Dear Mepa, as protectors of the environment in Malta, we write to you about development applications for sites at Portomaso, in particular with reference to approved Outline Development Permit PA01270/95, and current application PA04096/08.

It is Mepa and EN standard practice that whenever an Environmental Impact Study was carried out as part of the application process for the particular site, and when additional development work is proposed for parts of that site not considered for development in the original permit application, the developer is required by Mepa to submit a Project Description Statement for the Mepa Environmental section to determine whether the impacts of the additional proposed work is to be considered under the update study to the original EIS.

It is commonly know that the original EIS for the Portomaso development had considered a very controversial application under PA01270/95 converting the former sole tourist use by Hilton International of the land granted to the original developers by government, into a mainly commercial and residential development, with a newly constructed Hilton Hotel. It is equally well known that the permit had defined the extent of the development allowed on the site to a new hotel, an office tower, a marina, and 250 residential units. The government was paid by the developers to extend the use of the site from sole tourism use, to the uses applied for under the original permit.

Since then the developers have extended the hotel by another 80 bedrooms and built another large hotel pool on previously protected coastline:

• They increased the number of apartments from 250 to 400

• They built another 50 apartments at what they call block 30 on a zone approved in the original permit as a landscaping zone

• They are currently building another 80 apartments in a 13-floor building called 31on a site zoned for a five-floor building, part of which has taken up one lane of the previously approved two lane public road approved in the original Portomaso outline permit

• Now they are proposing to build another 60 apartments on an ecological zone protected by the original EIA.

Surely, before this application can be considered any further, the Mepa Environmental section should require the developer to carry out additional environmental studies as an extension to the original EIS, dealing with issues such as:

• impacts to the ecological zone,

• impacts to the historical bastion wall,

• impacts to public access to the beach and to the marina,

• pollution causing emissions caused by the huge increase of parking required by the hotel extension, the new blocks 30 and 31, and the new proposal for 60 apartments on the ecological zone.

A TIS update should also be requested.

The Superintendent of Fortifications and the Natural Heritage Advisory Committee of Mepa have already expressed their opposition to this latest proposal on the ecological zone in front of the bastion; these opinions should be considered in a properly well scoped update to the EIA, including the further studies referred to above, and other studies noted during the relative public consultation exercise required by law to determine the Terms of Reference of the EIS update.

This procedure has previously been applied to most major projects.

With the Mepa reform this procedure should become more so the norm, not the exception, and Mepa is expected to seriously apply this procedure thoroughly to all proposals which in any way produce new and additional impacts beyond the studies of any previous EIS.

Peter Richards

Kent

UK