I discovered – quite by chance – that there are plans, in an advanced stage, to gain permission to cover an area of 15,000 square metres (ca. 14 Tumoli) of agricultural land (naturally ODZ) with a permanent building for the cultivation of mushrooms. The area under consideration is directly behind the Craft Village in Gharb, on the slopes of Ta’ Dbiegi.

Incidentally, Ta’ Dbiegi is the highest point in Gozo and is one of the few hills with no buildings on it – in spring it is covered with wild narcissus and has an enormous scenic value all year round.

Due to numerous irregularities regarding the application it was only discovered a few days ago by the people who will be most effected; the Gharb and San Lawrence Councils, the Craft Village, the Kempinski Hotel, and local residents. I have just studied a 245 page thick Environmental Planning Statement, a document which is normally only requested once a project has been accepted in principle.

To give a very brief outline:

Basically, an area of about 12,000 square metres (10 to 12 Tumoli) on the slopes of the hill will be excavated to construct a semi-underground bunker for the production of mushrooms. The remaining open area will be used to store chicken excrement and straw. At present this factory is housed in Xewkija, but not in the main industrial site.

According to the EPS the bunker will be camouflaged by planting herbs on the roof. This idea is ludicrous, it is too cold and wet to grow herbs outdoors in winter and too hot and dry in summer, unless they are covered with shade cloth and continuously watered. The roof is also to be used to store straw bales which of course would effect the ‘High Landscape Sensibility’ factor as they are not particularly attractive.

According to the EPS, this particular factory would need 22,000 kg of odoriferous chicken excrement and 45,000 kg of straw per week to be productive. Of course, neither Gozo nor Malta can produce this amount of raw material, it would therefore have to be supplied from overseas countries and transported via Malta. Considering that most of the finished product, i.e. the mushrooms, would be consumed in Malta this seems to be an incredible waste of transport costs, wear and tear on vehicles and roads, non-renewable energy and fuel. The cubic dimensions of this raw material adds up to many truck loads of pure excrement, and excrement mixed with straw passing though prime tourist and residential areas – most likely even through the main square of Rabat (Victoria)! Although the EPS mentions that this will be transported in sealed vehicles, the law that stipulates that vehicles transporting building rubble, stones and other rubbish have to have a cover over the loading area has to date never been enforced. It appears that the members of MEPA are not aware of the fact that chicken excrement smells horrendous and does a lot more damage than rubble dust, it is also more difficult to scrape off one’s windscreen, shoes and clothes as well as roads, pavements and benches.

The proposed site does not conform to regulations regarding agricultural distances from residential areas. Not only does it abut on residential buildings, but access to the factory would be through the Ta’ Dbiegi Craft Village, an important tourist attraction on the island. I am sure the local craftspeople would not appreciate having all their goods impregnated with the smell of chicken excrement and I am sure that no tourist would like to purchase souvenirs such as the beautiful lace and knitted wear offered if it is impregnated with the smell of chicken excrement, nor would they like to shop in an odoriferous atmosphere!

Other questions arise such as:

1. What is going to happen to the straw and excrement substrate once it has been used? Where is it going to be dumped? There are insufficient working farms on Gozo to accommodate it all. Will it be transported to Malta? Or dumped in the sea or a convenient valley? When spread on farms, it will result in a continuous odour, chicken excrement does not disappear, it just gets more intense!
2. 
   
3. How much ground water is going to be extracted? How does this proposal fit in with the MRRA moratorium on the drilling of new boreholes.
4. 
   
5. The power capacity in this area is on the borderline – how will it cope with the air-conditioning of an area covering at least 10,000 square metres? I do not know the height, but if it is at least 3 metres, the volume to be cooled/heated would be immense!
6. 
   
7. The problem of increased insect activity was not even mentioned in the report. Flies, mosquitoes and sand-flies are a problem all over Gozo, especially in Summer. We are very fortunate that due to the fact that there are not many animal farms in the area around Ta’ Dbiegi, our insect population, although bad, is slightly better than other areas on the island. With several tons of moist manure/straw lying around it will become impossible to sit outside during the spring and summer months and will inevitably affect tourist stays in the area.
8. 
   
9. There will be no advantage to the labour market – according to the EPS there is a potential for an increase of 35 unskilled jobs in Gozo. These would more than likely be filled by irregular immigrants from Malta and not by Gozitans. On the other hand the loss of jobs in the tourist sector has not been calculated.
10. 
    
11. Alternative sites are available, for instance the Xewkija Industrial Estate, however this was deemed unsuitable as it “could cause difficulties with the adjacent residential area.” I would assume by this, that the residents in Gharb and St Lawrence and the tourists, craftspeople and staff in the Craft Village and the Kampinski Hotel are relegated to the status of no importance.
12. 
    
13. Another alternative would be the many, many thousands of cubic metres of derelict quarries which could also be used. The fact remains, why destroy agricultural land when there is more than sufficient, unused, but derelict, industrial areas available? It is fact that undeveloped agricultural land is much cheaper that industrial property – especially if the factory fails, the land can be disposed of as disturbed land and sold for residential properties with a view!
14. 
    
15. Why were only ODZ areas taken into consideration, and why are ODZ rules blatantly ignored.
16. 
    
17. Finally, what is going to happen with the debris and construction skeletons once the tourists no longer visit the island and eat mushrooms?

I am not writing this as a fussy foreigner, but as a very concerned person who also has a vested interest in the island and its people. I appeal to the authorities and politicians involved to think again – very carefully and to attempt, or at least make an effort, to put a stop to this outrageous destruction of one of the few unspoilt areas left on this island. It is not just a piece of land we are talking about – it is the heritage of your children and their future generations.

The land belongs to the Maltese and Gozitans and it is you who are basically the real guardians of the islands. We only have this island on loan and it is our duty to preserve it for future generations.

In conclusion, I can only hope that someone at MEPA has the guts and integrity to put a stop to this appalling breach of trust.

Lesley G. Kreupl