Application No: PA05277/96
Location : Ta’ Cenc, Ta’ Cenc, Sannat Gozo
Proposal: To develop Ta’ Cenc area into Malta’s fist ‘Heritage park’ and ‘Multi-ownership tourist hotel development’
19th February 2016
Din l-Art Helwa (DLH) has reviewed the 2015 EIS Addendum which was submitted to MEPA following a revised master plan for the development in caption.
- Din l-Art Ħelwa is extremely concerned by the renewed proposal to build 15 villas on the plateau near Mgarr ix-Xini at Ta’ Cenc in Gozo, as well as an interpretation centre and other structures outside the development zone. This proposal is completely unacceptable and should be thrown out by the Planning Authority. It goes directly against current planning policies which relate to this area.
- The Gozo & Comino Local Plan (p.158) for this area notes that “a number of fundamental points have to be observed in the development of this area. These are aimed mainly to provide free and unhindered public access around the coastline, to limit development in the lower part of the plateau (near Mgarr ix-Xini), to protect the wealth of archaeological, scenic and ecological heritage at the top of the plateau and to sensitively merge the resultant development with the surrounding landscape. Care should also be exercised in terms of restricting as much as possible the height limitation and to steer development away from the coastal cliffs and the southern escarpment.”
- Din l-Art Helwa is of the opinion that these fundamental points have not been observed in the proposed development. In particular, it was clarified by government in a letter to the MEPA Board in 2006, by the Planning Minister who approved the Local Plans, that this clause limits the development in the lower part of the plateau to the existing development, and does not allow further development in this area. Contrary to this, the proposal studied in this EIS will intensify development significantly in the lower part of the plateau (near Mgarr ix-Xini).
- The Rural Policy and Design Guidance of 2014 does not contemplate the construction of new residences outside the development zones.
- In 2006 a petition raised by Din l-Art Ħelwa against proposed development at Ta’ Cenc was signed by 10,000 persons.
- Despite the fact that the proposed number of new villas has been decreased in number from 35 villas to 15 villas when compared to the 2005 plans, in fact the total footprint of proposed development of villas on the plateau has only been reduced by 25%.
- Ta Cenc is an area of high landscape value and of high ecological sensitivity, and is included in the EU Natura 2000 network of protected areas. The proposed development will create unacceptable levels of disturbance to the site, including from ancillary development such as extensions to roads, and increased lighting and traffic.
- The EIS Addendum makes continual reference to the Structure Plan policy TOU10 which is no longer in force. The Strategic Plan for the Environment and Development (SPED), which has replaced the Structure Plan, makes no reference to TOU10. All TOU10 references should therefore be eliminated and replaced with references from the SPED where relevant. It is established that development applications are to be decided by the Board on laws and policies currently in force at the time that it was taking its decision on the application, and this should be reflected in the EIS as well as in the eventual DPA report by the Planning Authority. TOU10 is no longer in force.
- Besides the Local Plan policy referred to above, further detailed policies which refer specifically to the site are those found in the Gozo and Comino Local Plan (GCLP); GZ-Snat-2 are as follows:
In determining applications for planning permission, MEPA shall have regard to the following points:
a) safeguard the wealth of archaeological, ecological and scenic heritage found at the top of the plateau from built development, trampling and tipping;
b) restrict the tourism related development on the eastern flank of the promontory;
c) encourage the upgrading of the existing facilities near the hotel provided that development of tourism related or other facilities are maintained at a minimum distance of 50m from the coastal cliffs and sufficiently away from the northern escarpment;
d) safeguard the area indicated on MAP 13.6 for free and unhindered coastal access;
e) protect a pedestrian path shown on MAP 14.11-E running parallel to the northern carriageway route which links the hotel to the Villa Area for free and unhindered public access;
f) ensure that the overall height of the development does not increase in the area closest to the northern escarpment or the coastal cliffs;
g) restrict development within 50m of the inland most tier of the coastal cliffs anywhere along their length;
h) prohibit developments and/or activities that may negatively affect the colonies of breeding seabirds in the cliffs below Ta’ Cenc. This includes both land-based and sea-based activities.
- A superimposition of Map 13.6 of the GCLP and the proposed masterplans show the Villa area marked in red to lie within the area which is clearly specified as Coastal Viewshed Protection Zone GZ-COAS-1
Unless otherwise specified in this policy document, development in these areas shall be restricted to the maintenance of existing traditional coastal features with no lateral increase in built footprint or vertical increase in height of the built structures. The relevant coastal areas may also be safeguarded for their ecological, natural heritage or landscape importance as indicated through policy GZ-RLCN-1.
- There is only one revised drawing submitted for the application PA 5277/96 which is a master plan. This does not clearly indicate the works involved and it is hard to appreciate the works described in the EIS addendum. No plan/s indicating existing and proposed layouts in the typical MEPA colours (Red and yellow) are available. In addition to this no sections through the site were submitted. The land formation here has steep contours so an understanding of level is of paramount importance to evaluate any submission. DLH requests that the necessary drawings are submitted should this application proceed. No plans showing proposed landscaping, access routes or lighting have been provided so it very hard to understand how this EIS addendum has arrived at its assumptions and conclusions.
- The visuals submitted, especially viewpoints 2, 6, 8 and 9 show that the development has a negative visual impact from most of the angles and approaches to the site.
- The Superintendence of Cultural Heritage had written to MEPA in 2006 expressing concern on the impact of the proposed Ta Cenc development on the area overlooking Xewkija. This area contains an important stretch of pre-historic landscape. The Ta Cenc landscape was described as one that should be valued as a depository of the country’s cultural heritage. In 2008 the Superintendence called for a total ban on the Ta Cenc development and asked MEPA to schedule the entire Ta Cenc area, a measure which would preclude any development in the sensitive stretch of land, including the villas at Tal-Gruwa and at Mgarr ix-Xini.
- The EIS Addendum notes that the landscape value at Ta Cenc as being of high landscape value. as follows:
2.3.1 The value of the landscape at Ta’ Ċenċ is considered as being high. This is due to several factors including the following:
- The presence of several unique individual features which merit protection, such as rare species of flora and fauna;
- the presence of spectacular land forms;
- the SAC and SPA status assigned to the area;
- the presence of unique archaeological features;
- the scenic quality of the site and surrounding areas;
- the overlap of all of the above features and qualities in one single area;
- the irreplaceability of the landscape;
- the views that can be enjoyed from the area, particularly the ones to the south and east; and
- the fact that there is substantial potential for enhancement of features, which have degraded over the years and the restoration of the landscape.
- The new Strategic Plan for the Environment and Development (SPED) of 2015, which has now replaced the Structure Plan, states that that the location of new residences should be guided within urban areas, and that rural areas must not be “exploited by uses which are not legitimate or necessary”. Granting permission to build private villas at Ta Cenc would continue the relentless destruction of the countryside.
- The SPED clearly states that further land take-up in rural areas should be considered as a last resort and only “where it is essential for the achievement of sustainable development.” There is absolutely nothing sustainable about building more ODZ villas on the Ta’ Cenc peninsula.
- The whole area inclusive of the hotel site was designated as Natura 2000 site Rdumijiet ta’ Ghawdex, Ta’ Cenc by GN 859/08. The has been classified as a Natura 2000 site both for the habitat, Special area of Conservation (SAC) and the birds directives site as a Special Protection Area (SPA) . The sensitivity of the site would require in depth studies due to the increase in light pollution, noise pollution and possible pathways disturbing habitats and bird colonies. The introduction of new species in the landscaping would also need to be assessed. The EIS addendum states that as the hotel extends seawards it would encroach on part of the habitat of the Thermo-Mediterranean Coronilla garrigue.
- The Draft Natura 2000 Management Plan for the SAC/SPA at Ta Cenc (Rdumijiet u l-Inhawi ta’ Ta’ Cenc) notes that “Further development in the SAC can have a number of impacts on the site, especially if not restricted to disturbed areas and if located close to important habitat types: important factors are destruction and/or fragmentation of habitats, impacts on adjacent habitats from construction activity, and disturbance of wildlife.”
- The draft Management Plan also notes that “In case parts of the site are further developed for the purpose of the construction of villas, additional infrastructure might be needed as well. This could result in impacts such as destruction and/or fragmentation of habitats, impacts from construction activity (including dust, littering, trampling, noise and vibrations), and disturbance of wildlife.” The cumulative impact of any further development on this site therefore also needs to be evaluated in this proposal.
19th February 2016 – submitted to MEPA