The Environment Commission which was set up within the Pastoral Secretariat of the Archdioceses of Malta and chaired by professor Victor Asciak, said the application for the development should be rejected. It listed a number of reasons behind this decision in its 20-page report presented to Curia officials and also to the Malta Environment and Planning Authority.

This is the second opinion paper published by the commission since it was set up nearly a year ago. The first paper was about the proposed temporary landfills in the vicinity of the Mnajdra Temples. This plan was later scrapped by the government.

The commission’s position papers do not necessarily reflect the opinion of the Maltese Church’s officials. In fact, Curia PRO Charles Buttigieg explained, the church officials did not express themselves in favour or against the position paper on the landfills. It is up to them whether to comment on the opinion paper, he said.

Prof. Asciak explained in detail the reasons behind the commission’s decision against the proposed development. The land in question, around 500 tumuli in all, was owned by the church but it was transferred to the government by way of an agreement ratified in February 1993.

The agreement stipulates that one of the conditions of the transfer was “to promote the safeguarding of the environment and the development of agriculture and to meet the country’s most pressing social requirements such as social housing and public utilities, as well as for humanitarian, educational and cultural purposes”.

Prof Asciak said the proposed development goes against this agreement made between the Church and the government over 10 years ago. Moreover, he said, the proposed development is also in direct conflict with Mepa’s structure plan. He said the loss of some 50 hectares of land currently being used for agriculture in a country where agricultural land is very limited can in no way be considered as encouraging major improvements in agriculture and horticulture, as required in certain policies of the Mepa.

The report goes on to say that “this clear breach of policy is further compounded by the fact that the site lies within the rural conservation area and part of it is designated as an area of agricultural value.

On geology, the commission agreed with the Environmental Impact Assessment (EIA) that the proposed landscape topological modification is rather limited and that while there will be risks of soil erosion during the construction phase of the project, these would be limited.

Since the golf course would use much less fertiliser than other agricultural land, the EIA said that the risk of contamination of the mean sea level aquifer – the main source of potable water in Malta – is not significant. However, the commission said the contamination risks had not been evaluated properly and sufficiently.

Professor Asciak said that the most evident negative impact of the proposed development (as identified by the EIA itself) is the loss of good agricultural land. This impact, he said, was judged to be substantial but reversible. “This argument does not hold any water. The degree of reversibility of the various impacts has to be assessed not only in the light of the natural and physical life-

supporting systems but also in the light of social and cultural constraints. The proposed development is more likely to lead to a disintegration of the social and cultural community of farmers of the area and this would be very difficult to reverse,” he said.

Other considerations of the commission included the loss of character of the current landscape, including the removal of rubble walls. The proposed landscape change will not fully respect the local characteristic features of the Maltese rural landscape.

“While it is difficult to define exactly the nature of such a landscape, one would wonder whether a well-tended golf course landscape would qualify as ‘distinctive’ to a discerning up-market tourist,” the report said.

The commission’s report quotes a report by Hawtree and Son which stated that “serious golfers would only travel to an area where there is more than one course, preferably five or six so that a different course can be played on each day of a seven-day tour.”

Professor Asciak said that the development of a golf course on the Verdala site would not constitute a sustainable tourism development due to the serious environmental and social impact this would have on the area.

The report conclusions states the following:

The EIA fails to properly assess the significance of negative impacts of the proposed development on a number of key resources including hydrology, agriculture, landscape, ecologically-sensitive habitats and cultural identity. No matter how skilfully portrayed, the proposed development is not in line with sustainability principles and is essentially a breach of land-use and other policies.

The commission urged the decision-makers to take a bold step in favour of sustainable development by fully addressing these concerns, and called on

the authorities to refuse the application.