Ralph Cassar, AD Secretary General and councillor in H'Attard, and AD Chairperson Carmel Cacopardo today submitted AD's comments regarding the Central Link EIA to The Environmental Resources Authority.
The general approach of Infrastructure Malta is very clear, AD says. The Central Link project seeks to reduce traffic congestion, through the construction of new roads, the widening of existing ones and the upgrading of junctions. It is envisaged that, as a result of doing away with bottlenecks, the level of emissions will be reduced, thereby improving air quality, the time lost in traffic will be eliminated as well as the over-consumption of fuel, resulting in savings in both the fuel used and the emissions generated. This approach is flawed on many levels.
Chapter 3 of the coordinated assessment examines and assesses alternatives to the proposal under consideration. Six alternatives are considered, ranging from a do-nothing option to a number of specific infrastructural solutions, including a combination of such solutions (see page 66 of the coordinated assessment). The coordinated assessment ignores one clear and specific objective of the National Transport Master-Plan 2025, that is a reduction in the number of cars on our roads. Approved in 2016, this master plan establishes a number of operational objectives for the implementation of transport policy. Objective 2.2.2 establishes the following: “Provide alternatives to private vehicles to encourage sustainable travel patterns and reduce private vehicular demand in the congested hub area”. The master plan explains that “this objective has been developed since the data shows that about 50 per cent of trips are under 15 minutes, illustrating that mobility is produced at a local level on very short paths.” (see page 95 of Master Plan)
The EIA presented by Infrastructure Malta fails to consider the implementation of this objective among the various alternatives that can be used to address traffic congestion, AD says. Public transport and the provision of measures such as public transport corridors – one of the policy measures in the Transport Master Plan is ignored, as are other measures on sustainable transport. It is pertinent to note that during 2018, 53.4 million people had used public transport: an increase of 11.25% over 2017. It is clear that the public is responding through the uptake of the sustainable transport options being made available. A bus rapid transit system is a policy measure which can be implemented in the short to medium term to further increase patronage of public transport. The Central Link will push the main Valletta-Rabat public transport service further away from residents, making it less accessible. A road map for implementing the objective of reducing the number of cars from our roads is the only sensible way forward. It is the long-term view which is missing in our transport policy. Once this road map is clearly defined, then it would be easier to reassess – and probably substantially redefine and downscale – the Central Link project on the basis of a realistic alternative.
The EIA, according to AD, is not clear on various other points:
1. It assumes that vehicles will still be powered by the internal combustion engine by 2045 – ignoring the real possibility that zero-emission vehicles will be the norm in the near future. The projections for emissions assumes business as usual.
2. The lowering of part of the road (p.57) is assumed to reduce noise pollution on Triq Tumas Chetcuti, Ferdinandu Inglott and Oliver Agius. The EIA does not indicate how lowering the road will reduce noise pollution. Lowering a road will not reduce air pollution. Shifting air pollution from one place to another will not solve the air pollution issue.
3. The assumptions made in the conclusion that without the Central Link air pollution will increase ten-fold are flawed. The assumption that the ICE will still power vehicles by 2045 is flawed. Infrastructure Malta’s reliance on road building to solve transport related issues is short-sighted. Induced demand will cancel out any short term gains. Other measures mentioned in the Transport Masterplan – which is official government policy – should have been taken into account in the EIA.