From Mr T. Temuge

Is Ghadira beach actually eroding? According to the Transport Minister, it is eroding at such an incredible rate that it could be gone within a few years! Has Dr Gatt had any scientific studies conducted to prove these catastrophic claims? The answer is no. But let’s simply take his word and believe that there is an imminent threat to Ghadira beach. The next logical question then would be to ask what is the main reason behind this erosion. Minister Gatt claims that it is the existing road. Does he have any studies to prove this point? Again, the answer is no. But according to Dr Gatt, it is “obvious”! Furthermore, if the road is removed, can the Ministry explain how the whole area will be miraculously covered by sand so suddenly? No, they cannot. But this does not stop them from jumping to the conclusion and submitting their proposals.

The Transport Ministry’s latest move to submit three proposals to Mepa (all of which, incidentally, cut through the EU protected area) is simply a tactic to pass the burden onto Mepa. The Environment Impact Assessments that will need to be carried out will look into the impact of the removal of the existing road and the construction of a new road through the Natura 2000 site. However, these EIAs will not address the fundamental question of whether there really is an erosion problem at Ghadira beach and, perhaps more importantly, what the sources of this questionable phenomenon are.

So, let’s try to understand the processes involved with covering the beach with sand – assuming that the government is not planning to import sand from an exotic country! Since Dr Gatt has no problem with speculations about the erosion at Ghadira beach and the reason for it, we will follow suit.

Theoretically, the raw material (that eventually becomes sand) comes from land in Ghadira, but this is a very slow process and it may take hundreds of years before the recovered land (from the road) becomes a sandy beach. On the other hand, most of the sand comes from the sea and this depends much on the type of waves (ie high energy or low energy ones). High-energy waves erode the beach whereas low energy waves deposit sand. So the main effect of the existing road since 1985 is likely to be that it has blocked most of the transfer of sand from the beach to the other side of the road. Now, this is an interesting point, as it therefore follows that the removal of the road may cause the whole beach to simply move backwards. Indeed, according to a report prepared by adi associates for the Sea Bank Hotel in 2004, which Dr Gatt is currently waving around as “evidence” to back his claims, this is exactly what might happen. If it does, then the result will not be a huge new beach that everyone will be able to enjoy, but simply one of the same size, now situated further back in Ghadira valley itself.

It is also important to understand the situation at the south end of the beach, where concrete quays were built more than 10 years ago in front of the Sea Bank Hotel. According to the local fishermen in the area, there was a small sandy beach covered with rocks before the hundred metre long quay in front of the Sea Bank Hotel was built. But now the waves are not being absorbed by the rocks and small sandy beach but are simply redirected as they crash onto the cement block. So, this could be the main reason why there is a redistribution of sand in the area. If this is indeed the reason behind the sand erosion of which the government is apparently so fearful, then why doesn’t the government simply remove the quay and the segment of the road inland by expropriating the land from the Sea Bank Hotel in the interests of the public? The area could then be reinstated to its original condition without the need to build a new road. But then, we need to prove this point by some sort of scientific studies, don’t we? Otherwise it is all speculation!

Again, let’s conduct the exercise of assuming that Dr Gatt is correct and the beach is eroding because of the existing road. If this is happening, then do we even need to remove the road? There are, after all, different ways of replenishing Ghadira beach without removing the existing road. Did the Transport Ministry study these alternatives? No, they did not.

It is also important to note that the fine sand that ends up on the existing road as a result of strong wind is being carted away by contractors and used in the construction business rather than being deposited back on the beach. This point was confirmed by a number of sources, including Mr Mallia of adi associates, who is one of the co-authors of the report prepared for the Sea Bank Hotel. The beach is also continuously being subjected to the regular redistribution of sand as a result of human activities, including beach cleaning and other management activities. So if this government is really concerned about its beaches, then we would expect a holistic strategy drafted in collaboration with the relevant authorities and NGOs, to address all the issues that may have a negative impact on Malta’s sandy beaches.

So, considering all of the above, we would suggest that before the government submits a proposal to remove the existing road, it first needs to justify exactly what effect the road is having on the beach. As stated above, this issue will not be addressed in the EIA, unless Mepa makes a specific request for its inclusion during the scoping period. Mepa can, and should, refuse the application if the applicant cannot provide scientific evidence to prove its point. But the Transport Ministry accused BirdLife of being “arrogant” just because it raised this valid point last week. We, however, choose not to respond to this kind of statement, which frankly is not the kind of statement one would expect from a government Ministry.

On the other hand, from a transportation point of view, we still wait for a logical explanation from the Transport Ministry as to how it makes any sort of sense to replace a four-lane road with no existing traffic problems with a two-lane road. Moreover, the Ministry does not provide any explanation as to why they are not considering investing EU funds in other parts of the island, where there are serious traffic problems, rather than insisting on replacing the existing road in Ghadira. However, instead of providing answers to these legitimate questions, the Transport Ministry seems to prefer to base its arguments on sand erosion and tourism, while the Prime Minister’s office – that is essentially responsible for the environment and tourism – remains silent.

BirdLife’s opposition to the proposed TEN-T road project in Ghadira is not aimed at safeguarding the Nature Reserve only. We are talking about building a new road through an undisturbed habitat that is also designated as an EU protected Natura 2000 site. Furthermore, the same road is planned to cut through the Foresta project site and is likely to cause irreversible damage and disturbance to the habitats in this pristine area. Moreover, it is planned that this road will be elevated (unlike the existing road) thus causing more disturbance to the nature reserve. All of this destruction and disturbance will be caused simply because the Transport Ministry claims that the existing road needs to be removed, without conducting any of the necessary studies to prove its claim.

Finally, and contrary to Mr Grima’s article in last Sunday’s paper, BirdLife Malta is not insisting on any method for the replenishment of the Ghadira Bay – let alone suggesting the same unacceptable method the government implemented at St George’s Bay. BirdLife Malta supports any proposal that will be beneficial for the ecology and tourism in Ghadira and elsewhere. However, it is our organisation’s duty to raise these valid questions and to draw attention to the obvious mistakes. We will continue to do so until the Transport Minister comes up with independent scientific studies that prove that the removal of the existing road is not only necessary but also the only solution. If this is the case, BirdLife Malta will be eager to cooperate with the authorities and do its share, but until then we do not see any reason why we should believe Dr Gatt.

Tolga Temuge

BirdLife Malta Executive Director