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The Advantages 
(according to the Local Plan Document)

(Thursday, 26th September 2002)

This site is definitely one of the least ideal sites for this dual utility purpose which it is bound to accommodate. According to section 8.6 of the Local Plan policy document, the advantages of this site include:

a. distance from inhabited areas; 
b. good access to harbour; 
c. land is disturbed;
d. visual mitigation measures can be employed;
e. there is no need to create new access to the site;
f. the land is in public ownership. 
 
 
It is strongly believed that the above "advantages" were not studied in detail prior to deciding that they may be classified as such.



a. “distance from inhabited areas”
There is a number of sparsed dwellings which surround the site in question. The smallest distance between the site and the nearest habitation is a bare 30 metres, practically across Triq ta’ Brieghen. A number of farms are also located near this site, the nearest farms being right across Triq ta’ Brieghen, which means a distance of around 9 metres from the site. It cannot be therefore stated that there is sufficient distance from inhabited areas. It is not sufficient to consider the distance of around 370 metres from the nearest development zone boundary. The dwellings sparsed around the countryside surrounding the identified site cannot be ignored.



b. “good access to harbour”
The close proximity of the site, being in Ghajnsielem, to Mgarr Harbour should be considered in conjunction with the fact that the site which has been chosen is very far away from many Gozitan localities. This means that although the site is close to Mgarr harbour and this may permit a smaller travelling distance of the packed waste, the distance which unpacked waste has to travel is much larger. One of the arguments why an application for development to set up a solid waste transfer station within the present landfill at Tal-Qortin at Xaghra was refused consisted of the fact that Tal-Qortin is not located within a central area of Gozo. The choice of a site within a more central location in Gozo was recommended for the reason highlighted earlier that unpacked waste would have to be conveyed through smaller distances if the solid waste transfer station is set up within a more central site.


c. ‘land is disturbed”
This statement implies that the site does, not have any landscape or agricultural value because it is disturbed. By the word “disturbed” one assumes that activity has been carried out within the site which has resulted in a downgrading of the site, such activity normally consisting of construction waste tipping. A visit to the site indicates that only a very small area of the site has been used for such activities. This area covers around 6,100 square metres. This is equivalent to only around 12% of the site area. The rest of the land is completely agricultural land. There are even glass houses which extend within the limits of the site indicated. Justifying the choice of this site for the identified dual purpose because “the land is disturbed” is therefore far from justifiable. Moreover, identifying “disturbed” sites for public uses may have its own dangerous implications. It may encourage persons dumping construction waste illegally to continue doing so. Indeed, the site in question is in its present state because dumping has continued for years. Removing the dumped material from the site in question would transform the land in agricultural land once again.


d. “visual mitigation measures can be employed”
Visual mitigation measures are generally adopted when a site as a purpose which is not sympathetic with its surroundings and when the site is located a rather prominent location. This is both the case with the site in question. It may therefore definitely be the case that the site at Tal-Brieghen may be far from ideal for the earmarked uses. Adopting visual mitigation measures is not a solution for a non-sympathetic site use. As will be shown subsequently, there are other locations which are more idoneous for such a use.


e. “there is no need to create new access to the site”
It is true that there are already two streets leading to the site at Tal-Brieghen. However, the local plan documents have failed to discuss the inappropriateness of both streets for serving as access roads to a site which is bound to serve as a Solid Waste Transfer Station and Sewage Treatment Plant. The street leading from Triq l-Imgarr through Triq Cordina and Triq tal-Brieghen to the site is definitely inappropriate for conveying waste since the lower part of Triq l-lmgarr and Triq Cordina are two of the main inhabited areas of Ghajnsielem.

The street leading from Triq l-lmgarr near Santa Cecilja Tower, through the Gozo heliport and Triq tal-Brieghen is also unsuitable for the transport of waste. No one can consider such a route as being acceptable if one gives serious weight to the fact that all unpacked and packed waste would have to pass in front of the Gozo heliport terminal. Would it be acceptable if such all the waste of the island of Malta was transported from in front of the main entrance of the Malta Air Terminal? Although the Gozo heliport gives a much smaller service in comparison with the Malta Air Terminal, for Gozo the heliport terminal is serving the same function as the Malta Air Terminal. The Gozo tourism industry definitely cannot afford the setback that tourists leaving and entering the heliport terminal are greeted with truck loads of waste being conveyed from in front of Gozo’s gateway of upmarket tourism.
 

f. “the land is in public ownership” 
The fact that the land is in public ownership cannot be considered as a good enough reason for the choice of this site. The present landuse, which is mostly agricultural, should be given more consideration than the ownership of the land.

Click here to read the actual disadvantages (commissioned by the Ghajnsielem Local Council)
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