The Environmental Impact Assessment (EIA) for the proposed redevelopment of the former Jerma Palace Hotel should not be accepted in its present form, according to the Marsaskala Residents’ Network, which has raised concerns in a statement about alleged inconsistencies and unanswered questions in the project documentation.

In a formal submission to the environmental authority, the Network said the assessment contains conflicting information on key aspects of the proposed development, including the number of hotel rooms and apartments, parking provision, building heights, basement levels, the site area and planned coastal works.

The group also pointed to what it described as a reference in one technical report to an entirely different project – the Thermal Treatment Facility adjacent to the Magħtab landfill – which it said raises further questions about the accuracy and reliability of the documentation.

Among the issues highlighted by the Network are concerns about air quality and traffic modelling, particularly in light of stricter European air-quality standards expected to be attained by 2030.

The submission also questions the potential impact of extensive excavation on the area's geology and raises concerns about risks to St Thomas Tower and surrounding heritage features. Other issues include the protection of Marsaskala Bay, wildlife and water quality, as well as the capacity of existing infrastructure to accommodate the development.

A major concern, the Network said, is the extent to which the project could depend on additional public infrastructure.

According to the group, the EIA raises questions about the capacity of existing water and wastewater systems and the potential need for upgrades. The proposed development could also require improvements to surrounding road junctions to cope with increased traffic.

The Network is calling for clarity on what infrastructure works would be required, who would fund and carry them out, and what disruption and costs could be passed on to residents and the wider public.

“The economic viability of a private development must not be secured by transferring its infrastructure burden to the community and taxpayers,” the group said.

It argued that residents should not be expected to bear, directly or indirectly, the costs of water, wastewater and road infrastructure needed to make a private development commercially viable.

The Marsaskala Residents’ Network is also calling for a proper assessment of less intensive alternatives for the site.

Among the ideas it has put forward is an observatory and astronomy education project that could incorporate environmental education and the area's heritage. The proposal could potentially be developed through a public-private partnership involving the developer and public stakeholders.

The Network said such an alternative could generate value while protecting and enhancing the natural environment, giving the site an educational, environmental and public purpose.

“Marsaskala's bay, coastline, historic setting and residential character must not be compromised,” the group said, adding that while the former Jerma Palace site needs regeneration, this should serve the wider public interest and not come at the expense of the community or the environment.

The Network is calling for the identified deficiencies in the EIA to be addressed and for revised assessments to be made available for public scrutiny. It said the EIA should not be accepted as adequate until the outstanding issues have been properly resolved.

The submission relates specifically to the Environmental Impact Assessment process and is separate from any representations or objections that may be made in relation to the planning application.

Members of the public are being encouraged to submit their views and feedback by 10 November. The Network has also published guidance on its Facebook page for those wishing to participate in the consultation process.