The sanctioning of changes and the approval of proposed development at a Rabat (Malta) zoo would raise serious environmental concerns, the Environment and Resources authority highlighted in its submissions to an application filed with the Planning Authority to sanction the Rabat site.

Brian Azzopardi, on behalf of Serengeti Animal Park Ltd, filed an application to sanction the change of use from a cow breeding farm to a zoo (animals with appropriate certificates). Sanctioning also includes safety fencing. The site is located Triq Had-Dingli, Rabat, Malta.

The ERA noted that through viewing aerial photos, it appears various interventions have been carried out on site, resulting in extensive site modification.

“The overall development and interventions (which include various cages, stores and other scattered structures, formal landscaping, etc.) have committed the whole site which is approximately 2,400 sqm in size. Despite not being indicated on the plans, recent aerial photos as well as photos submitted show that most of the area has been cleared from soil and replaced with hard landscaping and beaten earth.”

The ERA stressed that the proposal, which mainly includes sanctioning of works already carried out and also other proposed construction works, “is a flagrant example where no environmental considerations whatsoever have been regarded, which has resulted in illegal commitments and associated excessive land-take at the expense of the countryside.”

 Cumulatively, the ERA said, all the interventions and buildings on site have resulted and will result in the loss of a large tract of previously undeveloped land,  unacceptable proliferation of physical development, significant site formalization, adverse impacts on the overall state of the site and its surroundings and significant degradation of the physical characteristics and features of the site, amongst other things, the ERA said.

“The carrying out of such development without due consideration to the site’s surroundings has resulted in the complete degradation of the environmental quality and characteristics of the site, as well as adverse impacts on the rural character of the area. The piecemeal interventions carried out have also contributed to additional cumulative impacts both on site and on the surrounding environment.”

The authority highlighted that the proposal description states that this application is for the change of use of a cow breeding farm to an exotic animal farm. “However, whilst documentation stating that farm has ceased to operate has been noted, no development permits have been found on the site in question and no other information on the previous cow farm has been provided (such as site plan, any structures approved, etc )”

The authority declared that this situation is of significant concern, and should not be rewarded through retroactive sanctioning. “Approval of this proposal would consolidate further development intensification and sprawl ODZ. This is of concern from an environmental point of view as is the malpractice of first developing a site irrespective of its ODZ status and then requesting the sanctioning of a fait-accompli. In addition, the fact that these animals are already being kept in this site should not automatically justify the proposal.”

The ERA is also concerned that once the use is established, further indirect environmental pressures for extension and/or conversion may arise once the development is established, including the conversion of the structures for other uses, further outbuildings”

“The proposal is considered strongly objectionable from an environmental point of view.”

The ERA were not the only ones to raise concerns. The Superintendence of Cultural Heritage also objected to the application.

The Superintendence stated that the site footprint in question is located within an Outside Development Zone ‘Category 3’ Settlement, also an area of archaeological sensitivity (San Pawl Kuntent). “Pre-industrial quarries and troglodytic dwellings are located in the area in the immediate vicinity of the proposed development.”

The Superintendence said that photos confirm that the site footprint in question has been extensively modified.  “Works already carried out on site in an area that is known for its archaeological sensitivity may have resulted in accidental discoveries. Any unreported accidental discoveries made during unmonitored works are to the detriment of the archaeological record.”

Din L-Art Helwa and Nature Trust Malta also filed objections.