“On behalf of Alternattiva Demokratika – The Green Party I am submitting the following comments re EIA indicated in caption :
- In view of the fact that Local Plan was never subject to a strategic environment assessment in terms of the relevant Directive of the EU as transposed into Maltese legislation the coordinated assessment should have delved deeply into the cumulative impacts of the known projects in the area.
- Unfortunately, after perusing the documentation available in no way can it be said that the cumulative impacts of the known projects in the area have been assessed. There are at least five major projects around the perimeter of St George’s Bay. The impact of all of them should be considered cumulatively. Limiting the assessment to the excavation waste generated by the project under consideration does not address the impacts generated being seriously addressed. (around 336,000 cubic metres of waste of which 85.19% will be inert waste).
- Cumulative air quality impacts in particular those resulting from traffic are dealt with very scantily. ERA has rightly proposed that the traffic associated with the nearby Villa Rosa development be considered. This is not adequately done and should be extended to consider traffic impacts resulting from other major projects in the area.
- The request of ERA to address the consideration of impacts generated by the Villa Rosa project should not be limited to traffic. Nor should it be limited to the Villa Rosa project. It should be extended to all the other known projects in the area, which projects were identified in the Paceville draft Masterplan, which draft has been sent back to the drawing board.
- The issue of rock trimming above and around Ghar Gharq Hammiem is not adequately dealt with. Reference is in particular made to the conflicting statements in the Coordinated Assessment as to whether excavation should not be carried out or otherwise. The matter is dealt with unconvincingly: it should be extensively revisted and revised.
- The domino impacts of the project in accelerating further development in Pembroke to provide residential provision for foreign labourforce servicing the area is ignored.
 Coordinated Assessment Vol 1, p.329
 Coordinated Assessment Vol. 1, pp. 291-2 : The Cultural Heritage ESR also indicates that the impact of the proposed development on the case would be adverse (ASC, 2017, p. 56). The submission indicates that the mitigation measure would be “Structural study of the cave, no excavation carried out above the cave”.”
Chairperson – Alternattiva Demokratika -The Green Party.