Front Ħarsien ODZ has made the following submission to MEPA with regards to the Munxar ‘Agro-tourism’ Proposal.
Submissions on Munxar ‘Agro-tourism’ Proposal – Front Ħarsien ODZ
Since it is incompatible with Rural Policy, the proposal should be rejected at the outset:
a. Given that the accommodation will have 8 rooms, how can the conference center, restaurant, beauty and therapy salon, bar, boat rides and beach services all be economically viable? If these will need to rely on visitors who do not stay overnight (as suggested in the development application 2.3) then these facilities are not ancillary to ‘agro-tourism’ as defined in Rural Policy 4.4.1 and are not permissible on agricultural land
b. Rural Policy 4.4 (4) states that a new building for agro-tourism may be considered provided that (c) “the farming activity has been in operation for five years prior to the application.” This means that the would-be applicant first needs to convert his farm from fodder to honey and wine production, raise his sheep, horses, donkeys, rabbits, chickens, other poultry, goats and pigs, as stated in his plans, he must grow whatever he plans to grow in his greenhouses for five years and THEN he can apply for a permit to build agro-tourism accommodation and ancillary facilities.
c. The Rural Policy says only 400ms floor space is allowed for new agro-tourism accommodation (4.4 (4d)) whereas the application is for 450 ms footprint (4). This suggests that the building is significantly larger than that allowed by the Policy and permission should be refused for this reason.
Should the proposal still be given consideration by MEPA, Front Ħarsien ODZ suggests the following terms of reference for EIAs:
a. Impact of influx of visitors to Munxar upon local residents and visitors to the area, and businesses in the vicinity.
b. Impact upon residents in terms of loss of recreational space in Marsascala; survey of alternative areas for hiking, legal hunting and diving to be identified.
c. Assessment of the degree of likely involvement of local residents with the agritourism project, and social implications if Munxar becomes ‘off-limits’ to the locals.
a. Detailed infrastructure costs incurred for parking, refurbishment of roads and safety of visitors.
b. Costs of extending sewage system to service the facility.
c. Costs of extending water services and strain this will have on our water availability (no water catchment facilities are present or mentioned in the proposal)
d. Assessment of the impact of 3 buildings proposed on aesthetic value of the area and the subsequent devaluation of properties overlooking Munxar.
a. Impact upon farmers and their families’ livelihoods (for fields used for fodder)
b. Impact of the introduction of water, fertilizers and pesticides in an area previously untouched except for fodder production.
a. Heritage appraisal of nearby structures that would suffer limited accessibility and possibly damages due to heavy machinery operated in their vicinity.
a. Comprehensive survey of native and endemic species of flora and fauna including assessment of their rarity and of their national significance.
b. Depletion of gene pool for endemic and native species and the overall impact of this project on Malta’s biodiversity
c. Economic assessment of costs related to rehabilitation of the area.
d. Impact of excavation, pesticide and fertilizer use and possible slurry runoff on areas of ecological importance close to the facility.
e. Impact of the newly-introduced agricultural activity on the ground water levels in the area
f. Impact of the whole project on the surrounding areas of soft rock.
g. Feasibility study related to the introduction of sensitive agricultural plants and livestock in an area with a strong prevailing wind and low-quality, thin layer of soil.
a. Estimates of services required (water, electricity) and the impact of this for the rest of the country in terms of sustainable consumption, emissions and capacity of the area.
b. Impacts upon rainwater run-off and flooding if 10,000 sq m are paved over.
c. Estimate of further carbon in atmosphere if soil is removed during excavation.
d. Impact upon traffic and public transport in terms of capacity and emissions produced.
e. Impact upon air-quality if increase in traffic is found to be significant.
f. Waste generation and the cost of attending to this – waste collection facilities, recycling etc. and their costs.
g. Possibility of attracting rodents and other undesirable animals in an area previously undisturbed (due to the presence of food, waste and animal feed).
h. Evaluate the term ‘sustainability’ as used in the project proposal – which renewable energies are used, is the building constructed using eco design and energy-efficient, sustainable materials, how will the owner mitigate the use of resources such as fuel, electricity and water.
a. Consultation with with MTA, AAC, ERA and Dept of Health, as stated in Rural Policy.
b. Evaluate the proposal’s compatibility with the agricultural policy. The term ‘agritourism’ by definition should encourage diversification of existing farmers, and not the creation of a hotel-like facility that is incompatible with the original character of the area. The need for the project should be evaluated in light of the Xrobb l-Ghagin Natural Park, a few kilometers away.
c. Impact of the project on the landscape value of the area to be evaluated.
d. The footprint of the project as a whole should be evaluated as a whole. Apart from the accommodation facilities, the farm, greenhouses, slurry pit, animal feed silos, water reservoir, parking and access roads will increase the footprint considerably more than what is included in the proposal.
e. Although the construction is in an area of Schedule 3, the agricultural activity is proposed to take place on an area of Schedule 2. Due to its ecological significance, the impact of pesticides and fertilizer runoff is a serious issue. The proposed agricultural activity should be Permaculture.