nation. These are the only


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aspects of the environment referred to in the Constitution, underlining the importance of the landscape and historical heritage.

Structure Plan

11.7. The Structure Plan for the Maltese Islands identifies a number of policies that are relevant to assessing landscape and visual amenity and the impact of projects thereon. BEN 1 deals with bad neighbourliness and specifically with the visual intrusion of projects. BEN 2 indicates that applications for development permission will not be permitted if the project is unlikely to ‘maintain the good visual integrity of the area in which it is located’. Structure Plan Policy RCO 1 sets the scene for the creation of Areas of High Landscape Value:

POLICY RCO 1: Rural Conservation Areas are designated as illustrated in the Key Diagram. Within such areas the following sub areas will be designated, using World Conservation Union definitions and criteria where relevant: 7. Areas of High Landscape Value;

And Structure Plan Policy RCO 3 provides for local plans to specify the precise boundaries and specify in detail the measures of protection and enhancement to be adopted with respect to the various uses and activities

The North West Local Plan

11.8. The strategy for the NWLP is:

4.0 The main strategy of the Local Plan is to protect the natural and man-made environment and the scenic value of both rural and urban areas, provide for economic development needs, accommodate population growth, encourage leisure and tourism and sustain rural communities and agriculture.

11.9. And in respect of landscape:

4.9.1 The strategy for landscape seeks to:

i. conserve and enhance the unique landscape setting of the North West countryside;

ii. provide an assessment and adequate measures to protect and enhance the geographical, aesthetic and cultural aspects of the local plan area.

11.10. The NWLP divides the plan area into a number of Regional Landscape Character Areas (RLCA); the Application Site falls into the RLCA labelled “North East Coast”. It defines LCAs as “areas with a distinctive local identity in which landscape types and features combine to create a unique combination.” The Plan (see extract at Figure 11.1) indicates subdivisions into 30 Landscape Tracts but does not provide further


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details. MEPA’s Landscape Assessment of the Maltese Islands64 , notes that the hotel at the end of the Mellieha Bypass [is] rather unsympathetic to its backdrop.

11.11. The same section also notes that the coastal road close to the beach is very busy… and[in summer] the carriageway serve to accommodate a large number of parked cars. The string of high-tension power line lattice towers, which transects the area, presents additional marring to the landscape.

11.12. It is noted that the MEPA document addresses visual amenity issues rather than landscape and fails to provide a cogent analysis of the landscape of the area that informs the EIA.

Figure 11.1: Regional Landscape Character Areas

Source MEPA: NWLP

11.13. Map 17 of the NWLP, (see Figure 11.2) shows that northern flank of Ghadira Bay is identified a landmark of natural beauty / natural significance for recognition as Protected Landscape Areas under the I.U.C.N. Protected Area Management

64http://www.mepa.org.mt/Planning/factbk/SubStudies/LandscapeTP/LANDSCAPE_ASSESSMENT_STUDY_sep04.pdf

http://www.mepa.org.mt/Planning/factbk/SubStudies/LandscapeTP/LANDSCAPE_ASSESSMENT_STUDY_sep0


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Category III65. The same map identifies the coastal cliffs at the mouth of the Bay as protected under policy NWLA 2; it is noted that the same area is scheduled for protection under GN 400/96 as an Area of High Landscape Value in terms of Structure Plan Policy RCO 1. However, the Plan does not detail the measures of protection and enhancement to be adopted with respect to the various uses and activities.

Figure 11.2: Area of High Landscape Value and the Area identified for recognition as a protected Landscape Area in IUCN III

Source MEPA: NWLP

11.14. A detailed assessment of these and other policies is given in Chapter 6.

Standards and Guidelines 11.15. In view of the fact that there are no Malta-specific landscape and visual amenity

assessment guidelines, the ToR require that the landscape and visual assessment be carried out in line with the UK best practice methodologies as appropriate, notably the Guidelines for Landscape and Visual Impact Assessment (2002) – Institute of

65 Category III: Natural monument: protected area managed mainly for conservation of specific natural features – area

containing specific natural or natural/cultural feature(s) of outstanding or unique value because of their inherent rarity, representativeness or aesthetic qualities or cultural significance.


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Environmental Management & Assessment and the Landscape Institute. A Method Statement for Landscape and Visual Amenity Assessment was submitted to MEPA and accepted as an appropriate way to undertake the study.

ASSESSMENT METHODOLOGY 11.16. The Zone of Visual Influence (ZVI) was defined using a combination of desk and field-

based techniques. The output from Vertical Mapper informed the identification of potentially significant views and viewpoints for further analysis during the field survey. The extent of the viewshed (ZVI) was verified in the field along with the nine viewpoints that were agreed with MEPA for the visual amenity assessment (see below). The existing views from these locations were photographed, photomontages created, and the visual amenity and changes thereto as a result of the Scheme appraised.

11.17. MEPA’s agreement to the location of the viewpoints was sought before the visual amenity study was undertaken. The viewpoints include:

• Short distance views;

• Medium distance views from publicly accessible locations; and

• Long distance views from high points or tourist attractions.

11.18. For the sake of the record, the viewsheds generated by Vertical Mapper and the validated ZVI (ie the viewpoints) are shown together on Figure 11.3.

Consultations

11.19. MEPA was consulted at each stage of the assessment process to verify the desk and field survey methods, and to agree the viewpoints from which to undertake the viewpoint appraisals.

Desk Study Methodology

Landscape assessment

11.20. The landscape baseline conditions were determined through desk study and field survey. The desk study included:

• Review of the information shown on the base map of the area and reference to the maps prepared for the cultural heritage and land use aspects of this EPS;

• Analysis of aerial photographs to determine land use trends; and

• Review of existing baseline information from:

o Literature searches; o Previous environmental and planning studies undertaken in the area; o Historic maps; and o Legislation and policy documents.


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Visual amenity assessment

11.21. The ZVI from which the Scheme is visible was determined through the ZVI described above and verified in the field. A number of views from publicly accessible locations were identified within the ZVI as shown in Figure 11.3. These were agreed with MEPA as a basis for assessing changes to visual amenity that may result from the implementation of the Scheme.

Field Survey Methodology

Landscape

11.22. A comprehensive field survey was undertaken in October 2006. It was undertaken in accordance with Guidelines for Landscape and Visual Impact Assessment (The Landscape Institute and IEMA, 2002). The field survey served to record objective and subjective impressions of the landscape, and details of landscape condition, land use, and management. It provided the basis for the delineation of landscape character areas and the identification potential sensitive landscape receptors in accordance with the Guidelines.

Table 11.1: Potential sensitive landscape receptors Landscape elements Urban development: buildings, roads. Marine: beach, seasonal moorings, littoral marine infrastructure;

beach rooms and paraphernalia. Rural: well-vegetated / agricultural valleys, open bare ridge, rubble

walls on contours, few buildings, horizontal stratification Landform & topographic features: Bay, littoral platform, steep

sided ridge and valley, roads bisect landscape. Landscape characteristics Patterns & combinations of features: seaward end of southern

ridge, valley and littoral given to urban development; open valleys;; marked horizontality and sinuosity of terraced valley sides

Scenic quality of bay and non-urban areas Sense of place, especially in Bay and valleys Landscape character The distinct and recognisable pattern of elements that occurs

consistently in the landscape, and how this is perceived.

Visual amenity

11.23. The extent of the visibility of the Scheme was verified in the field survey, and the ZVI and publicly accessible viewpoints confirmed (See Figure 11.3). The field survey also confirmed the areas from which the Scheme was not visible.

11.24. Potential sensitive receptors identified in the course of the field survey (in order of descending sensitivity) were:

• Residents on Mellieha ridge, Mellieha;

• Tourists staying at / visitors to the Mellieha Holiday Centre;


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• Recreational users of the area;

• Road users (vehicle occupants and pedestrians); and

• Workers.


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Figure 11.3: Zone of Visual Influence and Viewpoints


228

Figure 11.4: Local Landscape Character Areas


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DETERMINING IMPACT SIGNIFICANCE 11.25. The significance of impacts on the landscape and visual amenity is dependent upon

judgements about the value of the existing visual amenity compared to the new visual amenity that would be created, the number of people affected, the magnitude, duration and permanency of the changes, and subjective judgements about how much these changes would matter to those concerned.

Landscape Assessment 11.26. The significance of landscape impacts has been defined as follows:

• Major Significance: Large negative changes in the landscape that are out of character with the landscape. Where the extent of the change of the landscape asset (character or element) is large in scale or magnitude and the affected landscape has a moderate or high landscape value / is sensitive to change. It would result in a change that would mean that the integrity of that asset would be significantly altered. The impact would be of international or national importance and / or likely to affect a large number of people. The impact would be of a long-term nature (or very severe short term in the case of construction impacts), irreversible, and certain or likely to occur;

• Minor Significance: Some noticeable changes in the landscape that are out of character with the landscape. Where the extent of the change of the landscape asset (character or element) is moderate or small in scale or magnitude and the affected landscape has a low or moderate landscape value / is moderately sensitive to change. It would result in a change that would mean that the integrity of that asset would not be greatly altered. The impact would be of local importance and / or likely to affect few people. The impact would be of a long or short-term nature, and likely to occur;

• Not Significant: No perceptible changes to the landscape resource or character of the landscape. Where the extent of the change in the landscape asset (character or element) is of limited importance in scale or magnitude and the affected landscape has a low sensitivity to change. It would result in a change that would mean that the integrity of that asset would not be altered. The impact would be of local importance and / or likely to affect very few people. The impact would be of a long to short-term nature, and / or unlikely to occur.

Visual Amenity 11.27. The significance of visual impacts has been assessed in relation to:

• The number and sensitivity of receptors affected;

• The duration of the changes;

• The extent of visibility & distance from the Scheme;

• The type of view – proportion of development visible, focus on Scheme due to proximity and whether it is fixed, transient or sequential;


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• The changes to the view from the identified view points as shown by the photomontages; and

• The scope for mitigation/enhancement measures to screen the development.

1.27. Based on the above criteria an assessment of the significance of the visual impact on each of the agreed viewpoints was made in terms of whether it is considered to be of:

• Major significance - large changes in the view. Where the extent of the negative impact on the visual amenity would be large in magnitude or extent, affect a visual amenity that is moderate or high sensitivity to change and / or a high intrinsic value. The impact would affect a modest number of high sensitivity people or many people of moderate sensitivity;

• Minor significance - some noticeable changes to the view. Where the extent of the negative impact on the visual amenity would be moderate in magnitude or extent, affect a visual amenity that is moderately sensitive to change and / or have a moderate intrinsic value. The impact would affect a modest number of moderate sensitivity people or many people of low sensitivity. Alternatively the impact would potentially be of major significance but with significant mitigation (e.g. screening) proposed or possible;

• Not significant - little or no obvious changes to the view. Where the extent of the negative impact affect a visual amenity would be small in magnitude or extent, usually affecting a low sensitivity visual amenity or one with a low intrinsic value. Most of the people affected would be of low sensitivity. The change would only affect a small part visual amenity area (the area of view).

EXISTING CONDITIONS: DESK STUDY

Landscape 11.28. The Scheme is situated on the lower reaches of the Mellieha Ridge that defines the

southern flank of Ghadira Bay. The geomorphology of the area is characterised by horsts and graben which, through the tilting of the Island to the east, resulted in a ria system of drowned valleys and relatively high intervening ridges / peninsulas.

11.29. In spite of man’s long standing involvement in the area, the landscape has only recently been substantially affected by his interventions. The construction of multi-storey housing on the southern flank of the bay extending along the littoral from the bayhead in the direction of Ras il-Griebeg has resulted in the insertion of a typical Maltese urban landscape with little attention paid to the intrinsic value of the landscape or the cumulative effect of the massing of buildings on it.

Landscape Character Assessment 11.30. The landscape types / character areas that provide the landscape context to the

Scheme are described below. The distinction between the types and areas is defined in the assessment as:


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• Landscape character types describe distinct and homogeneous generic landscape units that share common combinations of elements; and

• Landscape Character Areas are single unique areas and represent discrete geographical areas of a particular type. These are mapped on Figure 11.4 and described in Table 11.2. Landscape sensitivity described for each Landscape Character Area is judged on the basis of the landscape elements and the problems enumerated for each.

Table 11.2: Landscape types, Character Areas Defined area / Attribute Summary Description Landscape Type Ridge and Valley with bayhead beach and steep coast

Steep valley sides enclosing the bay, combined with the upper coralline spur that bisects the valley create a landscape that is unique in Malta. The tilt of the underlying geology from west to east has resulted in high ground at the west (spectacular sea cliffs) that gently falls away eastwards towards the beach at Mellieha. The cliffs have been identified (in the NWLP Policy NWLA 3) as area that would qualify as a protected landscape in terms of the World Conservation Union’s (IUCN) criteria.

Character Areas Character Area 1: Southern Ridge (Mellieha Ridge)

Spurs of high ground and steeply incised valleys, and caves in the valley walls. Urban development on the ridge.

Mellieha Ridge o Ridge largely given to urban development, predominantly multi-

storey development; o Buildings on ridge built to take advantage of sea views, but little

chance for residence that are not immediately on the edge of the ridge to view the sea;

o Horizontal stratification afforded by the ridge and valley system and the rural terracing inland are reflected in the contour development.

Problems o Loss of original ridge line; o Ad hoc development of apartment blocks of various heights and

widths; o Dominance of the urban development; o Layers of urban development cascade down Mellieha Valley /

Santa Maria towards the waters edge; o Mellieha Bypass severs the landscape; and o Green / undeveloped spur isolates and emphasises the sea-side

development. Landscape Sensitivity Moderate to high because of the relatively original landscape is easily read, but severely compromised.

Character Area 2: Southern Valley

Broad alluvial valley lying to the north of Mellieha ridge and to the south of the Danish Village ridge.

Southern Valley. o The intensively cropped valley floor o Valley dips from west to east towards Ghadira beach; o Well-maintained latticework of rubble walls o Buildings within valley are well set into the landscape; Problems


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Defined area / Attribute Summary Description o Dominance of the urban development in adjoining areas Landscape Sensitivity High.

Character Area 3: Intermediary Ridge

Spur of high ground between two broad alluvial valleys.

Intermediary Ridge o Exposed upper coralline limestone / garrigue and the ‘Danish

Village; o ’Smooth, rounded ridge partly afforested and partly bare rock

and garrigue / low lying vegetation; o Provides a backdrop to the agricultural valley, affording a sense

of containment; and o Traversed by arterial road at eastern boundary, which breaks

the continuity of the landscape. Problems o Potential increase in density at Mellieha Holiday Centre and los

of vegetation; and o Loss of continuity resulting from the arterial road. Landscape Sensitivity Moderate

Character Area 4: Northern Valley A broad alluvial valley largely given to cropping terminating at an arterial road across the bayhead at its eastern extremity and a wildlife sanctuary

Northern Valley. o Valley dips from west to east towards Ghadira beach; o Majority of valley given to agriculture; o Rectangular fields well defined by rubble walls; o Overlooked by Mellieha Holiday Centre; o Buildings within valley are well set into the landscape; and o Wetland / wild life sanctuary located at eastern end. Problems o Loss of continuity resulting from the arterial road; o Dominance of the urban development in adjoining area; o Intensification of agriculture through the introduction of further

glasshouses and polytunnels, and other changes of land use. o Change in hydrologic regime that affects the viability of the

marshlands. o Increased chemical use in agricultural land upstream may affect

the water quality within the wetland and hence the wildlife and vegetation.

Landscape Sensitivity High.

Character Area 5: Northern Ridge (Marfa Ridge)

The slopes of the northern ridge form a landscape character area of immense importance to the setting of the other character areas that comprise the Mellieha Unit. Most of the area is terraced, and combined with the scatter of substantial trees over a wide area, affords a typically Mediterranean feel. With the exception of the Tower, the ridgeline is unbroken.

Northern Ridge Marked Horizontal stratification reflected in o Terraced agriculture; o Sporadic woodland along terraces; and o Horizon / skyline pierced by Red Tower and electricity poles. Problems o Potential loss of rubble walls and intensification of afforrestation,


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Defined area / Attribute Summary Description change of land use;

o Potential for increased utility / power lines (and pylons) and a wind farm on the ridge;

o Electricity poles dissect landscape; and o Continuation and / or consolidation of green beach huts in

adjoining area. Landscape Sensitivity High.

Character Area 6: Beach This area (which includes hotels, the green beach huts, beach concessionaires and other urban development and summer moorings) is the area that is synonymous with “Mellieha Bay”. It is a summer major recreation and tourist area.

The Beach o Bayhead pocket beach; o Seasonal moorings; o Beach buildings; o Recreation facilities; o Arterial road; o Green beach houses; and o Hotels: RIU Seabank and Mellieha flank either end of the beach Problems o Potential loss of rubble walls and intensification of afforestation,

change of land use; o Arterial road; and o Continuation and / or consolidation of green beach huts. Landscape Sensitivity High.

The Zone of Visual Influence 11.31. The Zone of Visual Influence of the Scheme is extensive when based on contour lines

without taking into consideration intervening buildings and vegetation. The viewshed was created for each of the Scheme’s buildings, and superimposed on each other to determine the extent of visibility of the entire Scheme (See Figure 11.3).

EXISTING CONDITIONS – FIELD SURVEY

Scheme Landscape 11.32. The field survey affords the opportunity to appreciate the intricacies of the character

of the Scheme area, pick up features that are not shown on maps, and develop a deeper understanding of the landscape’s rationale, and particularly to gather sensory information such as sounds, smell, etc., all of which contribute to an overall appreciation of landscape character.

11.33. From all vantage points to the south of the Application Site, the sheer scale and magnificence of the ridge and valley system terminating in the pocket beach becomes very apparent. Viewed from the north, the grandeur of the landscape is not quite as striking. Although the ridge and valley system is very apparent, its morphological characteristics and the skyline are marred somewhat by the urban sprawl over the


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distant southern ridge. From this side of the landscape unit, the light which results from facing directly south makes the more distant aspects of the landscape more difficult to view, forcing one’s eye to the more intimate landscape afforded by the nearby marshlands and agricultural fields. It is from here, however, that the contrast between the urban development and the countryside becomes more apparent. The typical rural Maltese hillside landscape with the characteristic stratification is overwhelmed by urban development that is seemingly devoid of any sensitivity to the underlying landform. The RIU Seabank hotel, situated at the foot of the valley side, is barely distinguishable from the urban development of which it forms part. It acts as a terminal marker where urban development meets the rural patterns of the southern valley.

11.34. The field survey also showed that the central highland / Mellieha Holiday Centre effectively screens most views to the more distant valley. It also emphasised the fact that the importance of the separation afforded by ridge, creating a sense of enclosure and intimacy.

11.35. The horizontal nature of the landscape becomes more evident in the field, whereby the three dimensional layering of successive ridge and valley systems become more obvious, especially from higher vantage points.

11.36. Appreciation of the landscape looking outwards from the Application Site paints a somewhat different picture. The contrast between the rural views to the north / north west, the bay area views to the north east, and the views to the east and south east is very marked. The former present a somewhat timeless rural landscape of horizontal stratification and intimate spaces afforded by well-defined fields and planted borders; the other offers a busy urban landscape where urban development that smothers all vestiges of the former landforms.

Landscape Character 11.37. The general findings of the desk study were confirmed.

11.38. The character of the area affected by the Scheme is particularly important because it provides the context to the Scheme and the contrast and impact between the new landscape resulting from the introduction of the Scheme and the existing landscape would be, in part, determined by how well the Scheme is assimilated into the wider landscape. The key character attributes are:

• The three dimensional horizontal stratification of the landscape afforded by the ridge and valley systems;

• The vertical scale of the landscape; • The rounded nature of the skylines afforded by the natural landscape; • The disruptive effect of the existing urban development in respect of skylines and

continuity, particularly on the southern ridge; • The lack of homogeneity or sense of form in respect of urban development; • The open space afforded by the valleys and the bay; and


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• The manner in which the urban development is juxtaposed against the apparent timelessness of the landscape afforded by the rural landscapes and,in particular, the manner in which the landscape texture evokes a sense of history. This appears to be reinforced by evoking a sense that it is appropriate for changes to happen within the already compromised urbanised areas, but beyond which the landscape is sacrosanct and unchanging.

Visibility and Visual Amenity 11.39. The computer generated ZVI (which takes no account of buildings and trees) was

apprised in the field. Although the appraisal confirmed the wide visibility of the Scheme, it also confirmed that it was not visible from a substantial part of the computer generated ZVI.

11.40. The appraisal also confirmed that there is a reduction in the degree to which the Scheme can be discerned as distance from it increases. Near to the Scheme, for example from the bay head, much of the Scheme would be screened by intervening development, particularly the existing RIU Seabank hotel. From more elevated positions, such as from the Mellieha Bypass, or from the Red Tower, substantial parts of the Scheme would be readily visible, albeit the former from a considerable distance.

11.41. The viewpoints selected to illustrate the visual amenity of the ZVI, chosen with the agreement of MEPA, are representative of long, medium, and short distance views from public places. The selected viewpoints are shown on Figure 11.3.

Application Site visibility

11.42. In assessing views there is often likely to be a continuum in the degree of visibility of the development from full view to no view. Table 11.3 summarises the situation in respect of the Scheme.

• Extent of site visibility – full view, partial view, glimpse or no view into the site at all demonstrates the exposure of the site and the processes thereon to public view.

o The Scheme is not fully visible from any viewpoint. From all viewpoints it can only be seen as a glimpse or partially, because of the screening effects of terrain and structures. The view from Viewpoint 2 affords the greatest viewable area of the Scheme;

• Proportion of development visible – expresses the proportion of the development that is visible from the viewpoints: full, most, some, small amount, or none.

o The proportion of the Scheme that is visible from the viewpoints varies from a considerable proportion at the Viewpoint 2 to no more than 30% at the distant viewpoints.


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• Focus on Scheme due to proximity – is an indicator of the distance from the Scheme and whether the viewpoint would focus on the development due to its proximity (i.e., it is the only thing to look at), or whether the Scheme is part of a panorama.

o None of the selected views is close to the Scheme because of the screening effect of the vertical scale of the surrounding development, as agreed with MEPA. It is noted that a potential viewpoint on the Mellieha Bypass immediately south of the Scheme was considered and scoped out because it would be better represented and appraised by a slightly more distant point at Viewpoint 2.

• Transient or sequential view – it is apparent that the principal receptors (i.e., travellers) will have transient or sequential views. Transient views are those that pass quickly (like looking through a doorway as one walks past), and sequential views expose the receptor to different yet sequential views of the site. The latter allows the site to be viewed for a longer period and from different and changing perspectives.

o Transient views are experienced at all Viewpoints except Viewpoints 2 and 6.

Table 11.3: Summary of Application Site visibility from viewpoints Viewpoints

VP 1 VP2 VP3 VP4 VP5 VP6 Distance of viewpoint from Scheme (m) 420 480 340 1,490 1,140 640

Extent of Scheme visibility Partial Partial Partial Partial Partial Partial

Proportion of Scheme visible 5% 50% 50% 50% 5% 50%

Focus on Scheme due to proximity Panorama Panorama Panorama Panorama Panorama Panorama

Transient or sequential view Transient Transient Transient Transient Sequential

Sensitivity of visual receptors 11.43. The sensitivity of visual receptors is dependant on the location from where they

experience the view, their expectations, occupation or activity at the viewpoint, and the importance of the view. UK Guidelines66 note that the most sensitive receptors may include:

• Users of outdoor recreation facilities whose attention or interest may be focused on the landscape;

• Communities where the development results in changes to the landscape setting or valued views enjoyed by the community; and

66 Guidelines for Landscape and Visual Impact Assessment The Landscape Institute & Institute of Environmental

Management & Assessment, 2002


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• Occupiers of residential properties with views affected by the development.

The Guidelines also note that other receptors could include people engaged in outdoor sport or recreation other than those involving an appreciation of the landscape, people travelling through the area, and people at their place of work. The latter are regarded as the least susceptible to changes in view.

The following definitions are used to categorise the sensitivity of receptors:

• High sensitivity receptors: those who repeatedly revisit the viewpoint to partake of the view. Such views are generally highly valued by the community;

• Moderate sensitivity receptors: itinerant visitors (mostly tourists) to the viewpoint; and

• Low sensitivity receptors: road users, workers, etc.

11.44. Residents are not included above because views from private property are not protected under planning law or other public policy except in so far as the zoning of the land implies certainty as to the type of development that may be permitted. In this regard, the residents would have the expectation that the Application Site would be developed in accordance with the underlying zoning to a height of 8 floors which would, in any case, violate their views. Their rights are protected through the planning system whereby they are afforded the opportunity to object to any change of land use (or airspace). The EIA process does not assess the impacts of a project on the rights or values of individuals, but rather on the public collectively, and those rights and values are as expressed in legislation and planning policy. It is for this reason that EIAs do not address the effects of loss of views from private properties, land ownership, etc.

CHANGES IN THE LANDSCAPE AND VISUAL AMENITY 11.45. Changes to the landscape and visual amenity of the ZVI are anticipated because of the

Scheme. This section focuses on the impacts of the Scheme as described in Chapter 4, on landscape and visual amenity, and points to possible mitigation measures.

Changes in the Landscape and their Significance 11.46. The changes to the landscape during construction and operation are considered

together. In terms of landscape character, the impacts occur as a result of the construction of the Scheme. Hence, the assessment of the Scheme during operation is the same as that for the construction (completion of the buildings to their full height) and covers the loss of landscape features and the effects of the Scheme on those remaining.

11.47. Table 11.4 details the changes in landscape and their significance.


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Table 11.4: Changes in Landscape Character and the significance of the impacts Location Changes Effects & Significance Character Area 1: Southern Ridge (Mellieha Ridge)

No change Impact: Not significant.


Small extension to the developed area; in area of high landscape value but the change would be of local importance.

Increases the dominance of the urban development over the adjoining rural areas Impact: Minor significance.



Character Area 4: Northern Valley




11.48. The Scheme is judged to be not in compliance with the draft Landscape Assessment of the Maltese Islands which calls for:

• The protection of the Maltese Landscape according to a hierarchy of importance. In this respect it is noted that although the landscape of the Application Site is not protected, it may impede views across it to Areas of Very High Landscape Sensitivity… Long distance views to and from these areas should be strictly safeguarded;

• Sensitive contextual development along urban fringes, especially where these coincide with ridge area…. Height limitation should be very carefully established in these areas;

Changes in Visual Amenity and their Significance 11.49. The assessment of the impact of the Scheme on the visual amenity of the ZVI takes

account of the scale of change resulting from the Scheme, the degree of contrast or integration resulting from the change, the duration and nature of the effect, the angle of view in relation to the main activity of the receptor, the distance of the viewpoint from the Scheme, the extent of the area over which the changes would be visible, and the number of people who may experience the views. The changes in visual amenity and the significance of those changes are described below for each of the viewpoints previously agreed with MEPA. Table 11.3 describes the attributes of each viewpoint.


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Viewpoint 1: Ghadira Promenade

Figure 11.5: Viewpoint 1 before and after the Scheme Viewpoint 1

Date: 13th November 2007, camera at 1.7m.

Location Ghadira Promenade

Key features

Panoramic view of the southern shore of Ghadira Bay and the promenade towards Application Site. Mixed urban and rural scene; the beach is largely obscured by structures on the beach (beach concessions). Hotel and other urban development in mid ground, framed by higher ground of Mellieha Ridge and Mellieha village. Moderate to low visual amenity, moderate to low intrinsic value.

Sensitive receptors

Beach users and tourists. A considerable number of people use the beach in Summer (over 2000 on a Sunday in July 2004), some of which would pass along this section of the promenade. A similar view would be available to drivers.

Change to Visual Amenity

Decrease in the area of hillside visible behind the RIU Seabank Hotel.

Impact A moderate change affecting a reasonable number of mostly

low sensitivity viewers and some moderate and high sensitivity viewers. Impact: Minor to major.

z


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Viewpoint 2: Mellieha Bypass

Figure 11.6: Viewpoint 2 before and after the Scheme Viewpoint 2 Date: 13th November 2007, camera at 1.7m. Location Mellieha Bypass

Key features This is a panoramic view looking over Ghadira Bay. The RIU Seabank Hotel (and to a lesser extent other urban development) blocks the view over the Bay. The view supports a number of landscape elements, including agricultural uses, the Mellieha Bay Hotel, and the Bypass. Moderate to high visual amenity, moderate to high intrinsic value.

Sensitive receptors

Road users. Substantial numbers of low sensitive viewers.


The Scheme increases the building mass and further blocks the view towards the Bay.

Impact A minor to moderate change affecting a substantial number

of low sensitivity viewers. Impact: Minor to Major significance


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Figure 11.7: Viewpoint 3 before and after the Scheme Viewpoint 3 Date: 13th November 2007, camera at 1.7m. Location Triq il-Marfa, Mellieha

Key features This is a panoramic view looking along Triq il-Marfa towards the Scheme, which is largely obscured by urban development. Land uses to the left of the photo are predominantly rural. Moderate to low visual amenity, low intrinsic value.

Sensitive receptors

Road users. Low numbers of low sensitive viewers.


The Scheme adds more buildings and in so doing blocks distant views to the skyline.

Impact A major change affecting a moderate number of low

sensitivity viewers (road users). Impact: Minor significance


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Viewpoint 4: Red Tower

Figure 11.8: Viewpoint 4 before and after the Scheme Viewpoint 4 Date: 13th November 2007, camera at 1.7m. Location On the steps of the Red Tower.

Key features This is a panoramic view looking over Ghadira beach and valley. The latter accommodates agricultural land uses, the marshland / sanctuary and clusters of development. The urban sprawl of Mellieha village is also apparent. High visual amenity, high intrinsic value.

Sensitive receptors

Cultural sight seeing–tourists. Moderate numbers of moderate to low sensitive viewers.


The Scheme adds more buildings at the terminus of the urban area. It extends the urban area further into the rural area.

Impact A minor change affecting a moderate number of moderate to

low sensitivity viewers. Impact: Minor significance


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Figure 11.9: Viewpoint 5 before and after the Scheme Viewpoint 5 Date: 15th November 2007, camera at 1.7m. Location Triq il-Marfa,, near northern end of Ghadira beach.

Key features This is a panoramic view looking across Ghadira Bay towards the Scheme. Most of the beach is visible. The distant shore of the Bay is built up; buildings of up to 5 storeys define the edge. The RIU Seabank Hotel is difficult to pick out; the north facing façade is practically always in shade Moderate visual amenity, moderate intrinsic value.

Sensitive receptors

Road users. Substantial numbers of low sensitive viewers.


The Scheme adds more buildings to marginally further obscure the distant views of the backdrop.

Impact A minor change affecting a substantial number of low

sensitivity viewers. Impact: Minor significance


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Figure 11.10: Viewpoint 6 before and after the Scheme Viewpoint 6 Date: 16th December 2007, camera at 1.7m. Location Mellieha Bypass

Key features This is a panoramic view looking towards Ghadira Bay and the Application Site during the night. The area is well lit: the principal fesatures are the Mellieha Holiday Centre, the Mellieha Bay Hotel, the RIU Seabank Hotel and Triq il-Marfa with street lighting and car lights Low visual amenity, low intrinsic value.

Sensitive receptors

Road users. No data is available regarding the numbers of road users at night, although they would all be regarded as low sensitive viewers.


The Scheme adds more buildings to the right of the RIU Seabank Hotel, thus extending the area of illuminated buildings.

Impact A minor change affecting a low number of low sensitivity

viewers. Impact: Not significant


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11.50. The impact of the Scheme on the visual amenity of the areas portrayed in the above photographs and photomontages from the agreed viewpoints is largely of minor significance. Such impacts are by-and-large unavoidable given the moderate amenity / intrinsic value and, in one case, a high amenity / intrinsic value of the visual amenity. The potential impact is tempered, however, by the lack of viewers that are usually deemed to be of at least moderate sensitivity.

PROPOSED MITIGATION MEASURES 11.51. It is difficult to mitigate the landscape effects of the Scheme to any greater extent

than the measures already incorporated into the design as the Scheme evolved through the iterative process of this EIA.

RESIDUAL IMPACTS 11.52. The residual impacts would be the same as the unmitigated impacts.

FUTURE MONITORING REQUIREMENTS 11.53. Nil.


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Table 11.5: Summary of Impacts on Landscape and Visual Amenity

Nature, Scale and Type of Impact Policy Importance Probability of impact occurring




Impact

Asset Impacted

Beneficial/ Adverse

Const’n /

Oper’n

Extent of impact

(Nat/Local/Site)

Extent of impact

(Nat/Local/Site)

S term/

L term

Perm/ Temp

Reverse/ Irrevers. (Inter/National/Local)

(Likely, Unlikely, Remote

Uncertain)

(Major, Minor, Not

significant)

(Major, Minor, Not

significant) Impact on Landscape Change in landscape character Character Area 1: Southern Ridge (Mellieha Ridge)

Neutral Oper’n Local Direct L term

Perm Revers. Local Likely Not significant

None Not significant


Adverse Oper’n Local Direct L term

Perm Revers. Local Likely Minor None Minor





Character Area 4: Northern Valley









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Nature, Scale and Type of Impact Policy Importance Probability of impact occurring




Impact

Asset Impacted

Beneficial/ Adverse

Const’n /

Oper’n

Extent of impact

(Nat/Local/Site)

Extent of impact

(Nat/Local/Site)

S term/

L term

Perm/ Temp

Reverse/ Irrevers. (Inter/National/Local)

(Likely, Unlikely, Remote

Uncertain)

(Major, Minor, Not

significant)

(Major, Minor, Not

significant) Impact on Visual Amenity Viewpoint 1: Ghadira Promenade

Adverse All Local Direct L term

Perm Revers. Local Likely Minor to Major

None Minor to Major



Perm Revers. Local Likely Minor to Major

None Minor to Major

Viewpoint 3: Triq il-Marfa, Mellieha






Viewpoint 5: Triq il-Marfa (north bay)



Viewpoint 6 Mellieha Bypass (night)




PPA 00720/05: Extension to the Seabank Hotel: Environmental Impact Statement

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12. AIR QUALITY AND CLIMATE CHANGE

INTRODUCTION 12.1. The purpose of this chapter is to assess the impacts of the Scheme on air quality and

climate change.

12.2. The potential key issues associated with the Scheme are outlined below:

Key Issues

• Effects of emissions arising from construction of the Scheme on sensitive receptors

• Effects of emissions arising from the operation of the Scheme on sensitive receptors

• Effects of the operation of the Scheme on climate change


1.2 A Description of the Physical Characteristics and Features of the Project including Constructional Features of the Project

1.2.10 Given that the proposal may, directly or indirectly contribute to Greenhouse Gas (GHG) emissions67, the following should be submitted:

a) an estimate of the expected annual and total GHG emissions during the construction, operation and decommissioning phases of the proposal;

b) the proposal’s contribution to total national GHG emission on an annual basis; and

c) the intensity of GHG emissions.


This description is identified by area of influence for each relevant parameter. The area of influence for each parameter shall be determined

67 Note: Given the absence of local guidelines on climate change it is recommended to use ‘Incorporating Climate Change

Considerations in Environmental Assessment: General Guidance for Practitioners’ prepared by the Canadian Federal-Provincial-Territorial Committee on Climate Change and Environmental Assessment (available on http://www.ceaa-acee.gc.ca/012/014/climatechange_e.pdf)

http://www.ceaa


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by the consultants who shall also justify the extent of the chosen area of influence. This must be approved by the Malta Environment & Planning Authority prior to commencement of the EIA. This description should include:

2.8 Air Quality

This section shall clearly establish the current background levels of pollution, including dust and comparison to the limit values as specified in EU legislation. Details on prevailing wind and climate conditions shall also be included, amongst other relevant parameters.


All significant impacts of and risks posed by the proposed project, during demolition, construction and operation should be assessed, given the environmental characteristics of the site outlined in Sections 1 and 2 and the policies outlined in Section 3. A descriptive and quantitative analysis (including significance, magnitudes and timing) of the impacts of the proposed development should be made, and presented in summary chart format. The various techniques, methods and assumptions used in the analysis and predictions should be outlined. It is recommended that impact assessment should include:

(i) description of impact;

(ii) magnitude and significance;

(iii) duration (temporary and permanent);

(iv) extent (in relation to site coverage and surroundings and associated features);

(v) whether direct or indirect;

(vi) adverse or beneficial;

(vii) reversible or irreversible effects of the impact and extent of irreversibility as well as a description of any associated conditions / assumptions for irreversibility;

(viii) sensitivity of resources to impacts;

(ix) probability of impact occurring;

(x) confidence levels/limits to impact prediction;

(xi) scope of mitigation / enhancement; and

(xii) residual impacts.


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4.8 Impact On Air Quality

The impacts on air quality should include impacts of the construction and operation of the project as well as the impact on the environment from increased traffic.

4.12 Climate Change

GHG Impacts

The proposal’s direct, indirect and off site GHG emissions and related impacts should be identified during all phases and for all element of the proposal. The impacts of the proposal on carbon sinks (e.g. impact on forests, agricultural soils, landfills or wetlands and marine environment) or large GHG emissions, which are the consequence of accidents or malfunctions, shall be identified.

Impacts of CC on the proposal

The phases or elements of the proposal that are sensitive to variations in or changes to specific climate parameters (e.g. precipitation, wind, water levels, temperature, humidity, etc.) should be identified. The potential impacts that these changes may have on elements of the proposal shall be identified including the possible impacts resulting from changes to multiple parameters.

The adaptability of the Project in the event the region’s climate changes shall be discussed.

ASSESSMENT METHODOLOGY 12.4. Two sets of emissions are pertinent to the development of the Scheme:

• Traffic emissions resulting from construction and operation; and

• Dust emissions resulting from construction and operation.

Traffic Emissions 12.5. Traffic emissions are principally associated with operational traffic, that is, cars used

by employees and goods vehicles servicing the hotel, guests’ cars and the traffic already on the network, which is not associated with the hotel extension.

12.6. Traffic emissions are considered negligible and are therefore scoped out of the assessment. The rationale is provided below.


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Dust Emissions 12.7. Although dust emissions from Application Sites should ideally be determined in

respect of background concentrations of dust (mg/m3) and dust deposition (mg/m²/day), the collection of dust data and estimation of dust entrainment present considerable difficulties, as acknowledged by MEPA in respect of a number of EIAs and other studies prepared by the consultants in the past.68 Assessment of dust emissions requires long term atmospheric dust concentration and deposition data; such data are not available for monitoring points in the general vicinity of the Application Site.

Area of Influence

12.8. Taking into consideration current MEPA thinking to secure a 100m buffer around quarries (for example see the Central Malta Local Plan), and on the basis that previous studies69 have shown that the majority of softstone particulate emissions from a softstone crusher were deposited within 100 metres of the emission source, an A of I of 100 metre radius around the Application Site would be appropriate. Such an Area of Influence would account for most of the dust emissions escaping from the site. It is noted that this is a worse case scenario as the Scheme is located in Upper Coralline Limestone70. The remaining emissions, i.e., those carried by high winds, would be indistinguishable from those lifted from the surrounding fields and from the beach in the vicinity, and should not be accorded significance in determining the A of I.

12.9. Figure 12.1 shows that there are no urban areas within 100 metres of the prevailing North West wind. The nearest residential area to the south-east of the Site (i.e. an area that could be affected by the prevailing winds), lies over 400 metres away.

Objectives of Assessment 12.10. The objectives of the air quality study are to:

• Describe the traffic emissions from the Application Site in terms of source, type, and quantity during construction and operation, and assess their impacts on air quality;

• Assess the impacts of the development on air quality-related sensitive receptors;

• Assess the impacts of the development on climate change; and

• Propose mitigation measures to reduce the impact of emissions arising from the Application Site.

68 EIAs / studies prepared by Adi Associates Environmental Consultants Ltd for PA 1191/05, PA 03794/04, PA

00451/00, PA 00997/01, PA 01517/02, PA 04591/00, PA 2662/00 etc. 69 Environmental Planning Statement: PA5616/01 To sanction a softstone crusher and a concrete block making machine

at Triq il-Belt Valletta, Mqabba, Planning Services Consultancy 2003. 70 Dust particles from Coralline Limestone are larger than those from Globigerina Limestone.


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Competence of Surveyor 12.11. The air quality and climate change assessment was carried out by Adi Associates

Environmental Consultants Ltd.

Standards and Guidance 12.12. Guidance on air quality in the Maltese context is available in the following national

legislation:

• Legal Notice 224 of 2001 (as amended by L.N. 231/2004): Limit values for Sulphur Dioxide, Nitrogen Dioxide and Oxides of Nitrogen, Particulate Matter and Lead in Ambient Air Regulations, 2001;

• Legal Notice 295 of 2007: Environmental Management Construction Site Regulations, 2007.

12.13. This legislation has been assessed in detail in Chapter 6.

12.14. Dust-related nuisance is assessed against the average PM10 24-hour limit value for the protection of human health as set under LN 224/2001 at 50µg/m3, which is not to be exceeded more than 35 times in a calendar year. The average annual limit value for the protection of human health is 40µg/m3. Both of these standards were to be met by 1st January 2005. By 2010, the 24-hour limit is not to be exceeded more than 7 times in a year, and the annual limit is reduced to 20µg/m3 PM10.

12.15. Neither the EU nor Malta has legislation governing the deposition of dust from construction operations. MEPA’s Minerals Subject Plan includes policies on dust amelioration related to quarry operations. These include sheeting HGVs, wheel washing, and surfacing / sweeping / watering of internal haul roads, siting of plant and stockpiles (Policies DC15 and DC18 refer.) The Environmental Management Construction Site Regulations include similar provisions.


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Figure 12.1: Distance of nearest residential area affected by the NW wind


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BASELINE AIR QUALITY 12.16. For air quality, data were obtained from MEPA’s on-going air quality monitoring. The

data are presented in the State of the Environment Report, 2005 and can be accessed from MEPA’s website.71

12.17. Principal emissions arising from traffic are carbon monoxide (CO), nitrogen oxides (NOx), Volatile Organic Compounds (VOCs), particulates, 1,3-butadiene, and lead (Pb)72. Increased use of unleaded petrol has meant a decline in lead pollution from petrol in recent years. Dust will arise during demolition and construction of the Scheme.

MEPA Data 12.18. The State of the Environment Report (SoER) provides data for localities for the

following parameters – sulphur dioxide (SO2), NO2, benzene and ozone. Ozone in Malta occurs mainly from transboundary sources and SO2 from power stations. Therefore, the study of ozone and sulphur dioxide has no direct relevance to the Scheme and will not be considered further.

12.19. Although the SoER also provides data for particulate matter concentrations from two fixed monitoring stations in Floriana and Kordin, such data are not considered relevant to this Study as the Application Site is located in a rural area. Traffic is not as intense in the area especially during the winter months and during the week in summer.

12.20. MEPA set up a diffusion tube network in 124 locations located in 31 towns and villages across Malta and Gozo to monitor emissions of SO2, NO2, and ozone. The majority of the sampling locations were set up in the Northern and Southern Harbour districts.

12.21. Sampling was carried out between January 2003 and December 2005. Diffusion tubes were replaced on a monthly basis. Each used tube was analysed in the UK.

Results

12.22. The annual average concentrations recorded by the Diffusion Tube Network for Mellieha are available. The data for Mellieha are included in Table 12.1.

71 www.mepa.org.mt 72 Harrop, 2002, Air Quality Assessment and Management – A Practical Guide; Spon Press.

http://www.mepa.org.mt


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Table 12.1 Annual average concentrations for Mellieha 2003-2005

Results NO2/ µg/m3 Benzene/ µg/m3

2003 15.72 4.42

2004 14.97 2.60

2005 18.02 1.93

Limit value according to Directive 99/30/EC for SO2 and NO2; Limit value according to Directive 2000/69/EC for benzene

40 5

Source: State of the Environment Report, 2005 found at www.mepa.org.mt

12.23. The data shows that the values obtained in this area are well below the limit values. For the purposes of this assessment these values will be used to assess the impacts on air quality at the Application Site. No data is available for PM10.

ASSESSMENT OF IMPACTS 12.24. The Terms of Reference require the assessment to consider impacts on climate

change and on air quality.

Climate Change 12.25. In the absence of national guidance on the assessment of the impacts from

developments on climate change MEPA recommended the use of a Canadian guidance document, Incorporating Climate Change Considerations in Environmental Assessment: General Guidance for Practitioners73. This document assists practitioners in scoping the assessment from two perspectives:

• Greenhouse Gas (GHG) considerations: where a proposed project may contribute to GHG emissions; and

• Impacts Considerations: where climate change may affect a proposed project.

12.26. The first step of the assessment involves scoping: Preliminary scoping for GHG considerations and preliminary scoping for impacts considerations. Annexes are provided to assist practitioners.

Scoping for GHG considerations

12.27. Reference is made to Table A.1 of Annex I where examples of projects that can lead to high, medium, or low GHG emissions are given. The project types included are coal-fired generation plant, large scale manufacturing including electricity generation

73 The Federal-Provincial-Territorial Committee on Climate Change and Environmental Assessment, 2003,

Incorporating Climate Change Considerations in Environmental Assessment: General Guidance for Practitioners.

http://www.mepa.org.mt


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plants, large scale changes to land use / settlements including forest harvesting and flooding. The project consists of an extension of an existing hotel that will generate some GHG emissions but not at the scale mentioned in the Annex. On this basis, GHG emissions will be estimated, however it is beyond the scope of the environmental assessment to proceed further into the assessment.

Scoping for Impact considerations

12.28. As elsewhere in the Mediterranean, both Malta and Cyprus can expect to be increasingly vulnerable to flash floods arising from more frequent extreme rainfall events, from more intense Mediterranean storms, and from beach erosion due to increased wave heights and rising sea levels74.

12.29. Although the Scheme is located in a low-lying area and may therefore be sensitive to sea level rise, it is above sea level. The coast road in front of the hotel acts as a seawall. Sea level rise is likely to negatively affect the Ghadira sandy beach as the beach cannot retreat naturally because of the road. The development may also be sensitive to temperature variations especially temperature increases – these will necessitate more intensive use of air conditioning during hot periods.

GHG emissions

12.30. The electricity requirement for the Scheme is estimated at 1,000 kVA split as follows:

• 550 kVA of A/C power: An average consumption of 3 hours/day in winter75 and 12hrs/day in summer

• 100 kVA for Plant: An average consumption of 16 hours/day.

• 350 kVA for general: An average of 8 hours/day lighting & power.

12.31. Based on the above, winter consumption is 4,848 kWh / day and summer consumption is 10,120 kWh / day76.

12.32. Based on the above, annual consumption in kWh is as follows:

(4,848 kWh / day x 151 days) + (10,210 kWh / day x 214) = 2,916,988 kWh or 2,917 MWh

12.33. This consumption translates into 2,557 tonnes of carbon dioxide emissions77 per annum.

12.34. Malta’s National Allocation Plan78 quantifies electricity generated from the Marsa and Delimara power stations and the carbon dioxide emissions. Power generation in

74 Future Climate Change Policy in Cyprus, Hungary, Malta and Slovenia Workshop in Ljubljana, 11 October

2006. 75 Assumed to be November to May. 76 Communication from Ing Joe Muscat, project engineer dated 19th August 2008. 77 Emission factor from MEPA, 2007, National Allocation Plan for Malta 2008-2012 78 MEPA, 2007, National Allocation Plan for Malta 2008-2012


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2005 was 2,263, 424 MWh with carbon dioxide emissions reaching 1,983,806 tonnes. The electricity consumption at the Scheme (2,917 MWh) represents 0. 1% of the total annual consumption based on 2005 figures. In terms of CO2 emissions this is 0.1% of annual CO2 emissions.

12.35. Considering these emissions and noting the Canadian Guidance Note and what that document considers as high emitters (large scale industry and electricity generation plants) and also noting that consumption is <1% of annual generation, the impact of the Scheme on climate change is not considered to be significant.

12.36. Emissions from traffic generated during operation could not be estimated because this would depend on distances travelled.

12.37. As discussed in Chapter 4 measures to reduce energy demand include:

• Energy saving lamps;

• Power factor correction units;

• Sea water cooled chiller with a Co-efficient of Performance of 3.6;

• Heating by light heating fuel oil;

• Guestroom management systems;

• RO system for the production of water; and

• Cold water feed to calorifier through solar panels.

12.38. Furthermore, the principal axis of the new extension is primarily North-West, with only a small part of the hotel facing South. The proposed elevations consist of arched vault-like structures which create shade and the majority of the new rooms will face north-west, thereby allowing wider openings without causing overheating in summer. The building will include thermal insulation on all roofs and terraces and double-glazed windows will be used throughout. The “pyramidal” design of the extension also permits the utilisation of the dead core space above ground level for car parking, thereby reducing the excavation footprint, and placing the rooms on the outside, where natural lighting is readily available. Further reduction in energy demand has been achieved by placing the car parking above ground level and therefore doing away with the need for forced mechanical ventilation.

Air Quality 12.39. In assessing the significance of the impact of the Scheme on air quality, the following

criteria have been used:

• Not significant: no or little change to the current levels of the measured pollutants at the sensitive land uses;


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• Minor significance: an increase in the levels of the measured pollutants at the sensitive land uses, but less than the Air Quality Standards; and

• Major significance: an increase in the levels of the measured pollutants at the sensitive land uses that exceeds the Air Quality Standards.

12.40. The potential impacts of the Scheme on the sensitive receptors in the A of I are likely to include:

• Impact of dust emissions on sensitive receptors during construction (including demolition); and

• Impact of emissions from vehicles on sensitive receptors during operation.

Construction

12.41. The main emissions during construction are likely to be dust and particulate matter generated during construction, or from the handling of construction materials. Emissions from construction vehicles and equipment are negligible.

12.42. The potential effects of particulates / dust are:

• Visual: dust plume, reduced visibility, coating and soiling of surfaces leading to annoyance, loss of amenity, and the need to clean surfaces; and

• Health effects due to inhalation e.g. asthma, chest infections, or irritation of the eyes.

12.43. A number of other factors, such as the amount of precipitation and other meteorological conditions, will also greatly influence the amount of particulate matter generated. The proposed construction of the extension over the winter period is in fact an important mitigation measure.

12.44. The majority of particles released from construction will be dust particles of diameter >10 µm (as opposed to PM10). Dust particles greater than 10 µm are likely to settle out relatively quickly and may cause annoyance due to their soiling capability. Previous work indicates that the majority of dust emissions typically settle within 100 metres of their source, and research shows that only 10% remain in the air at 400 m away79. There are no formal standards or criteria for nuisance caused by deposited particles, however, a deposition rate of 200 mg/m2/day is often presented as a threshold for serious nuisance, though this is usually only applied to long-term exposure, since people are generally more tolerant of dust for a short or defined period. Significant nuisance is likely when the dust coverage of surfaces is visible in contrast with adjacent clean areas, especially when it happens regularly.

12.45. Emissions of dust from site excavation and construction works are likely to occur during the construction phase.

79 www.le.ac.uk/estates/masterplan/12.%20Air%20Quality.pdf

http://www.le.ac.uk/estates/masterplan/12.%20Air%20Quality.pdf


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12.46. Excavation of the Application Site and construction of the extension to the Seabank Hotel is anticipated to take 6 months. Excavation will be carried out over 2 months and construction will take three and a half months. Finishing works are anticipated to take between 2 and 3 months and landscaping the final 6 weeks. The timing of the various activities is described in Chapter 4. The excavation works are planned to commence in November 2008 so that the main dust-generating activities on site will coincide with the wet season, which will help to control dust emissions from the site.

12.47. Excavation shall be carried out by means of heavy duty and medium duty excavators such as rotary trenchers, hi-macs and JCB’s. Excavated surfaces will then be trimmed to the required levels using hand tools.

12.48. The dust generated from clearance, excavation, and construction is likely to escape from it (mainly through entrainment by wind and moving vehicles) and may affect nearby receptors. Figure 12.1 shows that the only nearby receptors in a north westerly direction are farmers; there are no high sensitivity receptors (such as hospitals and schools) in the vicinity. The dust will mainly affect farmers located downwind of the Scheme. Residences are likely to be affected when wind is blowing from a South Westerly direction. Dust will be a nuisance for farmers and residences for a short period. The impact of these dust emissions on sensitive receptors (people) is judged to be of minor significance because of the limited number of sensitive receptors and the limited duration of the impact. It is noted that construction will not take place during the summer months so it is unlikely to affect beach users.

12.49. Effective management and monitoring of dust mitigation measures (see below) would ensure that the potential for dust nuisance for such receptors is minimised.

Operation

12.50. Traffic contributes to emissions in the form of PM10, nitrogen dioxide, and carbon monoxide. The baseline air quality data from MEPA show that the air quality in the area is well below the air quality standard. The annual average shows that notwithstanding the traffic generated during the summer, air quality is still within the standard.

12.51. Traffic emissions during operation are expected to be negligible compared to the traffic passing on the arterial road especially during the summer months. It is noted that the hotel will be providing an additional 200 parking spaces for both staff and residents. The fact that the hotel will be run on an “all-inclusive” basis, the traffic impact is greatly reduced since such guests tend to arrive by coach and stay at the hotel for the entire stay (hence the need for more varied entertainment and facilities on site). Any excursions would normally also be organised and guests leave and return to the hotel by coach. It is estimated that 90% of the guests would not use a private / hired car. The TIS identifies that the influence of the proposed development on the existing network is insignificant, therefore, it can be concluded that the Scheme will not generate sufficient traffic to significantly alter the air quality in the area.


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12.52. Emissions from traffic are also scoped out on the basis of the sensitive receptors in the area. Residences are located over 100 metres away from the Site. There are no major urban uses in the vicinity. In the direction of the prevailing wind the only users are farmers. The impact of traffic on air quality is judged to be of no significance; the scale of the development is such that it is unlikely that traffic generated by the Scheme would result in emissions that would exceed the air quality standards.

MITIGATION 12.53. The works will be undertaken in accordance with the Environmental Management

Construction Site Regulations, 2007, including:

• A site manager will be appointed;

• A site billboard / notice board will be erected;

• Stone cutting will be undertaken in an enclosed area or using a dust extraction and collection system;

• Loose building materials that are to be stored on site will be kept in sturdy, sealable containers;

• Hoardings and barricades will be erected as described in Schedule II, Regulation 6;

• Excavation will be carried out between Monday and Saturday, except public holidays, from 07:00 to 20:30. No excavation is planned for the months of July to September;

• Construction will be carried out on all weekdays, except public holidays, from 07:00 to 20:00, and 07:00 to 13:30 on Saturdays. No construction works are planned for the months of July to September;

• Dust emissions will be controlled as described in Schedule III of the Regulations;

• The Site amenities (site office, waste management areas, storage areas, etc) will be located in a dedicated area on site; and

• Pedestrian and vehicular flow along the surrounding streets will not be interrupted. All excavation and building activity will be set back from street boundaries.

12.54. Schedule III of the Regulations require that the following dust mitigation measures are implemented:

• Application of water or pre-soaking and/or, chemical dust stabilizers or any other appropriate dust control technique, during construction in such a manner as to limit any generation of dust to within the site boundary;

• Prior to leaving the site the owner must, on a daily basis, remove any spillages resulting from the construction activity along or across a public way;


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• Prior to leaving the site, the owner must ensure that on a daily basis public sidewalks and public areas within 10 metres from either side of the extremities of the construction site including sidewalks and roads are swept or vacuumed;

• Paint chips, sanding residue, grit and dust must be prevented from coming into contact with storm-water runoff and surface water bodies;

• Sanding activities must ensure that dust emissions are controlled by equipping all mechanical equipment with dust extraction and recovery systems and for outdoor areas – all areas be totally covered around the whole working area with material that must form a barrier against the emission of dust or particulate matter into the environment and for indoor areas – all external apertures must be boarded with an impermeable material that must form a barrier against the escape of fugitive dust emissions outdoors prior to commencing any sanding operations;

• Mechanical fair facing of building stones is not permitted on site; and

• Adequate facilities and measures must be undertaken to ensure that the site and its immediate vicinity are kept clean at all times during construction.

12.55. The mitigation measures outlined above would, in general, provide sufficient mitigation to reduce the potential short-term impacts of the construction phase of the development. Furthermore, the proposed extension will be constructed as a series of cast in situ concrete flat slabs supported on a series of columns placed on a grid. Internal walls will consist of light weight partitioning to minimize dead weight on the slabs, thus increasing the efficiency of the structure, minimising the need for mechanical fair facing and similar interventions on site, and reducing the construction phase to create fewer disturbances on site.

RESIDUAL IMPACTS 12.56. It is anticipated that there will be residual impacts during the construction phase of

the Scheme (see Table 12.2). This is a temporary impact for the duration of the construction phase. The significance of the residual impact is minor.


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Table 12.2: Summary of Impacts

Predicted Impact Beneficial

/ Adverse

Nature, Scale and Type of Impact Policy Importance



significant)



Impact


Extent of impact (Nat/ Local/ Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers/ Irrevers

(Inter / National/

Local)


Uncertain)

Legislation



Air Quality Impact of dust on users of the Site

Adverse Constr’n Local Direct S term Temp Revers. Local Likely Air quality legislation

Minor Implementation of Environmental Management Construction Site Regulations, 2007

Minor

Impact of vehicle emissions on users of the site

Adverse Oper’n Local Direct S term Temp Revers. Local Likely Air quality legislation

Not significant None Not significant

Climate Change Increased GHG emissions

Adverse Oper’n Local Indirect L term Perm Irrevers National Likely None Not significant Reduce electricity consumption

Not significant


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13. NOISE EMISSIONS AND VIBRATION

INTRODUCTION 13.1. This chapter considers the noise and vibration impacts arising from the construction

and operation of the Scheme. The existing noise climate was established through a baseline noise survey, and the locations of sensitive receptors that may be potentially affected by changes to the noise environment were identified and agreed with MEPA.

13.2. Noise is likely to arise throughout the excavation and construction phases and possibly from the Food & Beverage / Conference-related land uses and traffic during operation. Vibrations are likely to arise during the excavation phase.

13.3. The potential key noise / vibration-related issues associated with the Scheme are:

Key Issues

• Effects of noise on sensitive uses

• Effects of vibration on sensitive uses and structural integrity of buildings and cultural heritage features




2.10 Noise and Vibration

Information on the prevailing background noise levels both in terms of frequency and intensity should be given. This baseline survey should follow parameters given in BS4142:1997. Locations for monitoring background noise should be chosen bearing in mind the following:

o Other existing noise sources in the area, including increase in traffic and congestion in the area;

o Other potential noise sources in the area, including new developments;


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o Sensitive receptors, residential areas, schools, hospitals, etc.;

o Sensitive recreational areas in the vicinity;

o Features that might shield noise, topographical, vegetation, etc.

These locations must be approved by the MEPA prior to commencement of the EIA.


All significant impacts of and risks posed by the proposed project, during demolition, construction and operation should be assessed, given the environmental characteristics of the site outlined in Sections 1 and 2 and the policies outlined in Section 3. A descriptive and quantitative analysis (including significance, magnitudes and timing) of the impacts of the proposed development should be made, and presented in summary chart format. The various techniques, methods and assumptions used in the analysis and predictions should be outlined. It is recommended that impact assessment should include:




viii. sensitivity of resources to impacts; ix. probability of impact occurring; x. confidence levels/limits to impact prediction; xi. scope of mitigation / enhancement; and xii. residual impacts. xiii.



4.7 Noise and Vibrations

This shall include an assessment of maximum noise levels expected to be generated, variations during the day and night and noise attenuation (the reduction in noise levels as a result of ‘environmental’ factors, e.g. mufflers at source, insulation of a building).The effects of noise and vibrations on the surrounding community arising during the demolition, construction and the


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operation of the proposed development shall be assessed. The assessment should also consider road traffic associated with operations on the site. Noise sensitive receptors should be identified and agreed with MEPA. It is recommended that BS4142:97 is used for the noise assessment and BS6472 (relating to human exposure to vibration) and BS7385 (covering the effects on buildings) is used when studying vibration.

5.0 Design of Mitigation Measures


This should include a description of the measures envisaged to prevent, minimise and where possible offset any significant adverse effects on the environment of the project during both construction and operational phases (including reference to consideration of alternatives in section 2. above). Such measures should be realistic and could include technological features; alternative technological features; operational management techniques; enhanced site-planning and management; aesthetic measures; conservation measures; reduction of magnitude of project; and health and safety measures.

The mitigation measures are to indicate how the project design shall take into account the need for continuous improvement with respect to GHG emissions.



5.3 Monitoring Framework and Management Plans


Area of Influence

Noise

13.5. The Area of Influence (A of I) was determined on the basis of the results of the noise monitoring survey by taking into account the maximum noise levels predicted to arise


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from the construction and operation of the Scheme and the distance required for the levels to fade to 63dB(A)80 or 3dB(A) above the background levels determined as LAeq60, which ever is the greater.

13.6. The worst-case noise scenario occurs during the excavation of the Application Site when noise levels at source are likely to be at their highest. Assuming no attenuation (worst case), these sound levels are anticipated to reduce to 63 dB(A) at a distance of 1.2 kilometres from the centre of the Application Site for excavation and 400 metres for construction. However, since the noise levels at monitoring Point B are currently 69dB(A) LAeq60, reflecting the traffic on Triq il-Marfa and the Mellieha Bypass, such levels are likely to pertain along the length of the arterial the crosses the Bay. It would be appropriate to set the radius of the A of I to correspond with the distance that it takes for 119 db(A) (which results from hydraulic hammer operation) to decay to 72dB(A) – a distance of approximately 600 metres in a free field situation. Taking account of the potential effects of the terrain and other buildings in the area, the A of I is depicted in Figure 13.1.

Vibration

13.7. Vibration levels resulting from construction activities are dependent on ground conditions, underlying geology, and upon foundations and the techniques used to excavate or construct a building. It is stated in BS 5228: Part 4, that the threshold for vibration perception for humans is ”…typically in the peak particle velocity range of 0.15 mm/s to 0.3 mm/s at frequencies between 8 Hz and 80 Hz. Vibration levels above this value can disturb, startle, cause annoyance, or interfere with work activities. At higher levels they can be described as unpleasant or even painful”.

13.8. Table 13.1 details distances at which certain construction activities give rise to a level of vibration that is just perceptible; it is based on BS 5228 and other studies81.

Table 13.1: Construction vibration levels Construction Activity Distance from activity when vibration may

just be perceptible (metres) Excavation 10-15 Hydraulic breaker 15-20

13.9. Such distances assume no mitigation measures that would interrupt the vibration path. The separation of the Application Site excavation from the surrounding rock by way of a trench will effectively stop the transmission of vibrations through the bedrock that would detrimentally affect buildings. (See Chapter 7.)

80 PPG24 Annex 1 indicates that the free-field level at the boundary between NEC B and NEC C should be

63dB(A). NEC = Noise Exposure Category. NEC B is where noise should be taken into account when determining planning applications and, where appropriate, conditions imposed to ensure adequate protection against noise. NEC C is where planning permission should not normally be granted. 63dB(A) is equivalent to the noise level arising from conversational speech or in a business office.

81 Lammas Road Environmental Statement, www.ashfield-dc.gov.uk/nalc/ docs/Chapter%208%20-%20Noise.pdf, accessed on 3rd April 2006.

http://www.ashfield-dc.gov.uk/nalc/


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13.10. The A of I for impacts on humans is, therefore, taken to be the maximum distance where vibration is just perceptible, that is 20 metres from the boundary of the Site. Since there are no vibration sensitive uses within that distance, the A of I has not been plotted.

Figure 13.1: Area of Influence: Noise


Noise 13.11. The purpose of the noise assessment, on the basis that excavation deploys the

techniques described in Chapter 4, was to determine the change in background noise levels as a result of the Scheme, and the possible impacts on noise sensitive receptors in the Area of Influence.

13.12. The subjective significance of a change in noise levels is generally related to the magnitude of that change. The significance of the change is also related to the number of people affected. Studies82 have shown that changes in broadband continuous noise, such as traffic noise, are not generally distinguishable until the

82 Department of Transport, Manual of Environmental Appraisal, London: HMSO, 1983.


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change is of at least 3dB, while a change of 10dB represents a doubling of loudness. Changes of less than 3dB are not, therefore, generally considered to be significant, although it should be recognised that such imperceptible changes can lead to a gradual deterioration in the quality of the environment, if further development occurs.

Vibration 13.13. This Chapter assesses the impact of vibrations on the integrity of buildings and

human beings. As described above, levels of vibration above a PPV of 0.3 mm/s are considered to disturb people, although at that level they will certainly not damage buildings.

Standards and Guidance 13.14. Although guidance on environmental noise in the context of planning is not available

specific to the situation in Malta, the ToR require that the noise assessment is carried out in accordance with BS 4142:199783. In addition to reference to the aforementioned British Standard, the noise assessment also has regard to BS 522884 and the UK Government Planning Policy Guidance Note, PPG24, Planning and Noise85.

13.15. Various types of noise are considered in PPG 24, including transportation noise and noise from industrial or commercial developments, recreational activities, and waste disposal sites. For construction noise and vibration, PPG 24 refers to the British Standard BS 5228.

13.16. The survey to establish the current noise climate of the area was carried out in accordance with BS 4142:1997.

13.17. Since guidance on vibrations in the context of planning specific to Malta is not available, British Standards are used. Vibration can be expressed in terms of displacement, velocity, or acceleration, each of which varies with frequency and time. Peak Particle Velocity (PPV) is often used to assess damage risk in buildings as it correlates best with case history data and is usually measured in mm/s.

13.18. British Standard 7385: Part 2: 1993 ‘Evaluation and measurement for vibration in buildings – Guide to damage levels from ground borne vibration’ gives the limit values for transient vibration, above which cosmetic damage86 would occur; these are presented

83 BS 4142:1997, Method for rating industrial noise affecting mixed residential and industrial areas, British

Standards Institution. 84 BS 5228: 1997, Noise and vibration control on construction and open sites, British Standards Institution. 85 Department of the Environment (UK), Planning Policy Guidance PPG 24, Planning and Noise, The

Stationery Office, 1990. 86 BS 7385: Part 1: 1990 ‘Evaluation and measurement for vibration in Buildings – Guide for measurement of

vibrations and evaluation of their effects on buildings’ defines cosmetic damage as “the formation of hairline cracks on drywall surfaces, or the growth of existing cracks in plaster or drywall surfaces; in additional the formation of hairline cracks in mortar joints of brick/ concrete block construction”.


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in Table 13.2. Minor damage87 is possible at vibration magnitudes which are greater than twice those given in Table 13.2 and major damage88 to a building structure may occur at values greater than four times the tabulated values.

Table 13.2: Transient vibration guide values for cosmetic damage Type of building Peak component particle velocity in frequency range of

predominant pulse Unreinforced or light-framed structures such as residential or light commercial type buildings

15mm/s at 4 Hz increasing to 20 mm/s at 15 Hz

20 mm/s at 15 Hz increasing to 50 mm/s at 40 Hz

13.19. For continuous vibration, the guide values given in Table 13.2 should be reduced by 50%; cosmetic building damage could occur in residential or light commercial type buildings where levels of vibration above 7.5 mm/s from 4Hz upwards are measured89. It is noted that MEPA uses 8 mm/s as the cut-off limit for blasting vibration from quarries.90

13.20. MEPA makes reference to BS 6472:1984 when monitoring vibrations from excavations from neighbouring properties. This Standard assigns a threshold value of 0.3 mm/s for vibrations that are perceived by humans and peak particle values of between 12 to 19 mm/s as the threshold for cosmetic damage to buildings. These values are similar to those used in this assessment and those contained in BS 7385: Part 2: 1993.

Survey Methodology 13.21. In order to determine the baseline noise levels at the site, Mr. John Demanuele of

Mediterranean Technical Services Limited carried out a noise survey. The monitoring locations were at the nearby Mellieha Holiday Centre, and across the road from the existing hotel in close proximity to the nearest residents, as agreed with MEPA (see Figure 13.2). The reasons for selecting the locations are summarised later in this Chapter.

Field Survey

13.22. The baseline daytime noise surveys were undertaken on Friday 7th December 2007. Night time studies were carried out on Tuesday 18th December 2007, starting at 22:28. The daytime monitoring period lasted for sixty minutes at each of the monitoring points (marked ‘A’, and ‘B’ on Figure 13.2) and the evening monitoring was 5 minutes at each of the monitoring points, both in accordance with BS 4142:1997.

87 BS 7385: Part 1: 1990 defines minor as the “formation of large cracks or loosening and falling of plaster or drywall

surfaces, or cracks through brick / concrete blocks”. 88 BS 7385: Part 1: 1990 defines major as “damage to structural elements of the buildings cracks in support columns,

loosening of joints, splaying of masonry cracks, etc.”. 89 The Standard notes that there are insufficient cases where continuous vibration has caused damage to

buildings to substantiate the guide values; the latter are based on common practice. 90 Minerals Subject Plan.


272

Noise Monitoring Equipment

13.23. Measurements and procedures were undertaken in accordance with BS 4142:1997, and the instrument was calibrated in accordance with BS 4142:1997.

13.24. Noise measurements were undertaken using a ‘QUEST’ integrating, logging, sound level meter (model: 2900), and a ‘QUEST’ Calibrator (model: QC-20).

13.25. The sound level meter was calibrated before each set of measurements in accordance with BS 4142:1997 Para 5.1, and at each monitoring point it was placed on a tripod stand 2.3 metres off the ground in order to avoid reflections from nearby objects.

Measurements

13.26. The following measurements were recorded:

• LAeq - the ‘A’ weighted average or residual noise;

• Lmax and LA10 (usually used to assess traffic noise); and

• LA90 - to indicate the background noise condition.

13.27. Paragraphs 5.1 to 5.5 of BS 4142:1997 give guidelines on measurement practice that were followed during the survey. In brief, these require calibration of the instrument and give guidelines in choosing measurement locations as well as on taking precautions against interference with the measurements, particularly from inclement weather.

DETERMINING IMPACT SIGNIFICANCE

Noise 13.28. The following criteria have been used to assess the significance of impacts of the

Scheme on the noise climate of the Area of Influence:

• Not significant (e.g. no material change in noise climate - a change of less than 3dB to the background noise levels);

• Minor significance (e.g. a change between 3 and 10dB to the background noise levels - such a change would be noticeable but would not usually give rise to widespread complaints);

• Major significance (e.g. a change of 10dB or higher to the background noise levels as predicted at the noise sensitive receptor - such a change is likely to adversely affect the sensitive noise receptors in the vicinity of the site, and give rise to widespread complaints).

13.29. Table 13.3 provides an indication of the loudness of sound pressure levels measured in dB(A), in order to give an idea of typical noise levels.


273

Table 13.3: Equivalent dB(A) levels Noise environment Typical dB(A) Library 30 to 35dB(A) Living room 40 to 45dB(A) Office 60 to 65dB(A) Heavy road traffic 75 to 80dB(A) Pneumatic drill 100dB(A)

Source: Bruel & Kjaer chart

Vibration 13.30. The following criteria have been used to assess the significance of vibrations on the

sensitive receptors of the Area of Influence:

• Not significant - no damage to buildings and no change to the structural integrity of the buildings and other structures; vibration levels not perceivable (PPV is less than 0.15 mm/s at the sensitive receptors);

• Minor significance - cosmetic damage to buildings and other structures but no change to the structural integrity of the buildings; vibration levels are perceivable for a long period of time (PPV would be between 0.15 mm/s and 0.3 mm/s - such levels would not usually give rise to complaints);

• Major significance - minor to major damage to buildings and other structures91; vibration levels are disturbing (PPV would be greater than 0.3 mm/s - such levels are likely to give rise to complaints).

91 The definition of cosmetic, minor, and major damage is given in subsequent paragraphs when discussing the

impacts of the construction on the stability of surrounding buildings.


274

Figure 13.2: Location of Noise Measurement Points


275

BASELINE CONDITIONS: NOISE

Noise Measurements 13.31. The two locations at which measurements were taken are shown on Figure 13.2.

Table 13.4 indicates why each location was chosen. The full results of the survey are provided in Technical Appendix 6: Noise Baseline Survey and a summary is provided in Table 13.5.

Table 13.4: Location of noise monitoring points Location Description A, Mellieha Holiday Centre

This point was chosen to represent the noise climate at the north of the Application Site; it is situated at the point of the noise sensitive users at Melliha Holiday Centre – pool users. It is screened from traffic noise generated by the arterial road to the east by MHC buildings.

B, Nearest residential uses

This location is at the edge of the nearest residential use zone. It is sited to gauge the noise levels from the Scheme and the junction of Triq il-Marfa and the Mellieha Bypass.

13.32. The survey showed that the background noise level measured at the two noise monitoring points is 49 - 50 dB(A) (LA90) during day light hours, and 37 - 41dB(A) (LA90) at night time.

Table 13.5: Summary of survey results

Location Period LAeq60 LAmax LA10 LA90 Predominant noise source

07/12/2007 10:34 to 11:34 52 74 54 49 Distant traffic A, Mellieha

Holiday Centre

19/12/2007 22:28 to 22:33 43 55 46 37 Distant traffic

07/12/2007 11:48 to 12:48 69 93 70 50 Traffic & sea B, Nearest

residential uses 19/012/2007

22:40 to 22:45 44 56 47 41 Passing traffic

Key Receptors 13.33. For the purposes of assessing the impacts of noise, the noise sensitive receptors are

considered to be any domestic premises, hotel, hostel, temporary housing accommodation, hospital, medical clinic, educational institution, place of public worship, library, court of law, or performing arts centre. Additionally, workers on the Application Site and nearby, pedestrians and patrons of businesses in the area, are also relevant. On this basis the noise sensitive receptors in the vicinity of the Scheme have been identified as:

• Users of the Mellieha Holiday Centre;

• Residents of the dwellings to the east of the Scheme; and

• Recreational users at the beach and nearby restaurants and visitors to il-Hofra salt marsh.


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BASELINE CONDITIONS: VIBRATION 13.34. Baseline vibration measurements were not undertaken for this particular assessment

as this was not required by the Terms of Reference and was considered not to add value to the assessment. However, in the absence of construction activities on the site, ambient vibration levels are anticipated to be typical for an urban location.

IMPACT ASSESSMENT: NOISE

Potential Impacts 13.35. The potential impacts associated with the Scheme include:

• Noise disturbance to the residents in properties to the east of the Scheme during excavation, construction, and possibly operation;

• Noise disturbance to the users of the Mellieha Holiday Centre; and

• Noise disturbance to recreational users of the beach, restaurants and promenade, and visitors to il-Hofra salt marsh.

Prediction and Significance of Impacts 13.36. The noise sources during the construction of the Scheme are:

• Plant used in the clearance and excavation of the Application Site, including shovels, excavator-mounted pneumatic breakers and hand held pneumatic drills, air compressors, drilling rig, trencher, and HGV haulage; and

• Plant used in the construction of the foundations and building, including tower cranes, concrete pumps, concrete mixer trucks, mobile cranes, generators, welding machines, water tankers, air compressors, bobcats, jumper compactors and HGV haulage.

13.37. The noise sources arising from the operation of the Scheme will depend on the eventual activity mix. They are likely to include climate control plant, recreation noise including entertainment noise, and noise from vehicles.

13.38. Noise emissions from the Application Site are assessed in respect of both excavation and construction activities, and operation. Since excavation and construction will only be undertaken in daylight hours and the existing hotel will be closed for the construction phase, consideration of night time noise emissions are not relevant. Noise emissions resulting from operations are likely to be at their highest in respect of outdoor entertainment. A worst case for operational noise, based on sound from entertainment, is assumed.

Noise levels resulting from construction activities

13.39. Noise resulting from excavation and construction activities is likely to span the construction period of 6 months. The most noticeable will be that which results


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from excavation; such noise being limited to working hours, and for the most part not continuous, and spanning a period of 2 months.

13.40. The level of sound production by construction plant is governed by EU Directive 2000/14/EC and Legal Notice 64 of 2002, which govern the maximum noise emissions in the environment by equipment used outdoors. Equipment sound-power levels must be declared, and quality-control procedures established, to ensure continued compliance with the new legislation. Failure to comply with these Regulations may result in products being prohibited from the EU marketplace. The legislation restricts noise emissions from the type of plant likely to be deployed on the Application Site as set out in Table 13.6. It is also noted that the draft Environmental Management Construction Site Regulations limit noise levels to 110dB, but do not specify whether the level relates to maximum, LAeq, or background levels, nor how the level is to be determined.

Table 13.6: Maximum noise levels for construction plant Permissible

sound power level in

dB/1pW Source Net installed power P (in kW)

From 3 January 2006

Tracked dozers, loaders & excavator loaders

P ≤ 55 103

P > 55 84 + 11 lg P Excavators, builder’s hoists for transportation of goods, construction winches

P ≤ 15 93

P > 15 80 + 11 lg P Hand held concrete-breakers and picks

Mass ≤ 15kg 105

Mass < 15kg < 30kg 92 + 11 lg Mass Mass > 30kg 94 + 11 lg Mass Tower crane 96 + lg P

13.41. The noise performance details set out in Table 13.6 are not comprehensive and, while specifying the maximum permitted levels applicable to new plant, may not reflect the situation in Malta where plant is often purchased second hand and may no longer perform according to the manufacturers specifications. It would be more relevant if the noise assessment took account of the noise levels usually generated by the plant. Sound power levels of used plant deployed in Malta were measured by Mediterranean Technical Services, which supplemented the EU data. These are described in Table 13.7.

13.42. The predicted noise levels at the noise monitoring points (as agreed with MEPA) are set out in Table 13.7. In determining the distance from the noise source to the noise sensitive use, blank façades do not count. The distance is determined from the centre of the Application Site to the noise monitoring point. The plan distance is used and no screening is assumed. Attenuation of noise levels over distance are calculated in accordance with BS 4142:1997.


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Table 13.7: Predicted sound levels at noise sensitive receptors Estimated LAeq sound levels

Assessment point A: (375m from centre of

site)

Assessment point B: (130m from centre of site)

Source of Sound

Source db(A)

Number on-site at one time

dB(A) dB(A) Excavation using hydraulic hammers & ripper Hydraulic Hammer 119 3 72 81

Bulldozer with ripper

106 3 59 68

Shovel 106 3 59 68 HGV 109 3 66 75 Predicted level All plant simultaneously 73 82

Construction Tower crane 98 4 52 61

Hand held concrete-breakers and picks

105 1 53 62

HGV 109 2 60 69 Predicted level All plant simultaneously 61 70

Operation Amplified sound* day and night (to 11pm)

95 1 43 52

Current Level Current daytime / night time LAeq levels

52 / 43 69 / 44

Note: * = estimates

13.43. The significance of the predicted noise levels at the boundaries / buildings of noise sensitive receptors, as indicated above, is determined through reference to the predicted change in background noise levels.

Impacts at each of the noise assessment points

13.44. At the noise assessment points described in Figure 13.2, LAeq sound levels from the combined operation of the plant at the two noise monitoring points is predicted to be between 73dB(A) and 82dB(A) during the excavation phase, and 61dB(A) and 70dB(A) during construction. Noise levels at monitoring point B, which is a proxy for the residential uses in the vicinity could be reduced by approximately 28dB by closing windows, resulting in an indoor working hours noise climate during


279

excavation that is calculated to be of the order of 45dB(A). Taking such mitigation measures into account, the change in the indoor noise climate during excavation at this point is not significant. However, the level of noise outdoors is predicted to be 13dB(A) above the current levels and is, therefore, judged to be of major significance.

13.45. The change in the outdoor / window open noise climate at monitoring point B during construction is only 1dB(A); it is judged to be not significant.

13.46. The situation at monitoring point A, which is at the pool deck of the Mellieha Holiday Centre is not suited to amelioration through mitigation measures afforded by buildings or windows. Noise levels at the pool area during excavation and construction are predicted to be of the order of 73 dB(A) Leq60, and 61 dB(A) Leq60 respectively, some 9 - 21dB(A) above the current levels. This change in noise climate is judged to be of major significance.

13.47. The operational noise levels associated with amplified sound are predicted to be 43 dB(A) Leq60 at the Monitoring point A. Such levels occurring in the day time would not effect a change in noise levels during the day or during the night. Such an impact would not be significant.

13.48. The impact of the excavation and construction at the other noise sensitive receptors shown on Figure 13.2 is likely to be as follows:

• Tunny Net Restaurant: as for Monitoring Point B;

• Beach: as for Monitoring Point A; it is noted that the existing hotel lying between the Application Site and the beach will screen most of the noise; and

• Il-Hofra: as for Monitoring Point B; it lies adjacent to Triq il-Marfa.

13.49. Changes to traffic flows and patterns have been described in the Traffic Impact Statement (TIS) prepared for the Scheme. Estimates of traffic flows described in the TIS take account of new development in the area that has planning permission but is not yet operational, and a 2% per annum growth in network traffic (as agreed with MEPA).

13.50. Since a doubling of traffic flows is required to effect a 3dB(A) change in background noise levels, the additional traffic is unlikely to result in a substantial increase in background noise levels on Triq il-Marfa or the Mellieha Bypass. Additional noise resulting from increased traffic is not likely to be significant.


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IMPACT ASSESSMENT: VIBRATION

Potential Impacts 13.51. The potential impacts associated with the Scheme include:

• Impacts on the structural integrity of surrounding buildings and structures such as boundary walls;

• Vibration disturbance to the residents in the properties near the development during construction; and

• Vibration disturbance during construction to users of the facilities in the area.

13.52. The operation of the Scheme is not expected to generate vibration additional to that which is expected in urban areas.

Prediction and Significance of Impacts 13.53. The vibration sources during the construction of the Scheme are similar to the noise

generating ones i.e., plant used in excavation and plant used in the construction of the foundations and the buildings.

13.54. Since construction will only be undertaken in daylight hours, the assessment of night time vibration impacts is not relevant and will not be addressed.

Impacts on the structural integrity of surrounding buildings and structures

13.55. Excavation and new foundation work are common sources of vibrations that can affect adjacent structures. The plant and methods used in such works produce vibrations that may be transmitted to adjacent structures. Vibrations may also be caused by increased truck traffic accompanying excavation and construction work. In all cases, the strength of the vibrations reaching the adjacent structure depends upon the activity generating the vibrations, the distance between the source and the existing structure, and the type of ground found between the two. The susceptibility of adjacent buildings to vibrations may be increased due to deferred maintenance and past alterations that may have produced structural weak points. Plaster walls and ceilings lack the flexibility to accommodate abnormal movement, while shallow foundations (common in old buildings) may lack the rigidity to resist vibration induced movement.

13.56. Excavation and foundation work can also cause ground displacement and movement of an adjacent building. New construction almost invariably calls for foundations much deeper than those of neighbouring buildings. This is especially true for projects that include underground parking facilities. A structure with a shallow masonry or stone foundation and wall footings may experience corresponding displacement that can result in major structural damage92.

92 U.S. Department of the Interior, Technical Preservation Services website:

http://www.cr.nps.gov/hps/TPS/technotes/PTN42/print_version.html

http://www.cr.nps.gov/hps/TPS/technotes/PTN42/print_version.html


281

13.57. British Standard 7385: Part 2: 1993 ‘Evaluation and measurement for vibration in buildings – Guide to damage levels from ground borne vibration’ gives the limit values for transient vibration, above which cosmetic damage, minor damage, and major damage would occur (see Table 13.2).

13.58. The potential sources of vibration are likely to be associated with excavation, which tend to generate transient peaks. Plant such as compressors, pumps, generators, and trucks can emit significant levels of low frequency noise, which can cause resonance in nearby buildings, usually perceived as vibration by occupants. Care is needed in the positioning of such equipment.

13.59. As noted in Chapter 4, the excavation of the vertical interfaces between the Application Site and the existing hotel would also effectively shield third party properties. The general / oversite excavation works will be carried out by a bulldozer-mounted ripper and two excavator-mounted pneumatic hammers each supported by a shovel. No explosives will be used.

13.60. Vibration monitoring data for excavations elsewhere in Malta shows that the PPV at a distance of 15 metres from the monitoring point to the impact hammer was a maximum of 2.93 mm/s; at a distance of 7 metres this increases to a maximum of 14.89 mm/s93. It is noted that such measurements were taken at a site where excavation was by means of hydraulic hammers and that excavation was not preceded by the excavation of a trench either around the entire site or at least between the measurement point and the excavation point. The effect of vibrations is considerably reduced when a trench that is at least 2 metres wide and is slightly deeper than the lowest excavation point is dug between the source of vibration and the sensitive receptor.

13.61. In view of the fact that at 7 metres the vibration was found to be lower than the value prescribed by BS 7385: Part 2 of 15 mm/s, and considering that there will be a trench surrounding the excavation works, and further considering that the closest third party property is 78 metres from the boundary of the Application Site, the impact of vibrations on the stability of the latter buildings is likely to be not significant.

Impacts of vibrations on residents of surrounding buildings

13.62. The impact of vibrations on residents depends on the distance of the source of the vibration from the receptor. Table 13.2 shows that at a distance of 20 metres between the sensitive receptor and the excavation equipment, vibration is just perceptible. Experience indicates that when a trench is used, there are few complaints from residents.

13.63. Vibration arising from excavations at that part of the site that is closest to third party property is not likely to be perceptible at such properties, and is judged to be not significant.

93 MEPA, Report on Vibration Monitoring at the ex-Union club Site in Sliema.


282

MITIGATION 13.64. The placement of an 8-course franka-stone wall around the perimeter of the

Application Site is not likely to materially mitigate noise levels.

13.65. It is recommended that excavations are carried out during the low season, when there are likely to be few people at the Mellieha Holiday Centre pool area.

13.66. In order to minimise the generation of excavation noise and vibration it is recommended that the majority of the excavation is undertaken with a trencher and ripper.

13.67. The excavation of a trench (deeper than the excavation itself), would reduce the effects of the vibration on structures and persons to not significant.

RESIDUAL IMPACTS 13.68. It is anticipated that noise arising from the excavation activities will extend over the

duration of the excavation. Such residual impacts will be of major significance as described above, although of short duration.


283

Table 13.8: Summary of noise and vibration impacts

Predicted Impact


Importance


occurring




Excav’n / Constr’n /Oper’n


Direct/ Indirect

S term/ L term

Perm/ Temp

Revers./ Irrevers.


(Likely, Unlikely, Remote, Uncertain)



Noise impact on sensitive receptors a Monitoring Point A:

Adverse Excavation & Consr’n

Local Direct Short Temp Revers. Local Likely Major significance

None

Major significance

Noise impact on sensitive receptors at Monitoring Point B

Adverse Excavation & Constr’n


Excavation: Windows shut Construction: None

Excavation:: Not significant indoors with windows closed; major significance outdoors Construction: Not significant


284

Predicted Impact


Importance


occurring




Impact Excav’n

Constr’n /Oper’n


Direct/ Indirect

S term/ L term

Perm/ Temp

Revers./ Irrevers.


(Likely, Unlikely, Remote, Uncertain)



Impact of vibrations on structural integrity of closest buildings


Local Direct Short Temp Revers. Local Likely Not significant

Excavation of trench around site periphery deeper than excavation.

Not significant

Impact of vibrations on people in adjacent buildings

Adverse Constr’n Local Direct Short Temp Revers. Local Likely Not significant

Excavation of trench around site periphery deeper than excavation.

Not significant

Impacts of operational noise on residents

Adverse Oper’n Local Direct Short Temp Revers. Local Likely DAY: Not significant NIGHT: Not significant

Nil DAY: Not significant NIGHT: Not significant

Impacts of traffic noise on residents

Adverse Oper’n Local Direct Long Perm Revers. Local Likely Not significant



285

14. SUMMARY OF KEY IMPACTS, INTERACTIONS BETWEEN IMPACTS, AND MITIGATION

INTRODUCTION 14.1. The purpose of this chapter is to provide a summary of the key environmental

impacts, their interaction and cumulative effects, and their mitigation. It addresses the requirements in the Terms of Reference to describe mitigation measures to “prevent, minimise and where possible offset significant adverse effects on the environment of the project” and to identify cumulative and residual impacts. The chapter concludes with a summary of the mitigation measures proposed in the EIS.

SUMMARY OF KEY IMPACTS 14.2. Chapters 7 to 13 of the EIS describe the predicted impacts of the Scheme on

environmental aspects, in accordance with the Terms of Reference. For each predicted impact, an assessment has been made as to whether it would be of major or minor significance, or not significant. The criteria for judging significance are identified in each chapter and a summary table is included. Throughout the EIS, particular attention is focussed on the predicted major and minor impacts and, in the case of the negative impacts, how these would be mitigated. All the residual impacts are summarised in Table 14.2 at the end of this chapter.

14.3. The potential key impacts arising from the Scheme relate to:

• Geo-environment;

• Agriculture;

• Ecology;

• Cultural heritage;

• Landscape and visual amenity;

• Air Quality; and

• Noise.

14.4. Most of the identified impacts are minor. Major impacts that have been identified relate to the impacts on geology (due to the excavation), loss of agricultural land, potential disturbance from escape of invasive species, loss of rural cultural heritage features (especially rubble walls), and noise impacts during excavation. Where possible, mitigation measures have proposed to reduce potential impacts. Three major residual impacts do remain, however, i.e. the impact on the geology, loss of agricultural land, and noise impacts during excavation.


286

INTERACTION OF IMPACTS 14.5. The interactions between impacts are noted in the relevant sections of the EIS.

These are summarised in Table 14.1, which lists the impacts and identifies the relevant topic areas.

Table 14.1: Summary of Interactions between Impacts Impact Topic Areas Construction Geo-environmental

Agriculture Ecology Cultural heritage Air quality Noise Waste Visual

Operation Geo-environmental Agriculture Cultural Heritage Visual amenity


287

Table 14.2: Summary of Impacts

Nature, Scale and Type of Impact Policy

Importance

Probability of

impact occurring




/ Adverse


Extent of impact

(Nat/Local/

Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers/ Irrevers

(Inter / National/

Local)


Uncertain)

Legislation




Geo-Environmental Changes to geo-environmental features

Adverse Both Local Direct L term Perm Irrevers Local Likely Major Minimise excavation footprint to bare minimum

Major

Pollution of aquifer Adverse Constr’n Local Direct S term Temp Revers. Local Unlikely EPA Minor All water falling on the Site will be collected and will therefore not reach the aquifer

Not significant

Pollution of runoff Adverse Constr’n Local Direct S term Temp Revers. Local Remote EPA Minor All water falling on the Site will be collected

Not significant

Agriculture Loss of agricultural land

Adverse Cons/Op Site Direct L Perm Reverse National Likely Major None Major

Impacts on agricultural productivity in the A of I resulting from dust

Adverse Cons Local Indirect S Temp Reverse National Unlikely Minor Good construction practice

Not significant

Loss of protected trees

Adverse Cons/Op Site Direct L Perm Reverse National Likely Minor Transplantation Not significant to minor

Social Impact Beneficial Cons/Op Site Direct L Perm Reverse Local Likely Minor None Minor Ecology Loss of habitat Adverse Constr’n Local Direct L term Perm Irrevers

. Local Likely EPA,

LN Minor to major

Carefully dismantle rubble walls and

Minor


288


Importance

Probability of

impact occurring




/ Adverse


Extent of impact

(Nat/Local/

Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers/ Irrevers

(Inter / National/

Local)


Uncertain)

Legislation




311/2006, GN 112/2007

minimise impact on trees. New landscaping and rubble walls will provide alternative habitats. Construction vehicles must not use the rural road that borders Il-Hofra.

Disturbance to wildlife from noise & vibration


Local Indirect S term Temp Revers. Local Likely EPA, LN 311/2006, GN 112/2007

Insignificant to Major

Refer to Chapter 13. During construction, impact likely to be major. During operation, impact likely to be minor to insignificant

Minor

Disturbance to wildlife from light pollution

Adverse Oper’n Local Indirect L term Perm Revers. Local Likely EPA, LN 311/2006, GN 112/2007

Minor Sensitive lighting scheme

Minor to insignificant

Disturbance to wildlife from changes to hydraulic regime


Local Indirect L term Temp Revers. Local Unlikely EPA, LN 311/2006, GN 112/2007

Minor Monitor changes in marshland hydrology

Minor


289


Importance

Probability of

impact occurring




/ Adverse


Extent of impact

(Nat/Local/

Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers/ Irrevers

(Inter / National/

Local)


Uncertain)

Legislation




Disturbance to wildlife from trampling

Adverse Oper’n Local Direct S term Temp Revers. Local Unlikely EPA, LN 311/2006, GN 112/2007

Minor No facilitation of public access to the Site; reference to the Management Plan (where and if relevant) once this is drawn up

Not significant

Degradation to natural habitats from the introduction of alien or atypical species

Adverse Oper’n Local Indirect L term Perm Irrevers International

Unlikely EPA, LN 311/2006, GN 112/2007

Major Landscaping in accordance with MEPA guidelines

Minor – not significant

Cultural Heritage Loss of features Adverse Constr’n Site Direct L. term Perm Irrevers National Likely Cultural

Heritage Act (Minor), DPA (Minor)

Major Reuse material from rubble walls; Retain water reservoir

Minor

Damage to features Adverse Oper’n Local Direct L. term Perm Irrevers National Likely Cultural Heritage Act (Minor), DPA (Minor)

Minor to Major

Sensitive construction methods around cultural features

Uncertain

Cultural landscape Adverse Constr’n Local Direct L. term Perm Irrevers National Likely Cultural Minor None Minor


290


Importance

Probability of

impact occurring




/ Adverse


Extent of impact

(Nat/Local/

Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers/ Irrevers

(Inter / National/

Local)


Uncertain)

Legislation




in immediate vicinity of Scheme

/ Oper’n Heritage Act (Minor), DPA (Minor)

Landscape Character Area 2: Southern Valley

Adverse Oper’n Local Direct L term Perm Revers. Local Likely Minor None Minor

Visual Amenity Viewpoint 1: Ghadira Promenade

Adverse All Local Direct L term Perm Revers. Local Likely Minor to Major

None Minor to Major


Adverse All Local Direct L term Perm Revers. Local Likely Minor to Major

None Minor to Major

Viewpoint 3: Triq il-Marfa, Mellieha

Adverse All Local Direct L term Perm Revers. Local Likely Minor None Minor



Viewpoint 5: Triq il-Marfa


Air quality Impact of dust on users of the Site

Adverse Constr’n Local Direct S term Temp Revers. Local Likely Air quality legislation

Minor Implementation of Environmental Management Construction Site

Minor


291


Importance

Probability of

impact occurring




/ Adverse


Extent of impact

(Nat/Local/

Site)

Direct/ Indirect

S term/ L term

Perm/ Temp

Revers/ Irrevers

(Inter / National/

Local)


Uncertain)

Legislation




Regulations, 2007 Noise & vibration Noise impact on sensitive receptors a Monitoring Point A:

Adverse Excavation & Consr’n


None

Major significance

Noise impact on sensitive receptors at Monitoring Point B



Excavation: Windows shut Construction: None

Excavation:: Not significant indoors with windows closed; major significance outdoors Construction: Not significant


293

MITIGATION 14.6. This document and its supporting Technical Appendices report on the findings of the

EIS in accordance with the Terms of Reference. Each topic area has addressed the specific requirements of the ToR and, where appropriate, mitigation measures have been incorporated into the design, and where this has not been possible mitigation measures are recommended.

SUMMARY OF MITIGATION 14.7. A number of measures to reduce the impact of the Scheme were incorporated into

the siting and design of the Scheme components, through the iterations of the EIA process.

14.8. The main mitigation measures include:

• Soil removal will be carried out at the end of Summer before the rains and stored in a specially dedicated area on site for re-use in the landscaping scheme;

• No servicing or refuelling will be carried out on site and no fuel or chemicals will be stored on-site;

• A Construction Management Plan has been drawn up and will be implemented from the start of the project; the contents of the plan will be communicated to all personnel and training provided where necessary;

• The Construction Site will be surrounded by a fence to prohibit unauthorised entry. The Construction Site will have only one access;

• The western boundary of the Site will also be enclosed with a 3 coarse wall built on the side of the rural road so as to channel any surface water run-off in the road to the marshland, thereby avoiding ingress of surface run-off into the construction site and hence minimising losses of water that would normally have flooded the marshland;

• Protection of existing roadside culverts;

• Transplantation of protected trees, if possible;

• Investigation of the bedrock prior to excavation (following soil removal) for any evidence of cultural heritage features (e.g. cart ruts);

• Dismantling of, and re-use of the stone from, cultural heritage features on the Site;

• Adherence to proper site management practices, including the provisions of the Environmental Management Construction Site Regulations, 2007;


294

• Use of only indigenous and native tree and plant species in the landscaping scheme in line with MEPA guidelines;

• Use of energy efficient technology to minimise emissions and to cut down on costs;

• Monitoring of the hydrology of the marshland; and

• Incorporation of landscaping on the terraces of the hotel extension.

COMMITMENT TO MITIGATION 14.9. The Applicant has confirmed his commitment to implement the above mitigation

measures. It would be appropriate for these to be included in the Conditions of Permit should Development Permission be granted.

Appendix 1

Geological Sub-Surface Investigation Report

1

Geological Sub-Surface InvestigationEXTENSION TO EXISTING SEABANK HOTEL, LANDSCAPING,

SELF CATERING UNITS AND PARKING FACILITIES, AT TRIQ IL-MARFA, MELLIEHA

Report

Report by:Terracore Geo Services

January 2008

TABLE OF CONTENTS

INTRODUCTION ............................................................................................................................................................ 1

GROUND CONDITIONS .................................................................................................................................................... 1TERMS OF REFERENCE.................................................................................................................................................... 2WORKS UNDERTAKEN .................................................................................................................................................... 3STANDARDS AND GUIDANCE .......................................................................................................................................... 3

FIELD WORK – METHOD............................................................................................................................................ 4

RESULTS OF THE INVESTIGATION ........................................................................................................................ 6

RQD% AND SCR% ........................................................................................................................................................ 7FRACTURE FREQUENCY .................................................................................................................................................. 7

LABORATORY TESTING............................................................................................................................................. 8

CONCLUSIONS............................................................................................................................................................. 11

Appendix 1: Drilling logs........................................................................................................................................ 17Appendix 2: Core logs............................................................................................................................................. 21Appendix 3 Laboratory testing.................................................................................................................................. 1

TablesTable 1: Borehole drilling summary ....................................................................................................4 Table 2: % Core recovery and % Solid Core recovery data. ...............................................................6 Table 3: Fracture description ...............................................................................................................7 Table 4: Laboratory test results- Unconfined compressive strength....................................................8 Table 5: Water absorption....................................................................................................................9 Table 6: Los Angeles resistance to fragmentation test ......................................................................10

FiguresFigure 1: Location of site at Mellieha ..................................................................................................1 Figure 2 Locations of the site at Mellieha............................................................................................2 Figure 3: Site plan showing location of boreholes ..............................................................................5

ii

LIST OF PLATES

Plate 1: Photographs of core rock samples recovered from BH1 Run 1

Plate 2a: Photographs of core rock samples recovered from BH2 Run 1and Run 2

Plate 2b: Photographs of core rock samples recovered from BH2 Run 3 and Run 4

Plate 3: Photographs of core rock samples recovered from BH3 Run 1

Plate 4a: Photographs of core rock samples recovered from BH4 Run 1and Run 2

Plate 4b: Photographs of core rock samples recovered from BH4 Run 3 and Run 4

Plate 4c: Photographs of rock core samples recovered from BH4 Run 5

Plate5a: Photograph of rock core samples recovered from BH5 Run 1 and Run 2

Plate 5b: Photograph of rock core samples recovered from BH5 Run 2 and Run 3

iii

FOREWORD

The recommendations made and opinions expressed in this report are based on the ground conditions revealed by the site works, together with an assessment of the site and of laboratory test results. Whilst opinions may be expressed relating to sub-soil conditions in parts of the site not investigated, for example away from the location of the borehole drilled, these are only for guidance and no liability can be accepted for their accuracy.

The rocks and soils encountered and the samples retained represent a limited amount of the material present in the subsurface at the site. Although the investigation recovered representative samples of the rocks present, some material present on the site may not have been examined. Should significantly different rocks or soils be determined during site works, then further investigation may prove necessary.

Unless otherwise stated in this report, drilling is undertaken using rotary techniques. This method is regarded as being one of the most reliable.

Boring and sampling procedures are undertaken in accordance with B.S.5930, “Code of practice for Site Investigations”. Likewise laboratory testing complies with ASTM –C C170-90 1999, ASTM C97-02, BS EN 1097-2: 1998.

This report is produced for the benefit of the client alone. No responsibility can be accepted for any consequences of this information being passed to third party who may act upon its contents/recommendations.

IntroductionTerracore Geo Services has been commissioned ADI Associates perform a subsurface geological site investigation in connection with the construction of an extension to the Seabank Hotel located at Mellieha (Figure 1).

Figure 1: Location of site at Mellieha

Ground Conditions The site is located on Upper Coralline Limestone in the Ghadira Graben, close to the Ras il-Griebeg - Ghajn Znuber Fault to the south which has a throw of the order of 60m and the Il-Prajjet-L-Ghadira fault to the north. It lies at an altitude of about 8m above sea level (Figure 2). The lithostratigraphy at the site comprises a thin layer of soil underlain by Upper Coralline Limestone.

2

Figure 2: Location of site at Mellieha

Terms of Reference The terms of reference issued by the MEPA comprise the following:

A geo-technical survey of the material to be excavated and rock mass forming the foundation of the proposed structure shall be submitted. A number of core samples shall be carried, the number and location of which shall be as approved by MEPA prior to carrying out of any in situ tests. Rock sampling and testing shall comply with the relevant BS Standards. This description shall extend to at least 3 m below the deepest level of the proposed development (taking into consideration any facilities proposed underground). This section shall provide the information required for establishing the economic feasibility for the reuse of the excavated material (including any necessary studies to determine such feasibility) required in Section 4.2.

3

Works undertaken In accordance with the terms of reference issued by MEPA the investigation works comprised the drilling of five holes by continuous rock core sample recovery to depths ranging from 3m to 14m below ground level. These works were accompanied by laboratory testing to ascertain the quality of the limestone resource to be excavated.

Standards and Guidance Site investigation was conducted in accordance with BS 4019: Rotary core drilling equipment, and: BS 5930; 1999 Code of Practice for Geological site Investigations.

4

Field Work – Method Field work consisted of the drilling of five holes BH1 to BH5. The top section of these holes was drilled by the open hole destructive method down to bedrock. This was followed by continuously coring for a depth interval ranging from 3m to 14m using a T44 Beretta Rotary drill in conjunction with water circulation and a T2 86 double tube core barrel. Casing was inserted wherever necessary to stabilize the hole during drilling.

A drilling summary is found in Table 1 below. Details of the drilling are found in the drilling logs (Appendix 1). A site plan showing the borehole locations is shown in Figure 3.

The core samples recovered were photographed and logged prior to testing at the laboratory of Civil Engineering and Architecture of the University of Malta. Photographs of the cores recovered are attached at the end of the report.

Table 1: Borehole drilling summary

BHNo

Depth to bedrock

Cont Coring Total depth Ground level

m m m

1 0 0.0-3.0 3 2 0.40 0.4-12.4 14.4 3 0.8 0.8-3.8 3.8 4 0.9 0.9-14.0 14.0 5 1.6 1.6-10.5 10.5

The observations made during drilling included: CirculationColour of cuttings Falls of drill string

5

Figure 3: Site plan showing location of boreholes

Coring consisted of up to 3m runs accompanied by core recovery after each run. The core samples recovered were placed in specially prepared wooden boxes each 1m long and of sufficient width to take 3m of rock core sample, taking particular care to place the core in the required order such that the core can be examined from left to right starting from the TOP of the core which was labeled as such.

The samples recovered were logged and photographed and then moved to the Laboratory of the Building and Engineering Department of the University of Malta for testing.

6

Results of the investigation

Photographs of the rock core samples recovered during the site investigation are attached at the end of this report. Core logs for the core samples recovered from BH1 to BH5 are found in Appendix 2.

The site investigation revealed that the geology of the site consists of a thin soil layer up to 1.3m deep underlain by Upper Coralline Limestone. Two different types of beds have been sampled.

A top bed about 7m to 8m thick consisting of: Cream to light brown coloured, Calcirudite very coarse, massive, moderately strong LIMESTONE with fractures cemented by indurated red clay or laminated calcrete. Presence of gastropod molds noted.

A lower bed over 7m thick consisting of: Cream coloured calcarenite (reef) very porous massive moderately weak LIMESTONE grading downwards to a weak friable massive calcarenite, fractures planes are generally clean and clay or calcrete filling fractures is absent.

While the upper bed is generally moderately strong the lower one generally is moderately weak and contains friable weak zones. The core logs include:

A lithological description Percentage core recovery - %Rec Percentage solid core recovery -%SCR Rock Quality designation - %RQD Fracture description and Fracture frequency - f

These are summarized in Table 2 and Table 3 below.Table 2: % Core recovery and % Solid Core recovery data for borehole BH 1 to BH 5

BHNo

Run No 1 Run No 2 Run No 3 Run No 4 Run No 5

Rec RQD SCR Rec RQD SCR Rec RQD SCR Rec RQD SCR Rec RQD SCR

% % % % % % % % % % % % % % %

1 100 93 93

2 100 100 100 100 100 100 40 40 30 83 83 72

3 97 97 97

4 99 83 95 100 100 100 100 100 95 97 97 92 100 100 100

5 100 100 100 100 100 100 100 100 100

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Table 3: Fracture description

BH No Run No 1 Run No 2 Run No 3 Run No 4 Run No 5

1 3H, 3Ob fissures

up to 2cm wide filled with calcrete, several healed

2 3 SH fissures up to 2cm wide filled with calcrete, several healed

5SH irr 0 2 Ob

3 4 Ob faces stained with red clay

4 2SH, 3Ob fissures up to 2cm wide filled with calcrete, and red clay several healed fractures

1SH and 1Ob faces stained red

3 Ob irr faces stained red clay

1 Ob irr 0

5 3 Ob irr faces and 2S H faces stained with red clay

3 Ob irr faces and faces stained with red clay

2SH faces stained red

Ob: oblique SH: sub-horizontal irr: Irregular

RQD% and SCR% The tables above show that the quality of the rock core samples recovered was excellent. Recovery%, RQD% and SCR% are seen to be excellent and always over 90% with the exception of:

BH2 Run 3 and Run 4 – 6.4m to 12.4m below ground level.

Fracture Frequency Fractures are common in the upper bed described above and many of them are completely healed while a few (fissures) up to 2.6 fractures per meter, are filled with caliche or red clay.

8

Laboratory Testing Following logging a number of rock core samples were selected for testing at the Laboratory of the Building and Engineering Department of the University. The tests undertaken comprised the measurement of:

Uniaxial compressive strength which was measured in accordance with ASTM C170-90, 1999.Water absorption Wet and dry density Determination of resistance to fragmentation by the Los Angeles test method

The laboratory test results are summarized in Table 4 to Table 7 below. Table 4: Laboratory test results- Unconfined compressive strength

Sample ID. Diameter Length Area Failure Compressive Remarks Load Strength

mm mm /mm2 / kN / N/mm2

BH 1 Run 1 @ 1.2 m 72.2 145.1 4091.3 35.70 8.73 -BH 1 Run 1 @ 2.2 m 72.1 146.4 4083.4 90.57 22.18 -

BH 2 Run 1 @ 1.0 m 72.3 143.2 4106.0 51.23 12.48 cracked in the middle

BH 2 Run 1 @ 2.0 m 72.3 143.2 4106.0 38.81 9.45 -BH 2 Run 2 @ 3.5 m 71.9 138.0 4060.7 14.80 3.64 -BH 2 Run 3 @ 6.4 m 72.0 144.2 4072.0 12.25 3.01 chipped

BH 3 Run 1 @ 0.5 m 72.4 143.3 4117.4 72.82 17.69 -BH 3 Run 1 @ 1.5 m 72.2 144.5 4094.7 36.89 9.01 -

BH 4 Run 1 @ 0.9 m 72.1 144.7 4083.4 121.09 29.65 -

BH 4 Run 1 @ 2.35 m 72.2 144.6 4094.7 27.66 6.76 -BH 4 Run 2 @ 3.5 m 72.3 145.0 4106.0 74.45 18.13 some cracks

BH 5 Run 1 @ 1.6 m 72.3 144.5 4106.0 120.73 29.40 crackedBH 5 Run 1 @ 2.6 m 72.3 144.5 4106.0 132.86 32.36 -BH 5 Run 1 @ 3.6 m 71.8 143.9 4049.4 127.32 31.44 -BH 5 Run 2 @ 7.5 m 72.2 145.3 4094.7 48.85 11.93 -

9

Table 5: Water absorption

Sample ID.

Weight of the soaked

and surface-dried

specimen in air

Weight of the soaked specimen in

water

Bulk Specific Gravity

WaterAbsorption Remarks

g g %

BH 2 Run 1 @ 1.0 m 1145.5 571.8 1.9 6.5 -

BH 2 Run 1 @ 2.0 m 1220.1 646.2 2.0 5.6 -

BH 2 Run 2 @ 3.5 m 1039.7 507.7 1.7 12.9 -

BH 2 Run 3 @ 6.4 m 1066.6 508.9 1.6 17.7 chipped

BH 4 Run 1

@ 0.9 m 1350.3 760.7 2.3 1.4 -BH 4 Run 1 @ 2.35 m 1259.7 672.4 2.1 4.2 material lost

BH 4 Run 2 @ 3.5 m 1355.1 768.9 2.3 2.0 -

BH 5 Run 1

@ 1.6 m 1345.6 760.2 2.3 1.2 very cracked BH 5 Run 1

@ 2.6 m 1435.2 854.8 2.4 1.1 material lost BH 5 Run 1

@ 3.6 m 1424.9 853.3 2.5 0.9 material lost BH 5 Run 2

@ 7.5 m 1370.1 783.8 2.3 1.9 -

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Table 6: Los Angeles resistance to fragmentation test

Test portion size fractions:

Passing 14 mm test sieve and retained on the 10 mm test sieve30% passing a 11.2 mm test sieve

Sample I.D.: BH 2

Sample 1

Mass retained on 1.6 mm sieve (g) 2701.3 Los Angeles coefficient (LA) 46

Sample I.D.: BH 4

Sample 1

Mass retained on 1.6 mm sieve (g) 3494.1 Los Angeles coefficient (LA) 30

Sample I.D.: BH 5

Sample 1

Mass retained on 1.6 mm sieve (g) 3452.7

Los Angeles coefficient (LA) 31

A complete laboratory report is found in Appendix 3

Uniaxial unconfined compressive strength The test results show that the rock is of a mixed quality. BH 5 gave the best results in run one which are mostly consistently high from 29.4 to 32.3 N/sq mm. The average uniaxial compressive strength of for the samples tested is 16.4 Nmm-2. The rock is on average moderately strong but still low for a hardstone.

Water absorption The best values for water absorption were tested in BH 5, and range from 0.9% to 1.9% which are very good values for a hard stone.

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Los Angeles resistance to fragmentation test The results of BH 4 and BH 5 indicate that the rock at the two locations tested makes a good to fair quality hard stone. Test results of BH 2 show that the rock at that location is poor quality.

Conclusions

1 Site investigation for a proposed extension at the Seabank Hotel Mellieha comprised the drilling of five holes (BH 1 to BH 5) with continuous rock core sample recovery from top of bedrock to a depth ranging from 3m to 14m below ground level.

2 Core samples recovered from the site were entirely composed of Upper Coralline Limestone. LIMESTONE core samples recovered from the site were mostly of excellent quality in terms of RQD but of a mixed quality as far as the quality of the limestone resource is concerned.

3 However, Los Angeles resistance to fragmentation test on samples recovered from BH 4 and BH 5 indicate that the rock at these locations makes a good hard stone aggregate. Water absorption and compressive strength results are in agreement with these results.

4 The average compressive strength of the rock core samples recovered was 16.4 N/mm2.

12

Photographs of rock core samples recovered Note for scale core tray is 1m long and core samples diameter is 71mm

Plate 1: Photographs of core rock samples recovered from BH 1 Run 1

Plate 2: Photographs of core rock samples recovered from BH 2 Run 1and Run 2

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Plate 2b: Photographs of core rock samples recovered from BH 2 Run 3 and Run 4

Plate 3: Photographs of core rock samples recovered from BH 3 Run 1

14

Plate 4a: Photographs of core rock samples recovered from BH 4 Run 1and Run 2

Plate 4b: Photographs of core rock samples recovered from BH 4 Run 3 and Run4

15

Plate 4c: Photographs of rock core samples recovered from BH 4 Run 5

Plate5a: Photograph of rock core samples recovered from BH 5 Run 1 and Run 2

16

Plate 5b: Photograph of rock core samples recovered from BH 5 Run 2 and Run 3

17

Appendix 1: Drilling logs

18

12

Drill: 12/12/2007CoreRecovery

%

100.00

Driller Circulation: F = Full,P = Partial Loss, L = Total Loss.Test = SPT, Vane, Soil Sampling.

Client:

Area

Drill Type:

Standard Core BarrelMellieha

Assistant DrillerMark Scerri

Anthony Scerri

3.00

T44WaterDrilling Fluid:

ADI AssociatesLocation:

From TO

Length

REMARKS

FCored run 1 with white returns 3.00 3.00

B/H No: Job No:

Core

CirculationRecoveryRun

Date:

0.00

New Seabank areaCore Run

DESCRIPTION

23


%

100.00100.0040.0083.33


F0.00 0.40

3.003.00

6.40 9.40 Cored run 3 with white returns. Very soft. 1.8m washed out

0.40 3.40

1.203.00

B/H No: Job No:

Core


Date:

F

F3.00F

2.503.009.40 12.40

Core Run

DESCRIPTION

Cored run 1 with white returns. 3.00

Length

Drilling Fluid: ADI Associates

New Seabank areaFrom TO

3.40 6.40


Anthony Scerri

Cored run 2 with white returns

Cored run 4 with white returns. Very soft

REMARKS

Drilled open hole with brown returns. Top of bedrock at 40cm

Client:

Area

Drill Type:

Standard Core BarrelMelliehaLocation:

T44Water

19

31


%

96.67


Client:

Area

Drill Type:

Standard Core BarrelMellieha


Anthony Scerri

0.00 0.80


ADI Associates

New Seabank areaLocation:

From TO

REMARKS

Drilled open hole with brown returns. Top of bedrock at 80cm2.90

Core Run

DESCRIPTION

Cored run 1 with white returns 3.00

Length

B/H No: Job No:

Core


Date:

0.80 3.80 F

44


%

98.57100.00100.0097.33100.00


Date:

0.00 0.902.073.00 2.10

3.00F

F

B/H No: Job No:

Core


F

12.00 14.00

3.00

2.00

3.006.00 9.002.92

3.00

Core Run

DESCRIPTION

Advanced casing and cleared hole

Length

REMARKS

Cored run 4 with white returns 3.00

Drilled open hole with brown returns. Top of bedrock at 90cm

Cored run 5 with white returns F

Drilling Fluid: ADI Associates

New Seabank areaFrom TO

9.00

3.00 6.00

0.00 0.90


Anthony Scerri


Cored run 3 with white returnsCored run 2 with white returns

Client:

Area

Drill Type:

Standard Core BarrelMelliehaLocation:

T44Water

12.00

0.90

2.00F

20

55


%

100.00100.00100.00


Client:

Area

Drill Type:

Standard Core Barrel

1.60


Anthony Scerri


ADI Associates

New Seabank areaMelliehaLocation:

From TO

REMARKS

Drilled open hole with brown returns. At 1m hit some boulders. Top of bedrock at 1.30m


Cored run 3 with white returnsF

3.003.00 F

Run DESCRIPTION

Advanced casing with white returns

Length

7.50 10.503.003.00

F

B/H No: Job No:

Core

CirculationRecovery

2.90

Run

4.50 2.904.50 7.50 Cored run 2 with white returns

0.00 1.60

0.00 1.60

Date: Core

21

Appendix 2: Core logs

1

Appendix 3

Laboratory tests

2

Location: New Seabank AreaCommissioned by: Mr. Alfred XerriTest requested: Determination of resistance to fragmentation by the Los Angeles test methodStandard: BS EN 1097-2:1998Date of test: 15-Jan-08Report Number: R8006

Determination of resistance to fragmentation of rock

Test portion size fractions:30% passing a 11.2 mm test sieve

Sample I.D.: BH 2

Mass retained on 1.6 mm sieve (g) 2701.3Los Angeles coefficient (LA) 46

Sample I.D.: BH 4


Sample I.D.: BH 5


Notes:

Operator : ___________________ Approved : ___________________ Nicholas Azzopardi AMICT Franco E. Montesin B.Sc. (Eng) Hons. B.A. (Arch) MICT, A.&C.E

Lab Officer 2 Architect and Civil Engineer

3. The Laboratory test results show the properties of individual specimens tested under specified conditions. 4. The Laboratory will dispose of all samples after one calendar month from the date of issue of the final report unless instructed otherwise.

Msida MSD 2080

Test Report

1. The contents of this Test Report shall always be reproduced in full except except when explicit written approval is given by the laboratory management.2. Sheets containing the test raw data shall be retained for a period of six months after the completion of the official report. The results of this report can thus only be contested during these six months.

Sample 1

CIVIL ENGINEERING LABORATORYDepartment of Building and Civil EngineeringFaculty of Architecture and Civil Engineering

University of Malta

Sample 1

Sample 1

Passing 14 mm test sieve and retained on the 10 mm test sieve

3

Determination of water absorption and bulk specific gravity of rock

Location:Commissioned by: Mr. Alfred XerriTest requested:Standard:Date of report: 09/01/2008Report Number: R8006

mm mm g g g %

BH 2 Run 1 @ 1.0 m 72.3 143.2 1075.5 1145.5 571.8 1.9 6.5 -BH 2 Run 1 @ 2.0 m 72.3 143.2 1155.5 1220.1 646.2 2.0 5.6 -BH 2 Run 2 @ 3.5 m 71.9 138.0 920.5 1039.7 507.7 1.7 12.9 -BH 2 Run 3 @ 6.4 m 72.0 144.2 906.4 1066.6 508.9 1.6 17.7 chipped

BH 4 Run 1 @ 0.9 m 72.1 144.7 1331.7 1350.3 760.7 2.3 1.4 -BH 4 Run 1 @ 2.35 m 72.2 144.6 1208.8 1259.7 672.4 2.1 4.2 material lostBH 4 Run 2 @ 3.5 m 72.3 145.0 1328.6 1355.1 768.9 2.3 2.0 -

BH 5 Run 1 @ 1.6 m 72.3 144.5 1330.0 1345.6 760.2 2.3 1.2 very crackedBH 5 Run 1 @ 2.6 m 72.3 144.5 1419.0 1435.2 854.8 2.4 1.1 material lostBH 5 Run 1 @ 3.6 m 71.8 143.9 1412.7 1424.9 853.3 2.5 0.9 material lostBH 5 Run 2 @ 7.5 m 72.2 145.3 1344.4 1370.1 783.8 2.3 1.9 -

Notes:

Operator : ___________________ Approved : ___________________Nicholas Azzopardi AMICT, AIAT Franco E. Montesin B.Sc. (Eng) Hons. B.A. (Arch) MICT, A.&C.ELab Officer 2 Architect and Civil Engineer

Remarks

Msida MSD 2080

Test Report

Sample ID.

New Seabank Area

Absorption and Bulk Specific GravityASTM C97-02

Diamter Height

4. The Laboratory will dispose of all samples after one calendar month from the date of issue of the final report unless instructed otherwise.

CIVIL ENGINEERING LABORATORYDepartment of Building and Civil Engineering

University of MaltaFaculty of Architecture and Civil Engineering

1. The contents of this Test Report shall always be reproduced in full except except when explicit written approval is given by the laboratory

Bulk Specific Gravity

Water Absorptio

n

Weight of dried

specimen

Weight ofthe

soaked and

surface-dried

specimen in air

Weight of the soaked specimen in water

2. Sheets containing the test raw data shall be retained for a period of six months after the completion of the official report. The results of this report can thus only be contested during these six months.

3. The Laboratory test results show the properties of individual specimens tested under specified conditions.

4

Location:Commissioned by: Mr. Alfred XerriTest requested: Uniaxial Compressive StrengthStandard: ASTM C170-06Date of report: 09/01/2008Report Number: R8006

Specimen preparation: Cores trimmed to a height to diameter ratio of 2:1

Specimen conditioning:

Sample ID. Diameter Length Area Failure Compressive RemarksLoad Strength

mm mm /mm2 / kN / N/mm2

BH 1 Run 1 @ 1.2 m 72.2 145.1 4091.3 35.70 8.73 -BH 1 Run 1 @ 2.2 m 72.1 146.4 4083.4 90.57 22.18 -

BH 2 Run 1 @ 1.0 m 72.3 143.2 4106.0 51.23 12.48 cracked in the middle

BH 2 Run 1 @ 2.0 m 72.3 143.2 4106.0 38.81 9.45 -BH 2 Run 2 @ 3.5 m 71.9 138.0 4060.7 14.80 3.64 -BH 2 Run 3 @ 6.4 m 72.0 144.2 4072.0 12.25 3.01 chipped

BH 3 Run 1 @ 0.5 m 72.4 143.3 4117.4 72.82 17.69 -BH 3 Run 1 @ 1.5 m 72.2 144.5 4094.7 36.89 9.01 -

BH 4 Run 1 @ 0.9 m 72.1 144.7 4083.4 121.09 29.65 -BH 4 Run 1 @ 2.35 m 72.2 144.6 4094.7 27.66 6.76 -BH 4 Run 2 @ 3.5 m 72.3 145.0 4106.0 74.45 18.13 some cracks

BH 5 Run 1 @ 1.6 m 72.3 144.5 4106.0 120.73 29.40 crackedBH 5 Run 1 @ 2.6 m 72.3 144.5 4106.0 132.86 32.36 -BH 5 Run 1 @ 3.6 m 71.8 143.9 4049.4 127.32 31.44 -BH 5 Run 2 @ 7.5 m 72.2 145.3 4094.7 48.85 11.93 -

Notes:

Operator : ___________________ Approved : ___________________Nicholas Azzopardi AMICT, AIAT Franco E. Montesin B.Sc. (Eng) Hons. B.A. (Arch) MICT, A.&C.ELab Officer 2 Architect and Civil Engineer

4. The Laboratory will dispose of all samples after one calendar month from the date of issue of the final report unless instructed otherwise.

End trimming to align ends and make them parallel and perpendicular to the long axis of the coreSpecimens kept in water for 48 hours prior to test in temperature controlled curing tank at 22 degrees C

CIVIL ENGINEERING LABORATORYDepartment of Building and Civil EngineeringFaculty of Architecture and Civil Engineering

University of MaltaMsida MSD 2080

Test Report

Determination of Compressive Strength of Rock

1. The contents of this Test Report shall always be reproduced in full except except when explicit written approval is given by the laboratory management.

New Seabank Area

2. Sheets containing the test raw data shall be retained for a period of six months after the completion of the official report. The results of this report can thus only be contested during these six months.3. The Laboratory test results show the properties of individual specimens tested under specified conditions.

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