How long till the Government announces a hotel on Comino?

You might think me mad for saying this, but would you be surprised if this happens? In what appears to be a new development era in Malta, this government is sparing no expense in pandering to Maltese developer’s insatiable appetite for environmental destruction. The following are justifiable reasons why we should expect the Maltese government to announce the development of a luxury hotel in Comino.

Comino, the islet of Cominotto, and the Blue Lagoon in between. This beautiful nature reserve might be looking forward to the development of a new luxury hotel in the coming future.

Background to Comino

Comino is the third largest island in the Maltese Archipelago, and is considered to be one of the most spectacular sites in the country, boasting various gorgeous bays and bathing waters, ecological biodiversity and a rugged beauty that has so far escaped the clutches of Maltese developers.

The importance of Comino can be exemplified by its recognition as a nature reserve in Malta’s Structure Plan in 1991, and following Malta’s accession to the EU it was recognised as a Natura 2000 site, and also designated as a Special Area of Conservation (SAC) under the Habitats Directive and as a Special Protected Area (SPA) for birds under the Birds Directive.

A brilliant article by Din l-Art Helwa provides some interesting history into Comino. It describes how in 1960, hotels and bungalows were proposed on the island, including a restaurant on the islet of Cominotto and suspension bridges to connect Cominotto with Comino. Thankfully, this monstrous project never transpired, and we can now still enjoy Comino in its almost complete natural form.

However, a hotel and bungalows were constructed on the island in the late 1960s, during Malta’s post-independence development boom. Comino escaped considerable development until a pig farm was constructed on pristine land in 1979 next to a coastal gun battery. The hotel is still operational, but the pig farm was decommissioned in 2011 and returned to the government. This abandoned farm is currently in a state of disarray, and opens up a unique opportunity for developers to get their hands on land in Comino.

Subtle hints on developing Comino

MaltaToday provided a vivid insight into the current state of this pig farm in April 2014. This article cites efforts by Din l-Art Helwa to request the government to rehabilitate the land to its natural state, as the updated structure plan for Malta could allow redevelopment of this farm for tourism purposes. This NGO also called for the development of an educational centre in the case that the land cannot be rehabilitated, so that the land could at least be used towards the benefit of the public.

The decommissioned Pig Farm. (Photo credit: MaltaToday)

However, the government has already been dropping subtle hints about the possibility of a luxury hotel replacing the pig farm. In this MaltaToday article, a consultation document on the Strategic Plan for the Environment and Development (SPED) specifically refers to tourism development on “previously developed land” in Comino. Additionally, this draft document hints at making ‘better use’ of ‘previously developed land’ in Comino for ‘tourism and recreation purposes’.

Fast forward to June 2015, and the government introduced a ‘feasibility’ clause in SPED. The revised document states that “The sustainable use of land and sea resources depends on the efficient use of available space. In preparing policies, plans and programmes the government will adopt a sequential approach to the use of land where development should be guided:

• Firstly to the re-use of existing developed land and buildings (through change of use)
• Secondly to re-development of existing developed land and buildings, and
• Finally, where no other feasible alternatives exist, to the use of vacant land”

• 

  The area on which the pig farm was constructed is around 3.42 ha, roughly 34,000m2

This updated document sets a dangerous precedent for the redevelopment of the pig farm on Comino into a luxury hotel. The area encompassing the pig farm is relatively big, around 34,000m², or roughly the same size as the area occupied by the Ta’ Qali National Stadium. As you can imagine, this is literally a gold mine for any developer in Malta, whom you can probably hear salivating and rubbing his hands somewhere in a Government department.

Even though the local plan for Comino stipulates the island’s status of Special Area of Conservation and nature reserve, and only allows developers to “upgrade” the existing tourist complex and hotel if these are “compatible with the sensitivity of the surrounding context”, it seems as though the necessary steps are being laid for new development in Comino.

I often use the phrase “build a hotel on Comino” as a euphemism for an insane development proposal that is beyond the limit of rationality. Unfortunately, it seems that this notion might now become a reality, probably in the name of ‘economic prosperity’ or ‘national interest’. I am really curious to see how the Government will try and sell this one to the public.

Game of Thrones: How MEPA screwed up Malta’s best filming opportunity yet

Game of Thrones is an HBO fantasy drama adapted from George R. R. Martin’s novel series A Song of Ice and Fire. Despite a ‘soft’ first season release in 2011, anticipated mainly by fans of the novels, the show quickly achieved mainstream commercial and critical acclaim. In what would could only be described as a stroke of luck, Malta was selected as a filming location for the first season based on its abundance of natural and cultural locations that embody the fictional continent of Westeros. However, a filming choice sanctioned by the Malta Environment and Planning Authority led to an environmental catastrophe, causing HBO flee the island to more professional working pastures.

Please take us back HBO! We promise to behave this time round.

The prominence of Game of Thrones is not only exemplified by its list of accolades (including several Emmys and a Golden Globe Award), but also by its worldwide distribution. With an ever growing fan base, every new season boasts a marked increase in viewership – rising by 20% between the second and third seasons. HBO parent company Time Warner have reported that the series averaged 14.2 million viewers per episode in 2013, inching it closer to passing The Sopranos as the most watched HBO series of all time, and expected to claim this title at the end of this year’s fourth season.

In anticipation of the premier of Game of Thrones Season 4 on Sunday 6th April, I think it would be ideal to recall Malta’s best missed filming opportunity: After filming Season 1 in Malta, a protected area was damaged, the production company was blamed by Malta’s environmental authority (MEPA),  production moved to Croatia instead, and Malta missed it chance at a lucrative filming deal and free publicity!

Filming for the first season began in Malta in autumn of 2010, where scenes for King’s Landing (including the Sept of Baelor and the Red Keep) and the Dothraki Wedding (including Magister Illyrio Mopatis’ house) were filmed. Given the diversity of regions in the fictional continent of Westeros, some of which are found in Malta, the local filming industry could have easily positioned itself in a long and fruitful relationship with HBO throughout the continuation of the series.

However, filming took a sour turn when sandy material laid in Dwejra Heritage Park, a protected area, during the filming of the Dothraki Wedding adhered to the rocks beneath.

(Above) Game of Thrones Season 1 episode 1 showing the Dothraki Wedding scene and the sediment that was deposited in the protected area. Dwejra is characteristically known for the Azure Window also pictured above.
(Below): an aerial photograph showing the filming site (circled in red) before filming occurred.

Producers of the show were given the green light by MEPA to lay sand over the rocks near the Azure Window, a situation which created “outrage among residents and environmental NGOs who [became] worried that the protected fossil-rich area may [have been] severely damaged”.

The production company failed to comply with the permits issued, using a permeable membrane (pictured above) to cover the protected land area from the sand. The sand seeped through, causing it to become cemented onto the land beneath. MEPA claimed that the production company failed to adhere to the necessary permit requirements, and that it used damaging heavy machinery during the initial clean up processes.

In another MEPA gaffe, heavy machinery was used to clean the affect site, which subsequently damaged the rich fossil bed beneath. There was no need for concern though, since MEPA official quickly rushed to stop the operation – you would think they had learned their lesson the first time round to affix an official in an already damaged site (Photo credit: TimesofMalta)

The saga ended with a local production company shouldering the blame for the entire disaster, in which it was fined €36,500 by local authorities. As generally happens in Malta, this incident subsequently pushed MEPA to propose new conditions for all filming permits issued thereafter.

Is MEPA to blame?

MEPA’s role in this filming fiasco has much been debated in the local media, with lots of tiptoeing around the issue. MEPA even admitted that in had not been present during the laying of the sand, which it blamed on the production company for not informing the authority sufficiently in advance.

In any reputable country other than Malta, Environmental Agencies would shoulder the responsibility of such events. Instead, MEPA stated that ” it [is] impossible for Mepa enforcement officers to be always present during any form of development” – Oh Please. Such comments merit a Westeros style ‘beheading and a public display on a pike’.

It must have been logistically impractical to have MEPA environmental officials on a site that is going to be altered to such an extent – whilst keeping in mind that Dwejra is a candidate UNESCO World Heritage Site, part of the Natura2000 framework and locally classified as an Area of Ecological Importance (AEI), an Site of Scientific Importance (SSI),  a Special Area of Conservation (SAC), a Nature Reserve, a Bird Sanctuary and also boasts an adjoining Marine Protected Area (MPA).

Of course MEPA is to blame, since this case was unequivocally unique – filming requests of this magnitude and specialisation do not happen every other week in such protected areas. To add insult to injury, then MEPA director Michael Seychell stated that the tampered site was simply ‘bare rock’, so there was no cause for concern. This is obviously another attempt at mitigating the damage caused to the site.

In fact, an independent assessment of the impacts of filming found that:

• “Some damage [was] observed…as evidenced from freshly fractured fossils and damaged ichnofossils…beneath seemingly fresh heavy vehicle tyre tracks”
• “direct damage to karstic features within the south‐western and western reaches of the [filming area], closest to the sea”
• “[Limited] landscape and visual scene impacts…[more evident] at the micro‐scale…within the [filming area]… visual impact is related primarily to the characteristics of the deposited sediment which left behind a reddish residue on the affected rock surface”
• “The noted damage to irreplaceable fossil and ichnofossil features (whether such damage was caused by filming and ancillary activities, or by unrelated visitor pressures, or by both) constitutes a clear threat to the integrity of the site’s geological,
  geomorphological and palaeontological heritage; similarly, the observed damage to karstic features also disrupt the overall integrity of the protected area”
• “Possibility [for burial under sediment] could not be excluded for small sedentary species that live in crevices and fissures in the rock, under overhangs, under stones, or at base of the vegetation that was buried”
• “Vegetation in such areas was found to have a number of animal species associated with it suggesting that the partially buried plants may have had fauna that were negatively impacted by sediment transported or spilled from the area of deposition”

The Game of Thrones filming incident was a major MEPA gaffe, that undoubtedly caused damage to a protected area and made HBO flee Malta faster than Samwell Tarly running away from White Walkers.

(Above) – Game of Thrones season 1 episode 5 – The scene where Jaime Lannister arrests Ned Stark at Petyr Baelish’s brothel
(Below): The filming location for this scene is in Malta’s old capital Mdina

Whilst I am highly anticipating the premier of Season 4 of Game of Thrones, I am gripped with a small sense of melancholy at the thought of not seeing Malta representing Essos and Westeros – would it not have been awesome to see the Grand Harbour in the Battle of Blackwater Bay? Alas that will never happen, all because Malta has an incompetent and irresponsible Environmental Authority.

UPDATED – Is Maltese Fashion TV show ‘Venere’ polluting a protected area?

It is well renowned amongst the Maltese community that environmental laws are all bark and no bite. Despite this shameful reality, I find it vile how some people think it is justifiable to use a protected area for filming and proceed to pollute or cause harm to it, while at the same time doing it on national television!

I came across the following promotional video on Facebook for the upcoming installment of a Maltese fashion oriented television show called Venere. This show, set to air on Sunday the 3rd November, shows a collection of models (with really uncomfortable faces) being splattered on with what appears to be relatively viscous water based paint.

This promotional video has been shot at Ghajn Tuffieha, which can be identified from the characteristic blue clay slopes (see picture below). The site is listed as an area of ecological importance and as an area jointly managed by MEPA and the Gaia Foundation. Moreover, the areas around the blue clay slopes are also listed as a Special Area of Conservation as part of coastal cliffs under the Flora, Fauna and Natural Habitats Protection Regulations 2003 (L.N. 257 of 2003).

The Blue Clay slopes of Ghajn Tuffieha are unique to the Maltese Islands

As such I would like to pose two very simple questions to the Venere production team:

• Did you obtain a permit to throw paint around a protected area?
• How did you clean up after yourselves (if at all), or did you just leave the paint to wash down the slopes onto the small beach below and into the sea?

A still from the above video clearly shows that the paint has two destinations: a frightened model and the very dry and water yearning clay beneath her bum

Furthermore more, I am pretty confident that the provision of a filming permit in a protected area limits certain practices that can be carried out within in. The haphazard sloshing of paint is most certainly one of them, as this itself is illegal under several legal notices covering marine pollution, environmental protection, chemical use, waste and pollution! An example of these is L.N. 344 of 2005 Environment Protection Act (CAP. 435) Abandonment, Dumping and Disposal of Waste in Streets, and Public Places or Areas Regulations, 2005 – which clearly states that it is illegal to dispose of litter that includes:

“any other object, material or substance deposited in a public place causing or adding a disorderly appearance of such place or detrimentally causing an effect on the proper use of the place, or which may, in general, increase the risk of health or environmental hazard to the public or the surrounding environment, or which may be a nuisance to the public”

And just to be even more thorough, a pubic places is defined as

“any place, privately owned or otherwise, to which the public has access, and including a street, sea, playing field and playing ground, field, valley, beach, fountain, watercourse, reservoir, well and swimming pool”

Also, to the Venere production team, you may want to rephrase the word dune to slopes ahead of your Sunday programme, Dunes are generally made of sand, not clay.

* * *

Here is a reply I received on behalf of the Venere production team, which thankfully shows that I was not right and that the filming location was respected:

Dear Mr. Borg Micallef,

I am part of the Venere production team. I would like to show my appreciation for your work in writing environment-related-articles. I have environmental issues at hearth as well and most often I think that such issues are either ignored or taken with a pinch of salt. Hence I would like to thank you for your invaluable contribution, especially since I am aware of the commitment one needs to be able to write blogs and articles with such frequency.

However, I would like to kindly ask you to check your facts before publishing such insinuations and possibly slander. We would have appreciated if you had asked us your questions directly and we would have duly obliged. We would have not known you were asking them if someone had not indicated your blog.

We did not film in Għajn Tuffieħa; we filmed in Selmun. The viscous liquid you have seen in the promotion is not paint; it is milk, water and food colouring. That liquid was thrown on our models, we care for them and we care for our Islands. I would like to invite you to watch this episode on TVM next Sunday at 18:40 so that you can ascertain yourself that no trace was left on the slopes after we left.

We have been doing Venere for the past seven years. Practically all shots are taken on location and a very good number of the locations, we have had the privilege to shoot in, are pristine nature sites. We would not dare ruin them. We care for and really appreciate these locations and when we show them on national television we hope that more of our audience will grow to appreciate them, as we do.

A yacht marina in Gozo – Where exactly?

Islands in general have historically relied on the great seas and oceans for commerce, subsistence, travel, recreation and so on. Most harbours that are still used in the present day extend back centuries in their use, sometimes millenia. Malta is no exception to this case, which boasts one of the most celebrated natural harbours in the world. However, given its high population density, and increasing amounts of boat owners living and visiting the islands, is there room for more docking space in an ever shrinking coastline?

Mgarr Harbour – the only major port facility currently available in Gozo (Photo credit: bobchin1941)

The place of concern is Malta’s sister island, Gozo, where the current Government has issued a call for expressions of interest to build a cruise liner terminal and yacht marina. Apparently, the response has been “bigger than expected”, which is to be anticipated given how coveted marina space has become in Malta.

Gozo has only one major port facility, the Mgarr Harbour, that currently also operates the Malta-Gozo shuttle ferry service on a daily basis (pictured above). The biggest issue about building such facilities in Gozo is the obvious lack of space, since the vast majority of the island’s coastline is protected by some form of terrestrial or marine treaty which ‘in theory’ should inhibit the presence of marinas or terminals.

All protected areas in Gozo as obtained from the Malta Environment Planning Authority’s website and MEPA’s MapServer. The green line on the coastline indicated that areas which ARE legally permissible to develop.

 All terrestrial areas in red is land that is legally designated as  a Special Areas of  Conservation (SACs), Special Protected Areas (SPAs) and/or are part of the Natura2000 framework – all of which enjoy European protection. There are also three Marine Protected Areas (MPAs) in Gozo:

1.   an area in the east of Gozo that extends between Xwejni Bay next to Marsalforn and the White Rocks in Pembroke Malta – this is the entire area which covers the Neptune Sea grass meadows Posidonia oceanica (the green areas in the sea in the map above) which are internationally protected.
2. an area next to Dwejra Heritage Park
3. an area next to Mgarr ix-Xini.

Basically, the only area which is legally permissible to construct any form of maritime hub is depicted by the green line along the Gozo coastline in the map above, which is practically a fourth of the island.

But can we build there?

There needs to be a lot of planning when it comes to building a marine or terminal, but the rule of thumb is that the area needs to be at sea level, in order for boats and ships to berth without problems. Unfortunately, Gozo is not a smooth surfaced island, with many elevations and depression along the coastline. This can be illustrated by the following contour map which is freely available from MEPA’s MapServer online.

A contour map plots the highest point on a land’s surface. In this case, light greens indicate an area at sea level, while darker greens and browns indicate areas that are higher than sea level

As expected, the light green areas are located at the coast, with the majority of these being either bays or beaches:

• A – Dwejra
• B – Wied il-Mielah
• C – Wied Ghasri
• D – Marsalforn/Qbajjar
• E – Ramla l-Hamra
• F – San Blas
• G – Dahlet Qorrot
• H – Hondoq ir-Rummien
• I – Mgarr Harbour
• J – Xatt l-Ahmar
• K – Mgarr ix-Xini
• L – Xlendi

As can be observed from the above figure, there is really very little option in the choice of constructing this marina or cruise liner terminal, this barring also logistic issues of whether the site is easily accessible and so on. The current Gozo minister has pledged to not build this maritime monster at Hondoq ir-Rummien, which has recently been in the headlines over contentious development issues. He has instead suggested that an ideal site would be Marsalforn, which is located inside the MPA.

The only thing we can do now is wait and observe how this issue unfolds, but I am certain (based on the long standing faulty development decisions taken by the Gonzi administration), that the legal designation of MPA, SPA, SAC or Natura2000 will do little to prevent juggernaut projects such as this one from proceeding.