environmental planning statement volume 1: … · 2017-10-10 · vii consultants’ declaration adi...

PA 03347/16

PROPOSED CONSTRUCTION OF PETROL STATION AND AUTO REPAIR AND

MAINTENANCE CENTRE INSTEAD OF AN EXISTING OPEN STORAGE YARD,

L-IMQABBA

ENVIRONMENTAL PLANNING STATEMENT

VOLUME 1: COORDINATED ASSESSMENT

Version 1: September 2017

i

Report Reference:

Adi Associates Environmental Consultants Ltd, 2017. PA03347/16: Proposed

Construction of Petrol Station and Auto Repair and Maintenance Centre

instead of an Existing Open Storage yard, L-Imqabba. Environmental

Planning Statement. San Gwann, September 2017; xvii + 225 pp. + 1

Appendix.

THIS IS A DIGITAL COPY OF THE REPORT.

RESPECT THE ENVIRONMENT – KEEP IT DIGITAL

iii

This document has been prepared in accordance with the scope of Adi Associates’ appointment with its client and is subject to the terms of that appointment. It is addressed to and for the sole and confidential use and

reliance of Adi Associates’ client. Adi Associates accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared

and provided. Except as provided for by legislation, no person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior written permission of Adi

Associates. Any advice, opinions, or recommendations within this document should be read and relied upon only in the context of the document as a whole. The contents of this document do not provide

legal or tax advice or opinion. It is pointed out that ISO14001 certification covers the management

system only and not the contents of this report.

© Adi Associates Environmental Consultants Ltd 2017

Kappara Business Centre

113 Triq Birkirkara

San Gwann SGN 4197

MALTA

Tel. / Fax: 21378172 - 77

Email: [email protected]

Web: www.adi-associates.com

Quality Assurance

Proposed Construction of Petrol Station and Auto Repair and Maintenance

Centre instead of an Existing Open Storage yard, l-Imqabba

Environmental Planning Statement

September 2017

Report for: Denfar Ltd

Revision Schedule

Rev Date Details Written by: Checked by: Approved by:

00 Sept 2017 Submission to client Rachel Xuereb Director

Adrian Mallia Managing Director

Adrian Mallia Managing Director

File ref: G:\_Active Projects\EIA\DEN002 - Mqabba Petrol Station\EPS\MASTER EPS.doc

mailto:[email protected]

http://www.adi-associates.com/

v

CONTRIBUTORS

Adi Associates Environmental Consultants Ltd prepared this Environmental Planning

Statement in association with the specialist consultants listed below:

Specialist Consultant: Topic responsible for:

Joseph A Pace Base photos and photomontages

Marco Cremona Hydrology Baseline Study

Adi Associates staff was involved in the following parts of this EPS:

Staff Member: Area responsible for:

Rachel Xuereb Coordination, quality review

Rachel Decelis Air quality, environmental risk assessment, decommissioning,

climate change

Krista Farrugia Landscape and visual amenity

Yury Zammit Traffic and transportation

Andrea Pace Land cover, land use, mapping, and GIS

Chantal Cassar Cultural heritage baseline study

vii

CONSULTANTS’ DECLARATION

Adi Associates Environmental Consultants Ltd, Malta, prepared this Environmental Planning

Statement (EPS).

The Environmental Impact Assessment Regulations, 2007, Sections 28(3) and 29(1) require each

of the Consultants to declare that they carried out the study or part thereof, that they take

responsibility for statements and conclusions contained in their reports or part thereof, and

that they have no personal or financial interest in the proposed development.

We declare that Adi Associates Environmental Consultants Ltd has no personal or financial

interest in the proposed development.

Adi Associates has coordinated this EPS and has provided technical input to specific parts of

the Statement as identified in the previous page.

Adi Associates Environmental Consultants Ltd takes responsibility for statements and

conclusions contained in the parts of the report prepared directly by its staff. However,

statements made and conclusions drawn by the independent sub-consultants who prepared

the baseline studies reproduced in the Technical Appendices and which informed the

Environmental Statement remain the responsibility of the individual sub-consultants.

Adrian Mallia Rachel Xuereb

Managing Director, Adi Associates Director, Adi Associates

ix

The undersigned hereby declare that they carried out the study or part thereof, and that

they have no personal or financial interest in the proposed development.

Joseph A Pace

Marco Cremona

Rachel Xuereb

Rachel Decelis

Krista Farrugia

Yury Zammit

Andrea Pace

Chantal Cassar

xi

CONTENTS

1. Introduction ........................................................................................ 1

Purpose of the EPS ..................................................................................................................................... 1

Structure of the EPS ................................................................................................................................... 1

2. EIA METHODOLOGY ....................................................................... 5

Introduction .................................................................................................................................................. 5

The EIA Process .......................................................................................................................................... 5

Terms of Reference .................................................................................................................................... 5

Method Statements ..................................................................................................................................... 5

EIA Approach ............................................................................................................................................... 6

Significance of Impacts ................................................................................................................................ 6

Uncertainty ................................................................................................................................................... 7

Consultation ................................................................................................................................................. 7

Presentation of the EPS ............................................................................................................................. 8

3. Description of Scheme and Site ...................................................... 11

Introduction ................................................................................................................................................ 11

Objectives of the Scheme ....................................................................................................................... 11

Demand for the Scheme .......................................................................................................................... 11

Consultation ............................................................................................................................................... 11

Assessment of Alternatives ..................................................................................................................... 15

Alternative Sites ........................................................................................................................................ 15

Zero Option (Do-nothing Scenario) .................................................................................................... 15

Alternative Layouts and Techniques ..................................................................................................... 15

Description Of the Site and its Surroundings ..................................................................................... 21

Scheme Site ................................................................................................................................................ 21

Land Use in the Vicinity of the Scheme Site ....................................................................................... 21

Natural Heritage Designations ............................................................................................................... 22

Scheme Description.................................................................................................................................. 29

Access and Parking ................................................................................................................................... 29

Landscaping and Exterior Lighting ......................................................................................................... 29

Services ........................................................................................................................................................ 30

Car Wash .................................................................................................................................................... 43

Electric Charging Points ........................................................................................................................... 43

Operating Hours ....................................................................................................................................... 43

Resources ................................................................................................................................................... 53

Electricity Supply ....................................................................................................................................... 53

Water .......................................................................................................................................................... 53

Raw Materials ............................................................................................................................................. 53

Scheme Construction ............................................................................................................................... 54

xii

Construction Timing ................................................................................................................................ 54

Plant and Machinery .................................................................................................................................. 54

Construction Waste ................................................................................................................................. 54

Construction Personnel........................................................................................................................... 55

Construction Management...................................................................................................................... 55

Scheme Operation .................................................................................................................................... 61

Employment ................................................................................................................................................ 61

Operational Waste ................................................................................................................................... 61

Emissions ..................................................................................................................................................... 61

Emissions to Air ........................................................................................................................................ 61

Noise and Vibration .................................................................................................................................. 65

Scheme Decommissioning ....................................................................................................................... 65 Outline Decommissioning Plan .............................................................................................................. 66

4. Legislation and Policy Context........................................................ 67

Introduction ................................................................................................................................................ 67

International legislation ............................................................................................................................ 67

The Geneva Protocol on VOC emissions ........................................................................................... 67

The European Cultural Convention ..................................................................................................... 68

The European Convention on the Protection of the Archaeological Heritage (Revised) ........ 68

European Policy and Legislation ............................................................................................................. 70

National legislation .................................................................................................................................... 70

The Constitution of Malta ....................................................................................................................... 70

Environment Protection Act 2016 (Act I of 2016) ............................................................................ 71

Development Planning Act, 2016 (Act VII of 2016) .......................................................................... 72

Environmental Management Construction Site Regulations, 2007 ................................................ 73

Legal Notices .............................................................................................................................................. 75

Malta Resources Authority Act 2001 ................................................................................................... 77

Protection of Antiquities Regulations, 1932 ....................................................................................... 79

Cultural Heritage Act, 2002 ................................................................................................................... 79

Waste Management Plan for the Maltese Islands: A Resource Management Approach 2014 -

2020 .............................................................................................................................................................. 80

Planning Policy ............................................................................................................................................ 81

Strategic Plan for Environment and Development ............................................................................ 81

South Malta Local Plan ............................................................................................................................. 82

Fuel Service Stations Policy ..................................................................................................................... 91

Conclusion .................................................................................................................................................. 96

5. Geo-Environment ............................................................................. 97

Introduction ................................................................................................................................................ 97

Assessment Methodology ....................................................................................................................... 97

Standards and Policy Guidance .............................................................................................................. 97

Area of Influence ....................................................................................................................................... 98

Geo-environment Methodology ............................................................................................................ 98

xiii

Baseline: Geology ................................................................................................................................... 103

Stratigraphy .............................................................................................................................................. 103

Lithology of the Lower Globigerina Limestone member .............................................................. 107

Structural Geology ................................................................................................................................. 108

Quality of the Stone Material .............................................................................................................. 108

Soils ........................................................................................................................................................... 108

Baseline: Geomorphology .................................................................................................................... 109

Geomorphic Features ........................................................................................................................... 109

Baseline: Hydrogeology......................................................................................................................... 109

Surface Hydrology .................................................................................................................................. 109

Runoff Generated Within the Scheme Site ...................................................................................... 110

Mean Sea Level Aquifer ........................................................................................................................ 110

Assessment of Impacts .......................................................................................................................... 114 Impact Significance ................................................................................................................................. 114

Prediction and Significance of Impacts ............................................................................................... 114

Change in quality of aquifer ................................................................................................................. 114

Change in quality of run-off ................................................................................................................. 115

Mitigation ................................................................................................................................................. 115

Residual Impacts ..................................................................................................................................... 115

6. Cultural Heritage ........................................................................... 119

Terms of Reference ............................................................................................................................... 119

Assessment Methodology .................................................................................................................... 119

Objectives of the Assessment ............................................................................................................. 119

Standards and Policy Guidance ........................................................................................................... 120

Policy Importance of Archaeological Features ................................................................................ 121

Area of Influence .................................................................................................................................... 123

Methodology ........................................................................................................................................... 123

Desktop Survey Results ........................................................................................................................ 127

Cultural Heritage Features................................................................................................................... 128

Assessment of Impacts .......................................................................................................................... 135

Determining Impact Significance ......................................................................................................... 135

Prediction and Significance of Impacts ............................................................................................... 135

Mitigation Measures ............................................................................................................................... 136


Monitoring Requirements .................................................................................................................... 137

7. Landscape and Visual Amenity ..................................................... 141

Introduction ............................................................................................................................................. 141


Legislation and Policy Guidance .......................................................................................................... 142

South Malta Local Plan .......................................................................................................................... 142

Landscape Assessment Study of the Maltese Islands ..................................................................... 143

Standards and Guidelines ..................................................................................................................... 143

xiv


Desk Study Methodology ..................................................................................................................... 143

Photomontages ....................................................................................................................................... 146


Landscape Assessment .......................................................................................................................... 161

Visual Amenity ........................................................................................................................................ 161

Existing Conditions ................................................................................................................................ 163

Landscape ................................................................................................................................................. 163

Visual Amenity: Zone of Theoretical Visibility ................................................................................ 166

Changes in the Landscape and Visual Amenity ................................................................................ 168

Changes in the Landscape and their Significance ............................................................................ 168 Changes in Visual Amenity and their Significance ........................................................................... 169

Mitigation ................................................................................................................................................. 181


8. Air Quality ...................................................................................... 191

Introduction ............................................................................................................................................. 191

Terms of Reference ............................................................................................................................... 191


Legislation and Guidance ...................................................................................................................... 191


Sensitive Receptors................................................................................................................................ 193

Baseline Data ........................................................................................................................................... 193

Emissions .................................................................................................................................................. 203


Benzene .................................................................................................................................................... 209

Odours ..................................................................................................................................................... 209

Baseline Air Quality ............................................................................................................................... 210

Benzene .................................................................................................................................................... 210

Odour ....................................................................................................................................................... 210

Assessment of Impact from the Scheme........................................................................................... 212

Benzene .................................................................................................................................................... 212

Odours ..................................................................................................................................................... 212

Mitigation and Residual Impacts .......................................................................................................... 213

Future Monitoring Requirements ....................................................................................................... 213

9. Summary of key impacts, interaction between impacts and

mitigation ........................................................................................ 217

Introduction ............................................................................................................................................. 217

Summary of Key Impacts ...................................................................................................................... 217

Geo-environment ................................................................................................................................... 217

Cultural Heritage.................................................................................................................................... 218

Landscape and Visual Amenity ............................................................................................................ 218

Emissions to Air ..................................................................................................................................... 218

xv

Interaction of Impacts ........................................................................................................................... 218

Cumulative Impacts ............................................................................................................................... 219

Mitigation ................................................................................................................................................. 219

Required Authorisations....................................................................................................................... 219

FIGURES

Figure 1.1: Location of the Scheme site ................................................................................................. 3

Figure 3.1: Location of Nearest Fuel Service Stations ..................................................................... 13

Figure 3.2: Layout of Initial Design Option ........................................................................................ 17

Figure 3.3: Alternative Site Layout ....................................................................................................... 19

Figure 3.4: Images of the Scheme Site ................................................................................................. 23

Figure 3.5: Images of Surrounding Land Uses .................................................................................... 25

Figure 3.6: Surrounding Land Uses ....................................................................................................... 27

Figure 3.7: Scheme Layout ..................................................................................................................... 31

Figure 3.8: Upper Floor Plan.................................................................................................................. 33

Figure 3.9: Scheme Elevations / Sections ............................................................................................ 35

Figure 3.10: Trees to be removed from Triq il-Belt Valletta ......................................................... 37

Figure 3.11: Exterior Lighting Plan ....................................................................................................... 39

Figure 3.12: Tank Layout ........................................................................................................................ 45

Figure 3.13: Vapour Recovery System ................................................................................................. 47

Figure 3.14: Details of LPG Tank and Pipework ............................................................................... 49

Figure 3.15: Surface Water Drainage .................................................................................................. 51

Figure 3.16: Construction Site Layout Plan ........................................................................................ 59

Figure 4.1: Mqabba Environmental Constraints Map (extracted from the South Malta Local

Plan, and showing the Scheme site outlined in red) ................................................................ 85

Figure 4.2: Kirkop Environmental Constraints Map (extracted from the South Malta Local

Plan, and showing the Scheme site outlined in red) ................................................................ 87

Figure 4.3: Ground Water Resources Protection Map (extracted from the South Malta Local Plan, and showing the Scheme site outlined in black) ............................................................. 89

Figure 5.1: Hydrology / Hydrogeology Area of Influence ............................................................... 99

Figure 5.2: Geo-technical investigation: Location of Boreholes .................................................. 101

Figure 5.3: Geological Map of the Area of Influence (OED, 1993) ............................................. 105

Figure 5.4: Geological cross section ................................................................................................. 107

Figure 5.5: Hydrology map showing features of interest within the Area of Influence .......... 113

xvi

Figure 6.1: Area of Influence for Cultural Heritage Study ............................................................ 125

Figure 6.2: Cultural Heritage Features within the Area of Influence ......................................... 129

Figure 6.3: Rural Room close to the Scheme Site (KKP001) ....................................................... 131

Figure 6.4: Farmhouse (MQB003) ...................................................................................................... 132

Figure 6.5: Another two farmhouses within the Area of Influence - KKP003 (top) and

MQB007 (bottom) ........................................................................................................................ 133

Figure 6.6: Rubble walls (KKPMQB002) ........................................................................................... 134

Figure 7.1: South Malta Local Plan Map (Scheme Site outlined in red) ...................................... 151

Figure 7.2: Zone of Theoretical Visibility .......................................................................................... 153

Figure 7.3: Zone of Theoretical Visibility using both the digital terrain model (DTM) and the

digital elevation model (DEM) .................................................................................................... 155

Figure 7.4: Zone of Theoretical Visibility (DTM + DEM) and selected viewpoints ................ 157

Figure 7.5: Landscape Character Areas and Local Landscape Tracts ......................................... 159

Figure 7.6: Viewpoint 1 photomontage 10 years into growth of plants used in landscaping 183

Figure 7.7: Viewpoint 2 photomontage 10 years into growth of plants used in landscaping 185

Figure 8.1: Surrounding Land Uses ..................................................................................................... 195

Figure 8.2: ERA Diffusion Tube Locations for Benzene Baseline Data ...................................... 197

Figure 8.3: Baseline Odour Survey Locations .................................................................................. 201

Figure 8.4: Emissions of Benzene giving rise to an Annual Mean Ground-level Concentration

of 0.22 µg/m3 at Receptors.......................................................................................................... 204

Figure 8.5: Odour Survey Locations (operational petrol station) ............................................... 207

TABLES Table 3.1: Estimated Raw Materials for Construction ..................................................................... 53

Table 3.2: Construction Timing ............................................................................................................ 54

Table 3.3: Construction Plant and Machinery ................................................................................... 54

Table 3.4: Construction Waste ............................................................................................................ 57

Table 3.5: Estimates of Operational Waste ....................................................................................... 63

Table 3.6: CO2 Emissions from Scheme Operations ....................................................................... 65

Table 5.1: Summary of Impacts on the Geo-environment............................................................ 117

Table 6.1: Protection Ratings and Cultural Significance ................................................................ 122

Table 6.2: Cultural Heritage Features ............................................................................................... 128

Table 6.3: Impact Significance Criteria .............................................................................................. 135

Table 6.4: Summary of Impacts on Cultural Heritage .................................................................. 139

Table 7.1: Landscape Character Sensitivity ...................................................................................... 145

Table 7.2: Magnitude of Change to Landscape Resource ............................................................. 145

xvii

Table 7.3: Magnitude of Visual Change.............................................................................................. 147

Table 7.4 Landscape Receptors .......................................................................................................... 148

Table 7.5 Identification of Impact Significance ................................................................................. 163

Table 7.6: Landscape Character Types and Landscape Character Areas .................................. 164

Table 7.7: Summary of Scheme Site Visibility from Viewpoints .................................................. 167

Table 7.8 Changes in Landscape Character and Significance of the Impacts ............................ 168

Table 7.9: Summary of Impacts on Landscape and Visual Amenity ........................................... 187

Table 8.1: Baseline Odour Survey Details ........................................................................................ 199

Table 8.2: Odour Intensity Categories .............................................................................................. 199

Table 8.3: Benzene Emission Factors ................................................................................................. 203

Table 8.4: Odour Survey Details (operational petrol station) ..................................................... 205

Table 8.5: Criteria of Significance: Benzene Annual Levels ........................................................... 209

Table 8.6: Odour Exposure Matrix .................................................................................................... 209

Table 8.7: Matrix to Assess the Odour Effect at Receptors ........................................................ 210

Table 8.8: Benzene Baseline Data ....................................................................................................... 210

Table 8.9: Weather Conditions (baseline odour survey).............................................................. 211

Table 8.10: Results of Baseline Odour Survey ................................................................................ 211

Table 8.11: Predicted Benzene Concentrations at Air Sensitive Receptor .............................. 212

Table 8.12: Weather Conditions (survey at operational fuel station) ....................................... 212

Table 8.13: Results of Odour Survey (operational service station) ............................................ 214

Table 8.14: Summary of Impacts on Air Quality ............................................................................ 215

Table 9.1: Summary of Impact Assessment ...................................................................................... 221

APPENDIX

Appendix 1: A3 Photographs

1

1. INTRODUCTION

1.1. This Environmental Planning Statement (EPS) describes a proposal for a fuel service

station on a site on Triq Valletta in Mqabba (see Figure 1.1). The service station

will include a fuel filling station, car wash and drying area, auto gas filling facilities, and

a tyre service garage, as well as ancillary commercial premises and office space.

1.2. The project is proposed by Denfar Ltd. Denfar Ltd is hereinafter in this EPS referred

to as ‘the Applicant’; the project is hereinafter referred to as ‘the Scheme’.

1.3. A Full Development Permit application was submitted to the former Malta

Environment and Planning Authority (MEPA)1 in April 2014 (PA 03347/16). Following

the submission of a Project Description Statement (PDS), in May 2016, the

Environment and Resources Authority (ERA) determined that the Scheme required

an EPS in accordance with Schedule 1A, Category 7.6.2.6 Environmental Impact

Assessment Regulations, 2007 (Legal Notice 114 of 2007 as amended, S.L.549.46).

PURPOSE OF THE EPS

1.4. The purpose of this EPS is to present the findings of the Environmental Impact

Assessment (EIA). EIA is the process of systematically assessing the likely significant

environmental impacts of development proposals. EIA also ensures that the

significance of these impacts, and the scope for reducing them, is clearly understood

by the public, and by ERA and the Planning Authority (PA), before a decision is made

on whether or not the development should be approved.

STRUCTURE OF THE EPS

1.5. Following this introduction, the EPS is structured as follows:

Chapter 2: EIA Methodology

Chapter 3: Description of Site and Scheme

Chapter 4: Legislation and Policy Context

Chapter 5: Geo-environment

Chapter 6: Cultural Heritage

Chapter 7: Landscape and Visual Amenity

Chapter 8: Emissions to Air

1 MEPA has since been split into the Planning Authority (PA) and the Environment and Resources Authority

(ERA).

2

Chapter 9: Key Impacts, Cumulative Effects and Summary of Mitigation


1.6. The Environmental Risk Assessment is presented as Volume 2 of the EPS.

1.7. The EPS also contains the following Technical Appendices (compiled separately as

Volume 3 of the EPS):

Technical Appendix 1: Terms of Reference and Method Statements

Technical Appendix 2: Geo-environment Baseline Report

Technical Appendix 3: Cultural Heritage Baseline Report

1.8. The EPS includes a Non-Technical Summary in Maltese and English.

3

Figure 1.1: Location of the Scheme site

5

2. EIA METHODOLOGY

INTRODUCTION

2.1. This chapter sets out the broad methodology that was used for the Environmental

Impact Assessment (EIA) of the Scheme. It outlines the key stages that were

followed, in line with EIA best practice. The chapter also explains how the

significance of impacts was assessed, and how this was a consistent process

throughout the EIA.

THE EIA PROCESS

2.2. The current guidance on the EIA process is contained in the Environmental Impact

Assessment (EIA) Regulations, 2007 (Legal Notice 114 of 2007 as amended) (S.L.

549.46). The Environment and Resources Authority (ERA) has directed that an EPS

be prepared for the Scheme.

Terms of Reference

2.3. The Terms of Reference (ToR) for the EIA were prepared by ERA in consultation

with the relevant Government Departments. The final version of the ToR is included

in Technical Appendix 1: Terms of Reference and Method Statements.

2.4. The ToR were formulated following a scoping exercise, undertaken by ERA, to

identify the issues to be considered in the EIA. The ToR focused on those impacts of

the Scheme considered by ERA to be significant and, therefore, requiring further

assessment, and avoiding the examination of all environmental impacts. The ToR also

outlined the various components of the EIA.

Method Statements

2.5. As required by the EIA Regulations, the Consultants involved in this EPS were

approved by ERA.

2.6. Method Statements were prepared in respect of the topic areas: geo-environment;

cultural heritage; landscape and visual amenity; and emissions to air. The Method

Statements addressed the following:

Introduction, listing the objectives of the study and reference to the ToR;

Details of baseline survey methodology;

Description of the Area of Influence;

Field survey methodology;

Analytical methodology;

Evaluation of data;

6

Identification of impacts;

Prediction of impacts;

Impact significance; and

Mitigation.

2.7. All Method Statements were accepted by ERA, and were subsequently used as the

basis for carrying out the individual baseline surveys. The Method Statements are

included in Technical Appendix 1: Terms of Reference and Method

Statements.

EIA Approach

2.8. Good practice necessitates that EIA be treated as an iterative process, rather than a

one-off, post-design environmental appraisal. In this way, the findings from the EIA

can be fed into the design process, resulting in a more environmentally sensitive

project. This approach was adopted for this EIA.

2.9. Baseline surveys for the specialist EIA topics were undertaken by the Consultants

based on the Area of Influence (A of I) agreed with ERA for each topic area. A

detailed assessment of the Scheme’s impact on the features present within the A of I

was undertaken, and any potential environmental benefits of the Scheme were

identified.

Significance of Impacts

2.10. Assessment of the significance of impacts arising from a development is a key stage in

the EIA process. This judgement is critical in informing the decision-making process.

However, defining significance can be difficult. In general terms, environmental

significance involves assessing the amount of change to the environment perceived to

be acceptable to the community (Sippe, 1999).

2.11. The following criteria were used in this EIA to assess the significance of an impact:

Type of impact (adverse / beneficial);

Extent and magnitude of impact;

Direct or indirect impact;

Duration of impact (short term / long term; permanent / temporary);

Comparison with legal requirements, policies and standards;

Sensitivity of receptor (residential dwellings, hotels, recreational areas, etc.);

Probability of impact occurring (certain, likely, uncertain, unlikely, remote);

7

Reversibility of impact;

Scope for mitigation / enhancement (very good, good, none); and

Residual impacts.

2.12. Using these criteria, the significance of the impacts arising from the Scheme was

categorised in the EPS, as follows:

Not significant;

Minor significance;

Moderate significance (in the case of the landscape and visual amenity assessment

only); and

Major significance.

2.13. Definitions of the meaning of the ‘significance categories’ above in relation to each

topic area are included in the individual topic area chapters (see Chapter 5 to

Chapter 8). However, in general terms, if an impact is ‘not significant’, it is

considered to be environmentally acceptable; an impact of ‘minor significance’ refers

to an impact that is considered to be manageable; an impact of ‘moderate significance’

refers to an impact that may be manageable in certain circumstances, although is

likely to require implementation of suitable mitigation measures; and an impact of

‘major significance’ refers to an impact that is considered to be environmentally

damaging such as to require that the Scheme be redesigned, or that mitigation

measures be put in place to minimise the impact.

2.14. The EPS includes an assessment of the significance of predicted impacts and, following

the implementation of any proposed mitigation measures, the significance of any

residual impacts. A summary of the identified significant impacts is included in

Chapter 9. The recommended mitigation measures, and the residual impacts, are

described in respect of each topic area, at the end of the relevant chapter (see

Chapter 5 to Chapter 8).

UNCERTAINTY

2.15. The EIA process is designed to enable good decision-making based on the best

possible information about the environmental implications of a development. There

will always be some uncertainty in predicting potential impacts, as to the exact nature

and scale of the impacts. This arises through shortcomings in information, doubts, or

lack of certainty on the likelihood that an incidence would occur, and / or due to the

limitations of the prediction process itself. Where uncertainties have arisen, and

where they remain, this is clearly stated in the EPS.

CONSULTATION

2.16. There has been consultation with ERA throughout the EIA process. Additionally, the

8

l-Imqabba and Ħal Kirkop Local Councils were also consulted. The purpose of this consultation was to identify the issues these entities considered important in respect

of the locality, and to inform the EIA. The feedback from this consultation is

described in Chapter 3.

PRESENTATION OF THE EPS

2.17. This EPS is divided into three main parts following this chapter.

2.18. Part 1 comprises Chapters 3 and 4:

Chapter 3 explains the purpose of and justification for the Scheme, and includes

a description of the site and its surroundings; and

Chapter 4 summarises the relevant legislation and policy context, including

planning policies.

2.19. Part 2 comprises Chapters 5 to 8, which describe the potential environmental

impacts of the Scheme in relation to each of the topic areas. Each of the chapters is

structured as follows:

Introduction: identifying the key issues and how the chapter relates to the ToR;

Assessment methodology: summarising the methods used in undertaking the

baseline survey;

Existing conditions: a summary of the existing baseline situation and trends

irrespective of the Scheme; and

Assessment of impacts arising from the Scheme, identifying:

o Potential impacts: a summary of the potential impacts of the Scheme;

o Prediction and significance of impacts: a prediction of the likely impacts of

the Scheme against the baseline situation and an assessment of the

significance of the impacts;

o Mitigation measures: a summary of potential mitigation / enhancement

measures, to offset any identified adverse impacts;

o Residual impacts: a clear statement of those impacts that still have an

impact following mitigation, indicating the significance of the residual

impact; and

o Summary: a summary table of the impacts.

2.20. Part 3 comprises Chapter 9, which addresses the cumulative effects of the Scheme,

and summarises the impacts and proposed mitigation measures.

2.21. The Environmental Risk Assessment is presented as a separate volume (Volume 2)

9

since the risk assessment addresses abnormal operation whereas the impact

assessment chapters assess normal operation of the Scheme.

11

3. DESCRIPTION OF SCHEME AND SITE

INTRODUCTION

3.1. This chapter describes the Scheme. It explains the purpose of and justification for

the Scheme, and includes a description of the Scheme site and its surroundings.

OBJECTIVES OF THE SCHEME

3.2. As described by the Applicant, the main objectives of the Scheme are:

To provide a fuel service station that meets current environmental and safety

requirements; and

To provide a comprehensive service to customers through the provision of

ancillary facilities, including car wash facilities, retail facilities supplying automobile

consumables, and a tyre services garage.

DEMAND FOR THE SCHEME

3.3. The Scheme is located on Triq il-Belt Valletta, a distributor road. The closest

existing fuel service stations to the Scheme site are located at the edge of Iż-Żurrieq

(2.2 km driving distance), the Malta International Airport (2.4 km driving distance)

and at Ħal Safi (2.9 km driving distance) - see Figure 3.1.

3.4. The Applicant explains that the Scheme will meet the requirement for fuel stations to

comply with current EU Directives and local regulations, for example, in relation to

vapour recovery systems, and in the provision of charging points for electric vehicles.

The Applicant also explains that the Scheme will meet customer expectations

through providing a 24/7 service, as well as car wash and tyre service facilities, and a

shop selling car accessories and car care products.

CONSULTATION

3.5. As mentioned in Chapter 2, the L-Imqabba and Ħal Kirkop Local Councils were

both consulted during the preparation of this EPS. The purpose of this consultation

was to identify the issues that the Councils considered important for the locality, and

to inform the EIA.

3.6. The issues identified by the L-Imqabba Local Council can be summarised as follows:

Traffic management and security measures as Valletta Road is an arterial road and

thus Transport Malta needs to be consulted being responsible for this road;

The uprooting of mature endemic pine trees in Valletta Road and the visual

impact of the Scheme; and

Air borne dust particles next to the proposed car wash emanating from open air

12

stockpiles of sand and aggregate.

3.7. The issues identified by the Ħal Kirkop Local Council can be summarised as follows:

Traffic coming from Ħal Kirkop towards the Scheme will make a right hand turn

on Triq il-Belt Valletta, thus creating a potential hazard on the road; and

The poor state of the road needs to be addressed.

13

Figure 3.1: Location of Nearest Fuel Service Stations

15

ASSESSMENT OF ALTERNATIVES

Alternative Sites

3.8. The Applicant did not consider any alternative site(s) for the Scheme. The Scheme

site is owned by the Applicant, is concreted over and is currently being used for the

storage of concrete blockwork, in line with a Full Development Permit issued under

PA 05616/01. The Scheme site also satisfies the locational criteria for the relocation

of fuel service stations as outlined in the Fuel Service Stations Policy 2015.

Zero Option (Do-nothing Scenario)

3.9. The Terms of Reference (ToR) issued by the Environment and Resources Authority

(ERA) require that the alternative assessment considers the zero option, or do-

nothing scenario, which envisages there being no intervention on the site in

connection with the Scheme, and assumes the Scheme being located elsewhere (or

not constructed at all). This alternative option considers the way the site would

develop in the absence of the Scheme.

3.10. As mentioned, the Scheme site currently comprises an open storage yard in connection with a permit granted under PA 05616/01. The permit relates to a larger

site, including lands to the northeast issued “To sanction the siting of a mobile crusher

(softstone) and blockwork producing machine in an existing quarry”. Figure 3.4 shows

various images of the Scheme site as it is currently. In the absence of the Scheme,

the site would continue to be used as permitted under PA 05616/01.

3.11. The Scheme requires the felling of 11 mature Aleppo pine trees (Pinus halepenis -

Żnuber) on Triq il-Belt Valletta, in order to enhance accessibility to the site, and because of the flammable nature of these trees. In the absence of the Scheme these

trees would remain.

Alternative Layouts and Techniques

3.12. The Applicant explored a number of alternative layouts for the Scheme on the

Scheme site, primarily as a result of the access requirements investigated during the

formulation of the Traffic Impact Assessment (TIA)2.

3.13. Figure 3.2 shows one of the original designs for the Scheme, where the layout

included a number garages to be used for panel beating and spray painting, and a

mechanic and electrician’s workshop. The layout plan also included offices and a

retail outlet located to the north of the site. The layout was subsequently amended

during the process of the TIA, wherein the workshops where replaced by a

showroom, and five car wash bays were introduced to the west of the workshops

(see Figure 3.3). A later modification resulted in removal of the showroom and its

2 Bjorn Bonello, 2016, TRK156478 – Fuel Refuelling Station, il-Triq Valletta, Mqabba. Traffic Impact Assessment.

16

replacement by a tyre services garage and valeting area.

17

Figure 3.2: Layout of Initial Design Option

19

Figure 3.3: Alternative Site Layout

21

DESCRIPTION OF THE SITE AND ITS SURROUNDINGS

Scheme Site

3.14. The Scheme site has an area of approximately 2,630 m2. The site is located

approximately 700 m southwest of the Malta International Airport (MIA) runway

2406 at its closest point, 1.5 km (plan distance) from the MIA terminal buildings at

their closest point, and equidistant (approximately 650 m – 550 m) from L-Imqabba

and Ħal Kirkop (see Figure 3.1).

3.15. The Scheme site is located in an area characterised by both operational and disused

quarries and by construction-related uses that have been established in the disused

quarries. The Scheme site is roughly rectangular in shape and is bounded to the

north by a narrow laneway that separates the site from a concrete batching plant and

associated lorry parking / maintenance garage, and an operational softstone quarry.

Another operational softstone quarry is immediately adjacent to the east of the Scheme site. Along its southern boundary, the Scheme site is adjacent to the arterial

Triq il-Belt Valletta and disused land despoiled by dumping. Triq il-Belt Valletta is

lined with mature Aleppo pines trees (Pinus halepenis - Żnuber).

3.16. There are no dwellings within 260 m of the Scheme site, and there is no record of

habitation on the Scheme site. As mentioned, the whole of the Scheme site is given

over to concrete block manufacture and storage.

3.17. Figure 3.4 shows images of the Scheme site as it is currently.

Land Use in the Vicinity of the Scheme Site

3.18. Land cover and land use in the area surrounding the Scheme site were recorded

during a survey carried out in March 2017. The land uses are illustrated in Figure

3.5 and Figure 3.6.

3.19. The predominant land use in the immediate vicinity of the Scheme site is mineral

extraction (quarrying). Ordinance Survey sheets from the beginning of the twentieth

century show that the area was already extensively used for quarrying. This history

of quarrying activities in the area is also evident from the number of inactive and

disused quarries noted during the survey; a distinction was made between active and

inactive quarries when mapping the land uses (see Figure 3.6).

3.20. The quarries are soft stone quarries and ancillary facilities include batching plants.

The inactive quarries are either completely abandoned, and have been re-vegetated (some have been restored to agricultural use), or are being used for open storage or

other industrial purposes.

3.21. Arable land dominates the area to the southwest of the Scheme site, although there

are also some pockets of agricultural land to the north of Triq il-Belt Valletta. The

agricultural use is primarily taking place within former quarries.

3.22. The industrial (including open storage) sites are primarily concentrated along Triq il-

22

Belt Valletta.

3.23. The nearest residential property to the Scheme site is located approximately 230 m

to the southwest. The nearest urban area is the settlement of Ħal Kirkop, located approximately 485 m to the southwest; the settlement of L-Imqabba is located

approximately 660 m to the southeast.

Natural Heritage Designations

3.24. The closest natural heritage designation to the Scheme site is the Ħal Luqa Airport

Bird Sanctuary, which is located approximately 250 m to the east of the site.

23

Figure 3.4: Images of the Scheme Site

Aerial views of the Scheme Site

25

Figure 3.5: Images of Surrounding Land Uses

Active quarry Inactive quarry Storage within an inactive quarry

Industrial / storage use on disturbed land Agricultural land Residential unit

27

Figure 3.6: Surrounding Land Uses

29

SCHEME DESCRIPTION

3.25. The Scheme layout is illustrated in Figure 3.7. Floor plans and elevation / section

drawings are included as Figure 3.8 and Figure 3.9, respectively. Specifically, the

Scheme takes the form of:

Six sets of fuel dispensers (two of the dispensers will be of the 4-product, 8-hose type, including the two for autogas; the other four dispeners will be of the 3-

product, 6-hose type); the canopy covering the fuel dispensing area will have an

area of 820 m2 and will be approximately 6.3 m high at its highest point);

Two charging stations for electric vehicles;

Car wash / drying facilities (three wash bays and three drying bays within a

structure with a maximum height of approximately 4 m);

A garage for tyre services (vulcaniser) and one for valeting (with a cumulative

floor area of 250 m2 and a maximum height of approximately 5.6 m);

A retail unit (Class 4B Retail) selling car parts and accessories and an office (Class

4A Offices), which will be used in connection with the fuel service station

(cumulative floor area of approximately 200 m2 and a maximum height of

approximately 4.9 m); and

Surface parking in the forecourt for six vehicles and ten bicycle parking racks.

Access and Parking

3.26. The Scheme will be accessed off Triq il-Belt Valletta. There are no pedestrian

footways along this stretch of Triq il-Belt Valletta and little or no pedestrian traffic in

the area. There will be separate ingress and egress to the Scheme. The TIA of the

Scheme included a Road Safety Audit which informed the access design. There will

be no right turn into or out of the Scheme site, as recommended in the TIA.

3.27. As mentioned, car parking will be provided in the forecourt (a total of six spaces).

Bicycle parking (10 bike stands) will also be provided in the forecourt.

Landscaping and Exterior Lighting

3.28. The landscaping details are shown in Figure 3.7. As mentioned, it is intended to

remove 11 of the existing trees on Triq il-Belt Valletta, including the protected Pinus

halepensis (Aleppo pine) - see Figure 3.10. The trees are to be removed to

accommodate access to the Scheme and provide for better visibility. Additionally,

Pinus halepensis (Aleppo pine) trees are identified in Appendix 1 (Table 1) of the Fuel

Service Stations Policy 2015 as being a flammable tree species not to be located in the

vicinity of a fuel service station. The closest of the trees (to be removed) to the fuel

pump is 23 m. Transplanting the mature Pinus halepensis is not an option as they will

not survive.

30

3.29. New planting will take the form of five Judas (Cercis siliquastrum) trees. These tree

species are listed in Appendix 3 of the Guidelines on Trees, Shrubs and Plants for Planting

and Landscaping in the Maltese Islands, 2002, as being acceptable species for planting in

locations ODZ and in the urban fringe. Cercis siliquastrum (Judas) trees are also listed

in Appendix 1 (Table 2) of the Fuel Service Stations Policy as being a lower

flammability species, acceptable for planting in the vicinity of fuel service stations.

Compensatory planting for the loss of the pine trees would need to be explored with

ERA.

3.30. The exterior lighting layout for the Scheme is shown in Figure 3.11. Energy

efficient lighting will provide adequate illumination levels to the forecourt, with

minimum glare and light pollution.

Services

3.31. As explained by the Applicant, all the utility services required to accommodate the

Scheme (electricity, mains water, sewerage, and telecommunications) are readily

available near the Scheme site.

31

Figure 3.7: Scheme Layout

33

Figure 3.8: Upper Floor Plan

35

Figure 3.9: Scheme Elevations / Sections

37

Figure 3.10: Trees to be removed from Triq il-Belt Valletta

39

Figure 3.11: Exterior Lighting Plan

41

Fuel Storage and Dispensing

3.32. Liquid fuel will be stored in four underground storage tanks in accordance with

EN12285-1:2003, and as shown in Figure 3.12. The tanks will be compartmented;

tank compartments T21, T22, and T42 will each have a diesel fuel capacity of 30,000

litres, tank compartments T11, T12, and T41 will contain unleaded petrol, with a fuel

capacity of 30,000 litres each, and compartments T31, T32, and T33 will contain

unleaded petrol, biodiesel, and diesel respectively, each with a 20,000 litres capacity.

3.33. The tanks will be double-skinned; an interstitial Class 1 leak detection system (MSA

EN 13160) will also be installed. These storage tanks will also be protected against

cathodic corrosion by an external polyurethane protective coating, having a 15 year

anti-corrosion guarantee.

3.34. The tanks will be placed inside a pit constructed on a 150 mm granular base fill, made

from compacted fine sand over a solid base, free from water ingress. Moreover, the

tanks will be evenly backfilled with non-cohesive, chemically inert material such as

sand, as recommended in Table A.1 of EN12285-1: 2003 and dry lean mix up to the

manhole neck. The tanks will have a minimum backfill of 300 mm between the tank

and the wall of pit.

3.35. The proposed pit will be built to act as a reservoir that is impermeable to any fuel

such that, if there is a fuel spill, the fuel will be retained within the structure and will

not be lost outside the pit structure. The pit will be lined with a fuel resistant and a

hydraulic barrier geotextile lining, suitable for secondary containment of unleaded

petrol, diesel, and bio-diesel to EN14214:2003 and other hydrocarbons. The

geotextile will have a permeability of 5x10-9 centimetres per second. The lining will

have a self-healing capability. The base of each pit will provide a firm continuous level

of support for the tank. It will be slightly inclined towards a hydrocarbon monitoring

well.

3.36. This monitoring will be in the form of a small pit, some 300 mm x 300 mm x 200 mm

depth, which shall be equipped with a Class 5 leak detection probe. This leak

detection system was proposed by the engineer following the recommendations by

Ing Marco Cremona in the Hydrology Report (see Technical Appendix 2: Geo-

Environment Study). If the two skins of the tank fail, and the Class 1 interstitial leak

detection also fails to detect such double skin failure, fuel will be trapped in the tank

chamber, with progressive accumulation in the monitoring well. This leak will be

detected by this additional Class 5 detection system.

3.37. The fuel dispensers will be in accordance to European directive ATEX94/9/EC and

EN13617-1. Dispensers will be installed over a glass reinforced fuel dispenser sump

to prevent any fuel contamination. Collision protection, such as bollards or an

adequately sized kerb, will be installed for all dispensers. Dispensing nozzles will be

clearly labelled in accordance with the Malta Resources Authority (MRA)

requirements.

42

3.38. A suction system will be used to transfer fuel from the underground fuel storage

tanks to the fuel dispensers, where a non-return valve will be installed to ensure that

the suction pipe remains primed whilst the dispenser is at rest. This non-return valve

will be installed immediately below the fuel dispenser, at the point of connection of

the pipework. The fuel dispensers will be wired in armoured cables.

3.39. Stage IB and Stage II vapour recovery systems will be installed to recover most of the vapours generated during petrol delivery to the storage tanks, and during fuel

dispensing to clients’ vehicles respectively (see Figure 3.13).

3.40. Pipelines from tanks to the offset filling points, dispensing equipment and vent pipes

will be routed below ground, away from buildings and / or other features that would

prevent access to the pipelines if a need arises after installation. The vent pipes

above ground will be in galvanised steel. All underground pipework will be

surrounded with a minimum thickness of 150 mm fine sand to support the pipe

system, protect it from mechanical damage and to handle the effect of heavy traffic or

other loading imposed on the pipe system. All vent pipework shall have a flame

arrestor to EN 7244 and EN ISO 16852, at the discharge points.

3.41. In order to prevent fuel entering the vapour return pipework manifold in the event

that a fuel storage tank is overfilled, a liquid-operated overspill prevention valve will

be installed. Moreover, a Type ‘A’ overfill prevention system, in accordance to BS

EN 13616: 2004, will be installed on each tank fill-line. The overfill prevention valve

will be certified to a Phase 1 vapour recovery system by CARB, ULC-Approved, or

better. This system has the advantage that in case of fuel tank overfilling, it prevents

pressurising the fuel storage tank and fuel dispenser, with the head of liquid in the

vehicle compartment.

3.42. The Scheme will also be equipped with one or two Outside Payment Terminals

(OPT) that will be activated by cash, credit card or a key system. A limit of not more

than 100 litres to be delivered in a single transaction will be set. The OPT will have a

timing function to prevent continuous operation for a period of more than three

minutes, in order to avoid any spillages or fuel run-off.

3.43. Autogas will be stored in one above ground storage tank with a capacity of 5,000

litres (see Figure 3.14). Installation of the LPG tank will be carried out in

accordance with the MRA LPG Codes of Practice. The tank will be enclosed in a

protective compartment with a 1.8 m high fence, having two exit doors at extreme

ends. The tank will be installed and fitted with the appropriate fittings in accordance

with the MRA Codes of Practice. It will be pre-fabricated in corrosion resistant steel

of suitable thickness.

3.44. There will be two autogas dispensers, each equipped for 1-product, and being of the

dual hose type. These will be located on the island adjacent to the other fuel

dispensers. Autogas will be supplied to the dispenser in liquid form from a remote

pump installed near the tank (inside the fenced compartment).

43

3.45. All forecourt surface water shall be passed through a light liquid separator system

(see Figure 3.15). The fuel separator system to be installed will be a full retention

‘Forecourt’ Separator Class 1 equipped with an alarm kit, in accordance to EN858.

The fuel separator is designed to discharge to the main sewer, through an

appropriate siphon trap; this type of separator is designed to achieve a concentration

of less than 5 mg/l of oil. The fuel separator will be sized in accordance to EN858-2:

2003 and its size will be of 10,000 litres with 7,000 litres of fuel retention, suitable for

a maximum flow rate of 20 l/s.

3.46. The forecourt surface will be impermeable to all hydrocarbons and will not allow

seepage through or below the surface; this will be achieved through the laying of a

concrete surface finish and any associated expansion or joining material will also be

impermeable and resistant to any hydrocarbons. In addition, a fuel resistant

geotextile lining will be installed under the forecourt area, to ensure that no fuel will

contaminate groundwater.

3.47. The forecourt will be equipped with an overhead canopy, manufactured from fire-

retardant material. Energy efficient lighting will provide adequate illumination levels

with minimum glare and light pollution.

Car Wash

3.48. The car wash area will consist of six jet washer bays and an associated drying areas.

The area will be contained by peripheral surface drainage channels to divert any

contaminated water towards the full-retention separator. The drainage channels will be sufficiently sized to allow run-off to be intercepted positively and to freely enter

the channel without over-passing. Drainage from the car washing / drying area will

be discharged via a full-retention Class 1 oil / water separator, designed for water

recycling. The discharge from the separator will be diverted either to the recycling

water reservoir, or into the sewer, depending on the water recovery and demand of

the fuel service station.

Electric Charging Points

3.49. Two electric car charging stations are proposed, located in two parking bays. Power

supplied to each charging post will be in the region of 7.3 kW 3-phase, 400 Volts

alternating current.

Operating Hours

3.50. The fuel dispensers and car wash facilities will be open to the public 24 hours, seven

days a week (self-service outside of staffed hours). A limit of 100 L of fuel will be set

on all self-service transactions. For safety reasons, the autogas dispensers will only

be available for use when the fuel service station is staffed.

3.51. The service station, retail unit, and services garage will be staffed from Monday to

Friday, from 06:30 to 18:00, and on Saturday from 06:30 to 15:00.

45

Figure 3.12: Tank Layout

47

Figure 3.13: Vapour Recovery System

49

Figure 3.14: Details of LPG Tank and Pipework

51

Figure 3.15: Surface Water Drainage

53

RESOURCES

Electricity Supply

3.52. The Scheme will have an estimated annual electrical consumption of 48,000 kWh.

Water

3.53. The Scheme will have a large rain water reservoir, having a capacity of 720 m3 (see Figure 3.15 above). This reservoir will harvest rain water collected from the roofs

of the buildings, as well as from the canopies above the forecourt and carwash bays. .

3.54. Used water from the car wash area will be collected in a separate water reservoir for

reuse in the car wash (see Figure 3.15). This recycled water reservoir will have a

capacity of 44 m3. The used water will first be diverted through a full-retention Class

1 oil / water separator manufactured and testing in accordance to EN 858-1 and PPG

3, and designed for water recycling. The car wash area comprises three manual jet

wash booths, each having a water usage of 72 L per cycle. Assuming 600 car washes

per month, the total average water demand amounts to 86,400 L per month or

1,036.8 m3 per annum.

3.55. It is projected that 60% of the water used in the car wash operation will be

recovered and recycled. Thus the annual demand is 0.4 x 1,036.8 = 414 m3 per

annum.

Raw Materials

3.56. The principal raw materials (and estimated volumes) to be used in the construction

of the Scheme are shown in Table 3.1.

Table 3.1: Estimated Raw Materials for Construction

Material Volume

Hollow concrete blocks 2,520 m2

Other concrete materials (e.g. bases, strip foundations, flooring,

slab, infill, columns, beams, lintels) 750 m3

Damp proof course 465 m2

Waterproofing membrane 465 m2

Reinforcement 18,000 kg

Rendering 1,300 m2

3.57. The principal raw materials in use during operation are the fuels that will be

dispensed to vehicles; these will consist of diesel, biodiesel, gasoline, and autogas.

Vehicle tyres will also be used in the tyre services garage, and detergents will be used

in the car wash facilities.

54

SCHEME CONSTRUCTION

Construction Timing

3.58. The estimated duration of the construction period is envisaged to be approximately

six months. The construction will be carried out concurrently across the Scheme

site and there will be some overlapping of the various construction phases. The

indicative timing of the construction phases is described in Table 3.2.

Table 3.2: Construction Timing

Phase Approximate Duration

(months)

Site clearance and excavation for the fuel tanks 1

Construction of the fuel station and other structures 4

Finishing and landscaping works 2

Commissioning of the fuel service station 1

Plant and Machinery

3.59. The plant and machinery envisaged to be used during the construction of the Scheme

is shown in Table 3.3.

Table 3.3: Construction Plant and Machinery

Plant / Machinery Numbers

Site Clearance / Excavation

Excavator 1

Mechanical shovel 1

Dump trucks 1

Construction / Finishing

Mobile crane 1

Concrete ready mix trucks 1

Delivery trucks 1

Construction Waste

3.60. The principal wastes expected to be generated during construction of the Scheme

are identified in Table 3.4. This will primarily consist of excavation waste, estimated

at 2,353 m3, which will comprise a mix of rock and fill. The sub-surface geotechnical

site investigations revealed material belonging to the Lower Globigerina Limestone

Member. Part of the site was a former quarry which has been infilled with inert

material. The extent of the quarry could not be determined through the two cores

that were taken (see Chapter 5 of the EPS). However, the Applicant confirmed that

55

all excavated material will be taken to the Applicant’s facility next door to the

Scheme site to be reused.

3.61. There may be steel off cuts, residue inert building material (like broken concrete

blocks), residue timber used during construction, and domestic waste generated by

the construction workers. When the mechanical, electrical and finishing works begin,

other wastes will likely include plastic conduit, copper wires covered in plastic, off cuts of steel supporting rods and cable trays, ceramic tiles, marble off cuts, paper and

plastic bags for materials, aluminium off cuts, broken glass items, and gypsum soffit

ceiling parts.

3.62. A waste management area will be identified on the construction site, with colour

coded skips for segregating waste types; if required, smaller bins for separated waste

types will be positioned across the site.

3.63. Water run-off during excavation will drain to one area of the excavation for

settlement (silt traps) before collection by vacuum pumps for disposal as directed by

the Malta Resources Authority. The silt traps will also be water proofed to ensure

that the highly turbid run-off does not leave the site.

Construction Personnel

3.64. It is envisaged that there will be up to ten personnel employed during the

construction stage.

Construction Management

3.65. A detailed Construction Management Plan (CMP) will be prepared by the contractor

awarded responsibility for the construction works. This will detail the layout of the

site during the construction phase, and the measures to be put in place to mitigate

impacts from construction, as well as safety measures. The placement of the

temporary site office(s), details on hoarding, access and signage will also be described

in the CMP, as will the arrangements to be made for construction traffic. Figure

3.16 illustrates what is envisaged at this stage in terms of the layout of the

construction site. Given that the Applicant is also a supplier of raw materials and can

process inert waste, very little construction material is expected to leave the site.

3.66. If any utilities need to be relocated during excavation this will be at the expense of

the Applicant and in cooperation with the relevant utility suppliers / operators prior

to the commencement of the excavations.

57

Table 3.4: Construction Waste

Phase EWC Code Description Estimated Quantity Destination

Excavation

17 02 01

17 02 03 Packaging waste Small quantities Sent for recycling if clean (otherwise to landfill)

01 01 02 Excavated material 2,353 m3 All material will go to the neighbouring Denfar facility

for processing (as also operated by the Applicant)

Construction /

finishing

17 01 02 Bricks Small quantities All material will go to the neighbouring Denfar facility

for processing (as also operated by the Applicant)

17 01 03 Tiles Small quantities Licensed inert landfill

17 02 03 Plastic waste Small quantities Sent for recycling if clean (otherwise to landfill)

17 04 02

17 04 05 Rebar cut-offs, steel, aluminium Small quantities Sold as scrap metal

15 01 01

15 01 02 Packaging Small quantities Għallis non-hazardous landfill

59

Figure 3.16: Construction Site Layout Plan

61

SCHEME OPERATION

Employment

3.67. It is envisaged that the Scheme will employ up to approximately five employees when

it becomes operational.

Operational Waste

3.68. Operational waste likely to be generated by the Scheme will be primarily municipal

waste. Table 3.5 lists the principal wastes expected to be generated during the

operation of the Scheme. Waste oil rags and waste tyres from the tyre service

garage will be stored, pending collection, in a bunded waste management area (see

Figure 3.7 above). Non-hazardous waste from the shop and office will be stored in

waste bins prior to its removal from site. Sludge from the separators will be

removed as needed, and will be retained in the separators prior to removal.

3.69. Waste will be removed from the site using waste carriers registered for that type of

waste, or collected by authorised waste brokers. Wastes will be sent to authorised

facilities; where possible, recycling / recovery will be preferred over disposal. All hazardous waste transferred from the Scheme site will accompanied by a valid

hazardous waste consignment permit, issued by ERA. Each consignment under the

consignment permit will also be accompanied by a consignment note.

EMISSIONS

Emissions to Air

3.70. Emissions to air in respect of the operation of the Scheme are discussed in detail in

Chapter 8; the following summarises the emissions to air likely to be generated

during the construction and operation phases.

Construction

3.71. The construction processes are expected to generate minor dust emissions (both

total suspended particulates and PM10), which are temporary and can also be

mitigated to some extent.

Operation

VOC Emissions

3.72. In fuel service stations where there is no abatement, emissions of Volatile Organic

Compounds (VOC) arise mainly from the following activities related to the handling

of petrol:

Tank emissions: vapour displacement when an incoming bulk delivery of petrol is

received into storage tanks; and

62

Emissions during refuelling: occur when petrol is transferred from the tanks to

vehicles. They are a combination of vapour from the larger tank’s contents and

the vapour evolved in the vehicle’s fuel tank as a result of splashing and

turbulence during filling.

3.73. These emissions are caused by the release of vapour from petrol, due to its high

vapour pressure and low flash point (-43 oC). Diesel and other fuels handled at the

Scheme have a lower vapour pressure and a higher flash point, and therefore do not

release significant emissions, even without abatement.

3.74. Legal Notice 228 of 2016, the Control of VOC Emissions (Storage and Distribution of

Petrol from Terminals to Service Stations) Regulations (S.L. 549.52), stipulates that service

stations meeting certain criteria must be fitted with the following vapour recovery

systems:

Stage IB recovery: designed to reduce the total annual loss of petrol resulting from loading into storage installations at service stations to below 0.01% of the

throughput mass by mass (m/m), by returning the vapours through a vapour-tight

connection line to the mobile container delivering the petrol; and

Stage II recovery: designed to recover petrol vapours during refuelling, where the

efficiency of the system must be at least 85% and the vapour / petrol ratio must

be from 0.95 to 1.05 when the petrol vapour is transferred to an underground

storage tank at the service station.

3.75. As shown in Figure 3.13 above, both Stage IB and Stage II recovery will be installed

at the Scheme.

Emissions from Road Traffic

3.76. It is expected that most of the trips to and from the Scheme will be ‘pass-by’ trips,

that is, vehicles that would pass by the Scheme site anyway. The Annual Average

Daily Traffic (AADT) for Triq il-Belt Valletta is estimated at 24,780, while the amount

of vehicles that will stop at the Scheme is estimated at about 324 per day on average,

roughly 110,000 per annum3. As stated in the TIA carried out for the Scheme, it is

estimated that a very significant majority of trips to and from the Scheme will not be

new trips. These ‘pass-by’ trips will not result in a net increase in traffic; hence,

there is no significant increase in the AADT as a result of the Scheme.

Odour Emissions

3.77. Odour emissions may also arise from the handling of fuel. The impact from odour

emissions is assessed in Chapter 8.

3 Bjorn Bonello, author of Transport Impact Assessment for the Scheme. E-mail dated 28th July 2017.

63

Table 3.5: Estimates of Operational Waste

Activity EWC Code HP codes Waste Description Estimated Quantity

(annual) Destination

Tyre servicing 16 01 03 - Tyres 520 Tyres Sent for recycling

15 02 02* HP3, HP7, HP14 Contaminated rags 230 L Waste Oils Co. Ltd

Retail facilities 15 01 01

15 01 02 - Cardboard and plastic packaging 9,200 L Sent for recycling

Office

20 03 01 - Mixed domestic waste 5,200 L Għallis non-hazardous landfill

20 01 01

20 01 02

20 01 39

20 01 40

- Recyclable waste 1,000 L Sent for recycling

Effluent management 13 05 07* HP3, HP6, HP7,

HP14 Oil-water separator contents 2,600 L Waste Oils Co. Ltd

65

Greenhouse Gases

3.78. Greenhouse gases are expected to be generated primarily off-site, as a result of

electricity consumption by the Scheme during operation. Table 3.6 shows the

estimated CO2 emissions from the Scheme in operation. The loss of mature trees

will also increase emissions due to their carbon capture capabilities. This could be

offset by compensatory planting.

Table 3.6: CO2 Emissions from Scheme Operations

Activity Annual Consumption CO2 Emissions

Rate Annual CO2 Emissions

Electricity consumption 48,000 kWh 0.77 kg/kWh4 36,960 kg

Noise and Vibration

3.79. An increase in traffic would also result in increased noise emissions. However, as it

is expected that most of the trips to and from the Scheme will be ‘pass-by’ trips,

noise impacts from additional traffic are not expected to be significant.

3.80. The car wash facilities will also generate noise. The nearest residence is located

approximately over 230 m to the southwest of where it is proposed to locate the car

wash bays. The bays will be located on the southern perimeter of the Scheme site.

The bays will be enclosed to the rear and sides and covered overhead by a

polycarbonate canopy. The orientation and the overhead and rear / side enclosure of

the car wash area will serve to reduce noise emissions.

3.81. There will be no sources of vibration during the operation of the Scheme.

SCHEME DECOMMISSIONING

3.82. Given that the Scheme has not been constructed yet, there are no immediate plans

for decommissioning. If and when in the future the Scheme operators decided to

decommission the Scheme, the relevant authorities will be informed and a full

decommissioning plan will be prepared and submitted for approval prior to

commencement of decommissioning works.

3.83. The full decommissioning plan will follow any local or international guidelines

applicable at that time, including in relation to the environment and health and safety,

and will also include a waste management plan. The full approved decommissioning

plan will be implemented within 12 months of the final cessation of activities, or in

accordance with another timeframe as may be agreed with the relevant authorities at

the time. An outline decommissioning plan is described below.

4 Value based on the CO2 per unit kWh generated by Delimara and Marsa Power Stations (2014 data).

66

Outline Decommissioning Plan

3.84. The tanks, associated pipework, and fuel dispensers will be emptied in a process

known as bottoming. The separators will also be emptied of all contents. All tank

bottoms and separator contents will be removed from the site and disposed of as

hazardous waste.

3.85. The tanks will then need to be made safe by removal of any explosive vapours. This

will be done by filling the tank with inert gas (usually nitrogen) or with water. If

water is used, it will be passed through the separator prior to discharge into the

sewer, or collected and sent off-site for treatment.

3.86. Tanks may either be decommissioned in situ or off-site, although removal is

preferred5. In either case, care will be taken to avoid damage to the tanks during

decommissioning, to avoid risk of contamination. If the tanks are decommissioned in

the ground, they will be filled with solid material, such as hydrophobic foam,

concrete, or a sand and cement slurry.

3.87. If practicable, the oil / water separators will be removed for off-site disposal;

otherwise they will be decommissioned in the ground by cleaning out the residues,

making safe with nitrogen or water, and filling with solid material in a similar manner

to the tanks. All inlets and outlets will be sealed.

3.88. The ground will be checked for visible signs of contamination. Site records will also

be consulted to check for past spillages or leakages. If necessary, and in consultation

with the relevant authorities, core samples will be taken and tested for hydrocarbon contamination. Where test results show contamination which poses a significant risk

to human health or the environment, recommendations will be made for removal,

control, containment, or reduction of the contamination so that the site, taking into

account its future use, ceases to pose such a risk. Applicable ERA and international

guidance on remediation6 will be consulted.

3.89. Tanks and pipework will be classified as hazardous waste and transported to facilities

in Malta or overseas that are licensed to accept and treat such wastes.

3.90. All waste transfers will be carried out by licensed waste carriers, and the

consignment note procedure will be followed for hazardous waste. Exports of waste

will be carried out in accordance with the requirements of Trans-frontier Shipment of

Waste Regulations (1013/2006/EC). ADR-certified carriers will be used when

required by the European Agreement concerning the International Carriage of Dangerous

Goods by Road.

5 Institute of Petroleum (2002) Guidelines for Soil, Groundwater and Surface Water Protection and Vapour Emission

Control at Petrol Filling Stations http://publishing.energyinst.org/_data/assets/file/0005/9824/Guidelines-for-soil-

groundwater-and-surface-water-Jun-2002.pdf. 6 Such as Mobile Plant for Site Remediation Guidance Note

(https://era.org.mt/en/Documents/GBR%2018%20Mobile%20Plant%20for%20Site%20Remediation%20ERA.pdf).

https://era.org.mt/en/Documents/GBR%2018%20Mobile%20Plant%20for%20Site%20Remediation%20ERA.pdf

67

4. LEGISLATION AND POLICY CONTEXT

INTRODUCTION

4.1. This chapter discusses the relevance of international and national legislation, and

Maltese planning policy, and the compatibility of the Scheme with this legislation /

policy. It highlights and assesses the policies of Government Ministries, where

relevant, and outlines those European Union (EU) Directives and Regulations, and

other international obligations, applicable to the Scheme.

4.2. As discussed, the legal basis for the Environment and Resources Authority’s (ERA)

request for the preparation of an Environmental Impact Assessment stems from the

Environmental Impact Assessment Regulations published in 2007 (Legal Notice 114 of

2007) (S.L. 549.46).

INTERNATIONAL LEGISLATION

4.3. International legislation relevant to the Scheme arises from International Treaties and

Conventions to which Malta is a signatory, EU legislation, and local legislation

transposing these.

4.4. The International Protocols and Conventions relevant to the Scheme include:

The Geneva Protocol concerning the Control of Emissions of Volatile Organic Compounds

(VOCs) or their Transboundary Fluxes (Geneva, 18.11.1991)7;

The European Cultural Convention (Paris, 19.XII.1954)8; and

The European Convention on the Protection of the Archaeological Heritage (Revised)

(Valletta, 16.I.1992)9.

The Geneva Protocol on VOC emissions

4.5. This Protocol was adopted in Geneva on the 18th November 1991 and entered into

force on the 29th September 1997. The objective of the Protocol is to control and

reduce emissions of VOCs, which is the second major air pollutant responsible for

the formation of ground level ozone, so as to protect human health and the

environment from adverse effects. The Protocol extends the 1979 Geneva

Convention on Long-range Transboundary Air Pollution (CLRTAP).

4.6. Article 2.3(b)(ii) of this Protocol requires parties in those areas in which national or

international tropospheric ozone standards are exceeded or where transboundary

7 www.unece.org/fileadmin/DAM/env/lrtap/full%20text/1991.VOC.e.pdf 8 http://conventions.coe.int/Treaty/en/Treaties/Word/018.doc 9 http://conventions.coe.int/Treaty/en/Treaties/Word/143.doc

http://www.unece.org/fileadmin/DAM/env/lrtap/full%20text/1991.VOC.e.pdf

http://conventions.coe.int/Treaty/en/Treaties/Word/018.doc

http://conventions.coe.int/Treaty/en/Treaties/Word/143.doc

68

fluxes originate or are expected to originate to implement VOC controls during

petrol distribution and motor vehicle refuelling, and to reduce the volatility of petrol.

Implications for the Scheme

o The Scheme has been designed to take account of Malta’s obligations to

control and reduce emissions of VOCs. The impacts on air quality arising

from the Scheme are assessed in Chapter 8; the impacts of VOC emissions arising from the operation of the Scheme are considered to be

not significant.

The European Cultural Convention

4.7. This Convention was adopted in Paris on the 19th December 1954 and entered into

force on 5th May 1955. The objective of the Convention is to develop mutual understanding among the peoples of Europe and reciprocal appreciation of their

cultural diversity, to safeguard European culture, to promote national contributions

to Europe's common cultural heritage respecting the same fundamental values and to

encourage in particular the study of the languages, history, and civilisation of the

Parties to the Convention.

4.8. The Convention requires the Contracting Parties to “regard the objects of European

cultural value placed under its control as integral parts of the common cultural heritage of

Europe”, and “shall take appropriate measures to safeguard them and shall ensure

reasonable access thereto”.

Implications for the Scheme:

o The impacts on cultural heritage features and on landscape arising from

the Scheme are assessed in Chapter 6 and Chapter 7, respectively, of

the EPS. It is considered unlikely that there will be any significant impact

on the closest identified cultural heritage features to the Scheme site.

There is the potential for impacts on unrecorded archaeological artefacts

during the remaining excavation to be carried out on the site; the extent

of this impact is uncertain, as it will depend on whether artefacts are

present, their importance, and the extent of any loss or damage. The

impacts on landscape are considered to be of moderate impact to being of

no significant impact.

The European Convention on the Protection of the Archaeological

Heritage (Revised)

4.9. This Convention, which was agreed in Valletta on 16th January 1992, amends the

original Convention (agreed in London in 1969) on the protection of archaeological

heritage. The aim of this (revised) Convention is “to protect the archaeological heritage

as a source of the European collective memory and as an instrument for historical and

scientific study”. This revision was brought about through the acknowledgement that

European archaeological heritage is under serious threat from deterioration as a

69

result of “major planning schemes, natural risks, clandestine and unscientific excavations,

and insufficient public awareness”. In the context of the Convention, archaeological

heritage includes “structures, constructions, groups of buildings, developed sites, moveable

objects, monuments of other kinds as well as their context, whether situated on land or

under water”.

4.10. The Convention requires the Contracting Parties to institute a legal system for the

protection of archaeological heritage, including:

The creation and maintenance of a heritage inventory;

The creation of archaeological reserves; and

Mandatory reporting to competent authorities of the chance discovery of

archaeological material.

4.11. The Convention also requires the Parties to apply procedures for the authorisation

and supervision of excavations and other archaeological activities to ensure that they

are undertaken by qualified persons and in a scientific manner.

4.12. Other provisions of the Convention include:

The physical protection of archaeological heritage;

Integrated conservation of the archaeological heritage (including through

reconciliation with development plans and other planning processes);

Resourcing rescue archaeology;

Collection and dissemination of scientific information;

Public awareness; and

Prevention of illicit circulation of elements of archaeological heritage.

4.13. Malta ratified this Convention on 24th November 1994 and it entered into force on

25th May 1995. The provisions of this Convention have been transposed into local

legislation by the Cultural Heritage Act of 2002 (see below).


o The impacts on recorded features of archaeological importance arising

from the Scheme are assessed in Chapter 6 of the EPS. The impacts on

recorded features of archaeological importance are considered to be of

no significance. There is the potential for impacts on unrecorded

archaeological artefacts during the remaining excavation to be carried out

on the site; the extent of this impact is uncertain, as it will depend on

whether artefacts are present, their importance, and the extent of any loss

or damage.

70

EUROPEAN POLICY AND LEGISLATION

4.14. The Treaty establishing the European Community (Article 174) provides that

members should pursue the preservation, protection and improvement of the quality

of the quality of the environment, aim at a high level of environmental protection and

apply policies “….based on the precautionary principle and on the principles that Preventive action should be taken, that environmental damage should as a priority be

rectified at source”.10

4.15. The relevant EU Directives include the EIA Directive 2011/92/EU on the assessment

of the effects of certain public and private projects on the environment, which has been

transposed by the Maltese Environmental Impact Assessment Regulations 2007, and

various Directives that relate to waste, water, air quality, fuel quality and others. A

revised Environmental Impact Assessment (EIA) Directive (2014/52/EU) also entered

into force in 2014 and will start to be applied as from 16th May 2017. The EIA

Regulations are currently being reviewed to ensure transposition of the EIA

Directive.

4.16. Since the European Union’s environment acquis has been transposed into national

legislation, the Directives per se have not been assessed and instead the national

legislation transposing these Directives is assessed below.

NATIONAL LEGISLATION

The Constitution of Malta

Declaration of Principles

4.17. The Constitution of Malta (Section 9) declares that the State shall safeguard the

landscape and the historical and artistic patrimony of the Nation. These are the only

aspects of the environment referred to in the Constitution, underlining the

importance of the landscape and historical heritage.

10 Article 191 (ex Article 174 of the Treaty establishing the European Community):

1. Union policy on the environment shall contribute to pursuit of the following objectives:

- Preserving, protecting and improving the quality of the environment;

- Protecting human health;

- Prudent and rational utilisation of natural resources;

- Promoting measures at international level to deal with regional or worldwide environmental problems,

and in particular combating climate change.

2. Union policy on the environment shall aim at a high level of protection taking into account the diversity of

situations in the various regions of the Union. It shall be based on the precautionary principle and on the

principles that preventive action should be taken, that environmental damage should as a priority be

rectified at source and that the polluter should pay.

In this context, harmonisation measures answering environmental protection requirements shall include,

where appropriate, a safeguard clause allowing Member States to take provisional measures, for non-

economic environmental reasons, subject to a procedure of inspection by the Union.

71

4.18. Local legislation relevant to the Scheme is described in the following sections.

Environment Protection Act 2016 (Act I of 2016)

4.19. The former Environment and Development Planning Act, 2010 which consolidated

the provisions of the Development Planning Act 1992 (as amended) and the

Environment Protection Act 2001, has recently been replaced by the Environment

Protection Act and the Development Planning Act.

4.20. The Environment Protection Act stipulates that “It shall be the duty of every person and

entity, whether public or private, to protect the environment and to assist in the taking of

preventive and remedial measures to protect the environment and manage natural

resources in a sustainable manner”.

4.21. Various duties fall to the Government. Those relevant to the Scheme are:

“4(a) to manage the environment in a sustainable manner by

integrating and giving due consideration to environmental concerns in

decisions and policies on land use, socioeconomic, educational and other

matters;

4(b) to take such preventive and remedial measures as may be

necessary to address and abate the problem of pollution and any other

form of environmental degradation in Malta and beyond, in accordance

with the polluter pays principle and the precautionary principle;

4(e) to apply scientific and technical knowledge and resources in

determining matters that affect the environment;

4(f) to ensure the sustainable management of wastes, to promote the

reduction of waste and the proper use, reuse and recovery of matter;

4(g) to safeguard biological diversity;

4(h) to combat all forms of pollution and environmental degradation;

4(i) to consider the environment as the common heritage and common

concern of mankind; and

4(j) to provide incentives leading to a higher level of environmental

protection”.

4.22. The Act makes provision for the establishment of an authority to implement the

duties of Government under the Act – the Environment and Resources Authority

(ERA). ERA’s principal duties include:

to perform and succeed in the functions, assets, rights, liabilities and obligations of the competent authority established under the provisions of article 6 of the

Environment and Development Planning Act and under the provisions of article 3

72

of the Malta Resources Authority Act in so far as such functions, assets, rights,

liabilities and obligations refer to the role of the competent authority established

under the said Act in relation to the protection and management of the

environment and sustainable management of natural resources, and the

prevention, mitigation, offsetting or remediation of adverse effects on the

environment;

to formulate and implement policies relating to the protection and management

of the environment and the sustainable management of natural resources;

to carry out and or commission surveys, studies, assessments, investigations,

audits, monitoring and promote research on any matter relating to the

environment and the natural resources;

to provide information and issue guidelines to the public and to commercial and

other entities on matters relating to the environment and natural resources;

to establish measures for the protection of the environment and to promote the

efficient use of natural resources;

to ensure that national and international obligations relative to the matters

regulated by or under the Act are entered into force and complied with;

to permit, assess, investigate, audit, monitor, and take action on, any activity, intervention, project, operation or land use that may have an effect on the

environment;

to advise the Minister on international legislation and on the formulation of

national policy; and

to carry out, review or request others to carry out environmental assessments, environmental audits and environmental monitoring of activities and works having

an impact on the environment.

Development Planning Act, 2016 (Act VII of 2016)

4.23. The Development Planning Act (DPA) establishes the Planning Authority. According

to the Act the role of the Planning Authority is:

(a) to perform and succeed in the functions which were previously assigned to the Malta Environment and Planning Authority under the provisions of the Environment and

Development Planning Act and are now contained in this Act and to perform and succeed in

the assets, rights, liabilities and obligations of the Malta Environment and Planning Authority

established under the provisions of the Environment and Development Planning Act to the

extent that the Minister may prescribe by regulations under this Act;

(b) the functions of the Executive Council and the Planning Board listed under articles 38

and 64;

73

(c) to facilitate and coordinate the permit granting process for projects of common interest;

(d) to perform and succeed in the functions which were previously assigned to the Building

Regulation Board and the Building Regulation Office under the provisions of the Building

Regulation Act and which are now contained in this Act and to perform and succeed in the

assets, rights, liabilities and obligations of the Building Regulation Board and the Building

Regulation Office established under the provisions of the Building Regulation Act to the

extent that the Minister may prescribe by regulations under this Act; and

(e) the performance of any other functions as may from time to time be assigned to it by the

Minister, including the functions required to give effect to any international obligation entered

into by Malta relative to matters regulated by this Act.

4.24. The Act details the various activities to be carried out by the Planning Authority.

With respect to development permits applications Regulation 71 of the Act requires

that:

(1) Any person, including a department of government or body corporate established by law,

wishing to carry out any development referred to in article 70, shall apply to the Planning

Board for such permission, in such manner, on such form and giving such information as the

Planning Board may prescribe.

(2) The Planning Board may grant three types of development permissions:

(a) an outline development permission which gives approval in principle to the proposed

development, but specifies reserved matters which need to be included in a full development

permit application or applications. A period of time shall be stated within which the full

development permit application or applications shall be submitted, failure of which would

render the outline development permit null. Such period shall in no case exceed five years.

No development may commence without a full development permit;

(b) a full development permission is required before any development can commence,

whether or not preceded by an outline development permission. The full development

permission will be given subject to conditions included in the permission;

(c) a non-executable full development permission which approves the development but

imposes conditions to be adhered to before a full development permission is issued.

(3) Any person may also apply to the Planning Board for a determination as to whether a

proposal requires a development permission and the Planning Board is bound to inform that

person whether a development permission or any other form of notification is required in

terms of this Act or not.

Environmental Management Construction Site Regulations, 2007

4.25. The aim of the Environmental Management Construction Site Regulations

(S.L.552.09) is to limit environmental degradation through construction management

practices that cause least nuisance to neighbours, minimise risk to workers, and

safeguard private and public property. The Regulations came into force on 1st

74

November 2007.

4.26. The Regulations apply to “...any construction, water mining, or any other disturbances to

the soil, including land clearing, scraping, ground excavation, land levelling, grading, cut and

fill operations, and ancillary activities that include travel to the construction site, travel on

access roads to and from the construction site and demolition activities”.

4.27. The Schedules within the Regulations provide requirements for reducing nuisance to

neighbours through:

Erection of a site notice containing details of the owner, site manager, architect

and contractor;

Conditions for cutting of stone and bricks on site;

Transportation of loose material;

Obstruction of pavements;

Hazards to vehicular traffic;

Cleaning of the site and its immediate vicinity;

Rodent control;

Hoardings around development sites;

Covered ways and barricades;

Safe passage past the site;

Nuisance abatement, including construction times; and

Control of dust emissions.

4.28. Technical guidelines and specifications are also provided for minimisation of noise and

vibration levels; health and hygiene, including waste management; hazardous materials

handling; and point source pollution from storm water.

4.29. The Regulations apply to any construction site, except where the Minister has

exempted such development under the provisions of Schedule VI ‘Exemptions’.


o Regard has been given to the requirements of the Regulations in

addressing the construction impacts of the Scheme. An explanation of construction management is included in Chapter 3 of the EPS. Relevant

mitigation measures have been included in specific chapters of the EPS.

The construction of the Scheme will fall under the remit of these

regulations.

75

Legal Notices

4.30. The Regulations in force under the Environment Protection Act and the

Development Planning Act include the following Legal Notices that are relevant to

the Scheme:

Waste Management

Legal Notice 106 of 2007: Waste Management (Activity Registration) Regulations,

S.L.549.45 and Legal Notice 184 of 2011: The Waste Regulations (as amended,

S.L.504.37). These Regulations regulate the production and disposal of hazardous

and non-hazardous wastes. The Regulations aim to control all operations relating to the production and management of waste and promote sound waste

management practices so as to safeguard human health and the environment.

Legal Notice 55 of 2010: Waste Management (Waste Batteries and Accumulators) Regulations (as amended, S.L.549.54). These Regulations aim to maximise the

separate collection of waste batteries and accumulators.

Legal Notice 277 of 2006: Waste Management (Packaging and Packaging Waste) Regulations (as amended, S.L.549.43). These Regulations aim to reduce the

amounts of packaging waste disposed, including through the use of recycling.

Legal Notice 99 of 2004: Waste Management (End of Life Vehicles) Regulations

(as amended, S.L.549.36). These Regulations aim to prevent, reduce, recycle or

recover waste generated from vehicles.


o Waste management issues related to the construction and operation of

the Scheme are discussed in Chapter 3 of the EPS. The Construction

Management Plan that will be prepared for the Scheme will also address

waste management issues during construction. A waste management plan

for the operation may also be required as part of the environmental

permit for the operation of the Scheme. Construction and operational

waste management must be in accordance with these regulations.

Water

Legal Notice 194 of 2004: Water Policy Framework Regulations (as amended,

S.L.423.20). These Regulations are issued under both the Environment

Protection Act and the Malta Resources Authority Act. They establish a

framework for the protection of coastal waters as well as inland surface waters,

transitional waters and groundwater. The framework is intended to prevent

further deterioration, and to protect, enhance, and restore the status of aquatic

systems.


76

o The Scheme has been designed taking account of the need to ensure

against the contamination of water, as described in Chapter 3 of the EPS.

The impacts on groundwater quality and surface water run-off patterns

arising from the Scheme are assessed in Chapter 5 of the EPS; the

impacts are considered to be of minor significance.

Air Quality

Legal Notice 478 of 2010: Ambient Air Quality Regulations (as amended,

S.L.549.59). These Regulations lay down measures aimed at defining and

establishing objectives for ambient air quality designed to avoid, prevent or

reduce harmful effects on human health and the environment as a whole; and

assessing the ambient air quality in Malta on the basis of specified methods and

criteria. The Regulations do not set a target or limit value for Volatile Organic

Compounds (VOCs). However, they set a limit value for benzene of 5 µg/m3

(annual average).

Legal Notice 291of 2002: National Emission Ceilings for Certain Atmospheric Pollutants Regulations (as amended, S.L.549.32). The Regulations stipulate that

Malta must limit emissions of volatile organic compounds. It is the responsibility

of ERA to ensure that the thresholds laid down in the Regulations are not

exceeded.

Legal Notice 54 of 2009: Control of VOC Emissions (Storage and Distribution of Petrol from Terminals to Service Stations) Regulations (as amended, S.L.435.16).

These Regulations stipulate that service stations meeting certain criteria must be

fitted with Stage IB and Stage II vapour recovery systems.


o Of relevance to the Scheme are emissions in the form of VOCs,

particularly benzene, which is a component of petrol vapour. The Scheme

is envisaged to employ both Stage IB and Stage II vapour recovery to limit

benzene emissions. The Scheme will also necessarily require an

Environmental Permit from ERA. The impacts on air quality arising from

the Scheme are assessed in Chapter 8; the impacts of VOC emissions

arising from the operation of the Scheme are considered to be not

significant.

Biodiversity

Legal Notice 200 of 2011: Trees and Woodland Protection Regulations

(S.L.549.64). These Regulations protect a number of tree and shrub species

present in the Maltese Islands. Tree species listed in Schedules I and II are

protected, and all trees (except Schedule III species) sited in Tree Protected

Areas or other protected areas are also protected. When a development is likely

to have an effect on Schedule I or II trees, ERA may refuse the application,

impose permit conditions, require amendments to or relocation of the proposed

77

development, or a combination of these.


o The Scheme site is not located within a Tree Protected Area; however,

there are a row of mature Pinus halepensis (Aleppo Pine) trees on the

perimeter of the site, protected by Schedule I of LN 200 of 2011

(S.L.549.64), which will be removed to accommodate the Scheme. The potential for successfully relocating this tree species is considered to be

relatively limited, especially given the maturity of the trees. Pinus

halepensis is considered to be a flammable species of tree to be avoided

adjacent to fuel service stations.

Other

Legal Notice 116 of 2005: Freedom of Access to Information on the Environment Regulations (as amended, S.L.549.39). These Regulations ensure

freedom of access to and the dissemination of information held by public

authorities on the environment.


o The EPS and its supporting documents fall under this Legal Notice and are

to be made public.

Malta Resources Authority Act 2001

4.31. The Malta Resources Authority Act established the Malta Resources Authority

(MRA) and assigns it a number of functions in relation to the regulation of the water,

minerals, and energy sector. The Minister responsible for resources may, among

others, also make regulations for the granting, renewal, transfer, suspensions, and

cancellation of licences, permits, or other authorisations.

4.32. The regulations currently in force under the Malta Resources Authority Act that are

relevant to the Scheme include the Legal Notices listed hereunder:

Fuels

Legal Notice 53 of 2010: Petroleum for the Inland (Retail) Fuel Market Regulations (as amended, S.L.423.37). These Regulations regulate the inland retail fuel market

of petroleum, with the aim of safeguarding public interest and public safety.

Legal Notice 249 of 2008: Liquefied Petroleum Gas Market Regulations (as

amended, S.L.423.31). These Regulations regulate the LPG market, with the aim

of safeguarding public interest and public safety.

Legal Notice 44 of 2008: Quality of Fuels Regulations (as amended, S.L.423.29).

78

These Regulations seek to regulate the quality of fuels.


o The Scheme will comply with the requirements of these Regulations. The

Scheme requires a permit from the Regulator for Energy and Water

Services (REWS)11. Once the Scheme has been constructed and certified

by a competent person, the REWS will consider the issue of the permit.

Water

Legal Notice 17 of 2009: Water intended for Human Consumption Regulations (as amended, S.L.449.57). The Regulations aim to protect human health through the

provision of water that is wholesome and clean and to set in place a regime that

provides protection to persons consuming the water. They apply to any water

supplied by a water supplier.


o The Scheme has been designed taking account of the need to ensure against the contamination of water, including water intended for human

consumption, as described in Chapter 3. The impact on groundwater

quality arising from the Scheme is assessed in Chapter 5; the impact is

considered to be of minor significance.

Legal Notice 139 of 2002: Sewer Discharge Control Regulations (as amended, S.L.423.15). The Regulations control the discharge of effluents to the sewerage

system and prohibit the discharge of effluents containing substances listed in

Schedule A of the Regulations.

Implications for the Scheme: o The Scheme has been designed so as avoid hydrocarbon contamination in

discharge to the sewer through the installation of an oil-water separator.

Moreover, a sewer discharge permit is required for the Scheme; the

Applicant has not yet applied to the Water Services Corporation for this

permit.

Legal Notice 108 of 2009: The Protection of Groundwater against Pollution and Deterioration Regulations (as amended, S.L.423.36). These Regulations aim to

protect groundwater against pollution and deterioration.

11 The Regulator for Energy and Water Services (REWS) took over some of the functions of the Malta

Resources Authority (MRA) in 2015

79


o The Scheme has been designed taking account of the need to ensure

against the contamination of water, including groundwater, as described in

Chapter 3. The impacts on groundwater quality arising from the Scheme

are assessed in Chapter 5, and an Environmental Risk Assessment is

included as Volume 2 of this EPS. The impact on groundwater quality is

considered to be of minor significance.

Protection of Antiquities Regulations, 1932

4.33. Originally issued under the Antiquities (Protection) Act12 of 1925, these Protection of

Antiquities Regulations (as amended, S.L.445.01) apply to monuments and other

objects, whether movable or immovable, having a geological, palaeontological,

archaeological, antiquarian or artistic importance that have been in Malta for at least

50 years. The Regulations afford protection to buildings or sites of such importance,

ensuring that they are not demolished or altered without the permission of the

Minister responsible for Culture. The Regulations include a list of properties, sites

and features that qualify for protection under the Act.


o The impact of the Scheme on antiquities is discussed in Chapter 6 of the

EPS. It is considered unlikely that there will be any significant impact on

the closest identified antiquities to the Scheme site. There is the potential

for impacts on unrecorded antiquities during the remaining excavation to

be carried out on the site; the extent of this impact is uncertain, as it will

depend on whether artefacts are present, their importance, and the

extent of any loss or damage; however, seeing that most of the site is

located on a former (infilled) quarry, the likelihood of artefacts being

present within the site is extremely small.

Cultural Heritage Act, 2002

4.34. The Cultural Heritage Act provides overall protection to “...all movable or immovable

objects of artistic, architectural, historical, archaeological, ethnographic, palaeontological, and

geological importance...” and includes information and data relative to cultural heritage

in Malta. It also includes “...archaeological, palaeontological or geological sites and

deposits, landscapes, groups of buildings…which have an historical value”.

4.35. The Act also controls interventions that may be made on cultural property, all of

which require a permit from the Superintendent of Cultural Heritage and are subject

to tests, examinations or investigations. Furthermore, archaeological or

palaeontological excavations, or explorations on land, as well as in the territorial

waters, or in the contiguous zone of Malta, can only be made by the Superintendent,

12 The Antiquities (Protection) Act was repealed by the Cultural Heritage Act of 2002.

80

or with written permission of the Superintendent (Section 43(1)). Chance

discoveries of archaeological remains are also regulated by the Act: “Any person who,

even accidentally, discovers any object, site or building to which this Act applies in

accordance with article 3, shall immediately inform the Superintendent, keep the object

found in situ, and shall not for a period of six working days after informing the

Superintendent proceed with any work on the site where the object of cultural property is

discovered”. The details about rights and obligations by all parties in the eventuality of

an archaeological discovery are described in Sections 43(3), 43(4), 43(5), 43(6), and

43(7) of the Act.


o The impact of the Scheme on cultural heritage is discussed in Chapter 6

of the EPS. The impacts on recorded cultural heritage are considered to

be of no significance. There is the potential for impacts on unrecorded

archaeological artefacts during the remaining excavation to be carried out

on the site; the extent of this impact is uncertain, as it will depend on

whether artefacts are present, their importance, and the extent of any

loss or damage; however, seeing that most of the site is located on a

former (infilled) quarry, the likelihood of artefacts being present within the

site is extremely small.

4.36. The Act specifies that “No person shall make any interventions on such cultural property

or classes thereof without first having obtained a permit thereof from the Superintendence

(of Cultural Heritage)”. Applications are determined subject to the results of prior

investigation. There are restrictions on archaeological excavations is stated in

Section 43(1) whereby excavations or explorations can only be made by the

Superintendence of Cultural Heritage, or with written permission of the

Superintendence. Chance discoveries of archaeological remains are also regulated

and must be reported to the Superintendence.

Waste Management Plan for the Maltese Islands: A Resource

Management Approach 2014 - 2020

4.37. The new Waste Management Plan for the Maltese Islands: A Resource Management

Approach, 2014 – 2020 discusses legislation relevant to waste management in the

Maltese Islands, presents a detailed picture of the waste arisings, and includes a

strategy in relation to all waste streams, with the objective of moving waste

management in Malta up the waste hierarchy through increased prevention of waste,

re-use, recycling and recovery. The Plan provides the framework through which the

various requirements and targets contained in the European Waste Directives will be

implemented, in particular the Waste Framework Directive (2008/98/EC); Landfill

Directive (1999/31/EC); Packaging and Packaging Waste Directive (1994/62/EC); Waste

Electrical and Electronic Equipment Directive (WEEE) (2002/96/EC); Batteries and

Accumulators Directive (2006/66/EC); and End of Life Vehicles (2000/53/EC).

4.38. The Waste Management Plan defines waste management policy based on four

principles:

81

To reduce waste and to prevent waste occurring, with a view to achieving a

zero-waste society by 2050.

To manage waste in accordance with the waste hierarchy, whereby it is

recognised that waste should be prevented or reduced, and that what is

generated should be recovered by means of re-use, recycling or other

recovery options, in order to reduce waste going to landfill, and to use the

collection system to aid with achieving these goals.

To cause the least possible environmental impacts in the management of

waste.

To ensure that the polluter-pays principle is incorporated in all waste

management procedures.


o Waste management related to the construction and operation of the

scheme is discussed in Chapter 3. The Construction Management Plan

that will be prepared for the Scheme will also address waste management

issues during construction.

PLANNING POLICY

4.39. Planning policy relevant to the Scheme comprises policies embodied in the Strategic

plan for Environment and Development, 2015; the South Malta Local Plan 2006; the

Development Control Policy, Guidance and Standards 2015; and the Fuel Service Stations

Policy 2015.

Strategic Plan for Environment and Development

4.40. The Strategic Plan for the Environment and Development (SPED) outlines a National

Spatial Framework (NSF) for the Maltese Islands. The General Principles of this NSF

advocate a sequential approach to the use of land, as follows:

3.1. The sustainable use of land and sea resources depends on the efficient

use of available space. In preparing policies, plans and programmes

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.

82

This sequential approach is being adopted in order to ensure that land

take up in the Rural Area is considered as a last resort and where it is

essential for the achievement of sustainable development.

Furthermore,…

(iv) plans and policies prepared under the SPED shall seek the

conservation of all resources especially water in line with the approach

taken in the preparation of supplementary planning guidelines related

to firework factories, fuel stations and cemeteries.

4.41. In relation to guiding socio-economic development, Thematic Objective 1 of the

NSF advocates:

To manage the available potential space and environmental resources on

land and sea sustainably to ensure that socio-economic development needs

are met whilst protecting the environment and limiting land take up within

the Rural Area by:

1. Guiding the location of the bulk of new jobs and homes within the

Urban Area...

5. Achieving a wider mix of compatible uses on land and sea...

8. Facilitating the implementation of an integrated transport strategy...

10. Socio-economic development should ensure that rural areas are not

exploited by uses which are not legitimate or necessary.


o The Scheme site is located in the Rural Area (Outside Development

Zone). The whole of the site is currently used in connection with

quarrying and mineral processing activity, specifically for concrete block

manufacture and storage and recycled soft stone processing.

o As described in Chapter 3, the Scheme seeks the conservation of water

resources in line with the supplementary planning guidelines Fuel Service

Stations Policy 2015.

South Malta Local Plan

4.42. As mentioned, the Scheme Site is located in the Rural Area (Outside Development

Zone). For the most part, the Scheme Site lies within the Mqabba Local Council

administrative area; the southeast corner of the sites lies with the Kirkop Local

Council administrative area.

4.43. Figure 4.1 and Figure 4.2 are the Environmental Constraints Maps for Mqabba and

Kirkop, extracted from the South Malta Local Plan. These identify the Scheme site as

83

lying within the Aquifer Protection Zone (POLICY SMCO 08), specifically the

Water Protection Zone (see Figure 4.3, which is the Ground Water Resources

Protection Map, extracted from the Local Plan). A small portion of the site (on its

extreme southeast corner) is identified as lying within an Archaeologically Sensitive

Area (POLICY SMCO 04), described in Appendix C of the Local Plan as

comprising a ‘rock cut tomb’, listed as Class E.

4.44. POLICY SMCO 08 of the Local Plan addresses the protection of groundwater

resources and water quality in relation to the Water Protection Zone, as follows:

Development will only be permitted in accordance with the Level of

Protection Zones as set out below:

Water Protection Zone

Development permitted within the Water Protection Zone, as indicated on

Map 5 (see Figure 4.3), subject to the following criteria:

1. the connection to a public sewer system or sealed cesspool. Septic

tanks will be prohibited;

2. where the development involves or includes a road, adequate provision shall be made for the collection and storage of run-off water,

particularly in the immediate vicinity of water discharge points;

3. the provision of adequate collection areas for waste material;

4. the preservation of a sufficient rock layer above the ground water

table;

5. industrial development will not be permitted in the vicinity of public

boreholes, underground gallery systems of springs and pumping dolines

which contribute to the natural recharge of aquifers which are tapped

for drinking water purposes;

6. the prohibition of disposal of harmful effluents into the sewer system;

7. at agricultural establishments, the provision of a proper collection

system, adequate storage, containment of manure and animal slurry;

8. livestock breeding and rearing will not be permitted in doline areas or

in quarries; and

9. the provision of storage facilities for inorganic fertilisers on farming and

agriculture developments.


o The Aquifer Protection Zones and Water Protection Zones identified in

84

the Local Plan have since been have clarified as Groundwater Safeguard

Zones. The Scheme site does not lie within a designated Groundwater

Safeguard Zone. The nearest Groundwater Safeguard Zone to the site is

located approximately 198 m to the east (plan distance to nearest extent

of the 300 m Buffer Zone). Nevertheless, the Scheme has been designed

taking account of the need to ensure against the contamination of water,

including groundwater, as described in Chapter 3. The impacts on

groundwater quality arising from the Scheme are assessed in Chapter 5,

and an Environmental Risk Assessment is included as Volume 2 of this

EPS. The impact on groundwater quality is considered to be of minor

significance.

4.45. POLICY SMCO 04 of the Local Plan, which addresses Archaeologically Sensitive

Areas, advocates that:

On Class C, D and E sites, prior to any development occurring, the

developer must enter into a planning obligation that secures proper

investigation and documentation of these sites, following a monitored programme of archaeological excavation and recording by a competent

archaeologist. Development may be allowed on these types of sites subject

to modifications as required and as directed by MEPA in consultation with

the Museums Department or relevant Government agency, based on an

assessment of the archaeological significance of the findings.

In considering applications for development permission, MEPA in

collaboration with the Museum’s Department or relevant Government

agency will identify and advise on the level of protection appropriate to the

specific area or site in question and it will reserve the right to reclassify

areas and sites listed as Class E following further investigations.

Furthermore, the following buffer zones for Archaeological protection

classes A-E are established as follows:

...ii. a minimum of 50m for Class B-E features.


o Chapter 6 of the EPS identifies the archaeological and cultural heritage

features present in the area around the Scheme site. The Area of

Archaeological Sensitivity identified in the Local Plan is not identified; the

cultural heritage study did not identify any scheduled archaeological or

cultural heritage features in the vicinity of the Scheme site.

85

Figure 4.1: Mqabba Environmental Constraints Map (extracted from the South Malta Local Plan, and showing the Scheme site outlined in red)

87

Figure 4.2: Kirkop Environmental Constraints Map (extracted from the South Malta Local Plan, and showing the Scheme site outlined in red)

89

Figure 4.3: Ground Water Resources Protection Map (extracted from the South Malta Local Plan, and showing the Scheme site outlined in black)

91

Fuel Service Stations Policy

4.46. The Fuel Service Stations Policy identifies areas considered potentially suitable for

both new fuel service stations and fuel service stations that are being relocated from

elsewhere, in relation the locational and design requirements. Paragraph 3.2 of the

Policy identifies the following potentially suitable for new and relocated fuel service

stations:

a) Designated Industrial Areas

b) Small and Medium Enterprise Sites

c) Areas of Containment

d) Open Storage sites, as identified in the Open Storage Policy

e) Other areas designated for development in a subsidiary plan for:

(i) non-residential development; or

(ii) planning designation or existing uses which do not contemplate a

Social and Community facility or function;

and where in both cases MRA, CPD and TM deem it would be safe to

locate a fuel station.

f) Sites already occupied by fuel stations

g) Sites opposite to, or adjacent to designated industrial areas, as well as

sites opposite or adjacent to Areas of Containment.

4.47. Paragraph 4.1 of the Policy identifies the following additional sites for the location

of relocated fuel stations:

...sites lying outside areas designated for development in a subsidiary plan

legitimately committed for non-agricultural uses through planning

permission and disused quarries13.

13 The Policy does not infer that there should be a sequential approach to the identification of sites qualifying

under parts (a) to (g) of paragraph 3.2, or sites qualifying under paragraph 4.1. However, in discussions with

the Planning Authority, the interpretation of these paragraphs was qualified such that preference should first be

given to sites qualifying under parts (a) to (f) of paragraph 3.2, then to sites qualifying under part (g) of

paragraph 3.2, and then to sites qualifying under paragraph 4.1.

92

4.48. Furthermore, in relation to relocated fuel stations, Paragraph 4.2 of the Policy

advocates that:

...where a case can be made to consider sites other than indicated in

paragraph 4.1 above, this may be favourably considered especially in

circumstances where the community would benefit...and where the site

proposed for relocation does not give rise to unacceptable adverse environmental concerns.

4.49. In such cases, paragraph 4.3 of the Policy further advocates that:

In line with the spirit of the Structure Plan Policy SET1214, the proposal

should be justified on technical and / or planning grounds that there is no

feasible or suitable location within the areas identified for a RFS by this

policy...; and

The proposal should not be located on:

Good quality agricultural land as thus certified by the Department of Agriculture;

Areas of High Landscape Sensitivity as indicated in the respective

Subsidiary Plans;

Special Areas of Conservation (SAC’s) / Special Protection Areas (SPA’s);

A site within 50m from a listed or scheduled site. In cases where a

scheduled buffer zone is included, the distance shall be measured from

the edge of the buffer zone and shall be reduced to 20m ;

Garrigue or maquis;

A designated watercourse/valley-system;

A designated Area Prone to Flooding;

A site whose perimeter lies within the distance stipulated by law from a

fireworks factory complex;

14 The Structure Plan for the Maltese Islands 1992 has since been superseded by the Strategic Plan for the

Environment and Development, 2015, and in discussions with the Planning Authority the interpretation of this

statement has been qualified as “In line with the spirit of the Strategic Plan for the Environment and Development,

2015; Thematic Objective 1”.

93

A site lying on an escarpment, ridge edge or a comparatively steep

slope;

A site whose boundaries are closer than 15m or more than 500 m from the nearest Development Zone boundary.

c) The proposal should not negatively impinge on areas protected for

their scenic value or buildings or structures which, in the opinion of the

MEPA constitute ‘landmark buildings’ and whose context deserves

protection from visual intrusion; and...


o As mentioned, the Scheme site is currently used in connection with

quarrying activity, specifically for concrete block manufacture and storage

and recycled soft stone processing; there is a development permit relating

to the site for the sanctioning of “the siting of a mobile crusher (soft stone)

and blockwork producing machine in an existing quarry” (PA 05616/01,

approved in March 2004). The Scheme site qualifies as a site potentially

suitable for relocated fuel service stations in respect of paragraph 3.2

part (d) Open Storage sites, as identified in the Open Storage Policy. The

supplementary policy guidance document Areas for Open Storage, 2005

identifies “Land having a valid MEPA (Planning Authority) permit to

accommodate obnoxious industrial uses” as open storage sites.

4.50. Paragraph 3.1 also makes the following provisions which are applicable to new and

relocated fuel stations:

...shall have a footprint not exceeding three thousand (3,000) sqm and the height of any built structures shall in no case be higher than 7m.

...facilities which complement fuel stations in terms of economic

sustainability of the fuel stations would be encouraged, subject to other

relevant planning, environmental, transportation, civil protection, amenity or

resource protection constraints.


o The Scheme has regard to these policy objectives. Details of the Scheme

design are addressed in Chapter 3. It is the remit of the PA to assess the

compliance of the Scheme with the requirements of the Fuel Service

Stations Policy.

4.51. The following general provisions also apply to the siting and other aspects of both

new and relocated fuel service stations (Section 5):

Sites should not be located within 300m from a groundwater source that is

used for the abstraction of groundwater intended for human consumption

94

or intended for future use, such as boreholes, underground galleries of

pumping stations and spring valley systems.

Sites should be located at an appropriate setback from a Distributor or

Arterial Road. In all cases, the entrance to the fuel station should be visible

from the Distributor or Arterial Road and the access thereto should

preferably be already a schemed road.

Sites that may create a hazard (be it direct or indirect) to the traffic flow or

the surrounding environment will not be acceptable.

MEPA will not normally permit the location of a fuel service station within a

500 m distance of an existing fuel service station, in the same direction of

traffic. However, MEPA may favourably consider fuel stations on the

opposite side of the road from an existing fuel service station, if it can be

demonstrated that traffic on the opposite lane from the an existing fuel

service station cannot easily access it.


o The Scheme site is not located within 300 m of a groundwater source.

o The site is located on a distributor road; the access arrangements to the

Scheme have been informed by a Road Safety Audit conducted as part of

the Transport Impact Assessment (TIA.

o The closest existing fuel service stations to the Scheme site are located at

the edge of Iż-Żurrieq (2.2 km driving distance), at the Malta International

Airport (2.4 km driving distance) and Ħal Safi (2.9 km driving distance).

4.52. The following access provisions also apply to both new and relocated fuel service

stations (Section 6):

Access points to Fuel Stations should:

• Not be located on or close to a major junction

• Have separate entry and exit points separated by at least 20m

• Preferably operate using a one-way system

• Have a entry / exit minimum approach width of 6.0m

• Visibility splays kept free of any visual obstruction for motorists such as

advertising signs.

95


o As mentioned, the access arrangements to the Scheme have been

informed by a Road Safety Audit conducted as part of the TIA.

4.53. The following provisions also apply to both new and relocated fuel service stations

(Section 8):

In all cases, but especially in cases of fuel stations lying outside designated

areas, the scale, external materials and use of colour shall take into account

the context within which they are located and should fit rather than contrast

with the surrounding landscape.

Fuel storage tanks and services (including services leading to the site) should

be located underground unless safe construction and operation

considerations are deemed to dictate otherwise.

Any buildings or structures on sites located outside potential candidate sites

indicated as appropriate by this policy shall not exceed 7m in height. Any

services should be located inside the structure or the basement and where

this is not technically possible shall be adequately screened.

The canopy of the fuel station should be aesthetically pleasing and

compatible with its surroundings through appropriate design. It should be

designed in light weight materials and cover the least possible area. Such

canopies should not have an excessive amount of advertising on them. They

should also have light fittings in order to illuminate the station forecourt at

night (down lighting). However, such lighting should be designed in such a

manner so as to avoid direct light distracting motorists along the highway

and causing undue light pollution or disturbance to the surrounding

environment, especially in the countryside. Canopies should not protrude

onto the road or footpath.

The use of photovoltaic panels on the roof of the canopy shall be

encouraged. In cases where the fuel station is located outside potential

candidate sides indicated as appropriate by this policy, these shall be

mounted flat on the canopy so as to impart the least possible visual

signature.

The fuel station shall include a landscaping scheme which shall screen the

development as much as possible whilst enhancing its appearance. The

landscaping shall comply with MEPA’s Guidelines on Trees, Shrubs and

Plants for Planting & Landscaping in the Maltese Islands and shall also

include specifications for hard landscaping and lighting.

Any signage, including for the display of pricing, logos, etc. shall be included

in the application for development permission and shall be located in such a

way as to create the least possible visual intrusion into the surroundings. In

cases of fuel stations located ODZ, the use of illuminated panels shall be

96

kept to a minimum.


o The details of the Scheme design are addressed in Chapter 3.

CONCLUSION

4.54. This chapter reviewed the legislation and planning policies relevant to the Scheme. It has considered the relevant laws of Malta, Government Policies, and the policies of

the SPED and subsidiary planning documents, including the Fuel Service Stations Policy

2015, as well as EU legislation.

97

5. GEO-ENVIRONMENT

INTRODUCTION

5.1. This chapter describes the geology, geomorphology and hydrogeology within the

Scheme site and its surroundings. It also includes an assessment of the impacts and

risks posed by the Scheme on the geo-environment.

5.2. The key geo-environment issues arising from the Scheme are outlined below:

ASSESSMENT METHODOLOGY

5.3. The assessment methodology for the geo-environment study is described below.

The guidance on the protection of geology, geomorphology and hydrogeology is

outlined at the outset.

Standards and Policy Guidance

5.4. The principal sources of guidance for the impact assessment were the Strategic Plan

for the Environment and Development 2015, the Structure Plan for the Maltese Islands

199215, the South Malta Local Plan 2006, the Minerals Subject Plan 2002, and The Earth

Conservation Strategy 1991 (The British Nature Conservancy Council).

5.5. The European Union (EU) does not have any directive that protects the geo-

environment per se; however, Directive 92/43/EEC (Habitats Directive) seeks to

preserve and protect certain geology / geomorphologic features where these features

constitute important habitats. This Directive has been transposed into national

legislation (Legal Notice 311 of 2006 / S.L. 549.44).

5.6. Conservation profiles are intended to prevent future potential damage to sites. Since

no earth conservation model exists for the Maltese Islands, it has been suggested in

15 The Structure Plan for the Maltese Islands 1992 has been superseded by the Strategic Plan for the Environment

and Development 2015 (SPED); however, the SPED does not outline policy guidance relating to the geo-

environment in the level of detail that it was outlined in the Structure Plan. In the absence of specific policy

guidance, reference is still made to the relevant policies of the Structure Plan.

Key Issues:

Extraction of resources / geology features

Impact on ground water

Impact on surface water run-off

98

past studies (for example, Debono & Scerri, 199616 and Mallia et al., 199917) that until

such a model is formulated, models used in other countries can be adopted for local

use. The conservation model that has been used is that adopted by The Earth

Conservation Strategy of the Nature Conservancy Council (UK).

Area of Influence

5.7. The Area of Influence (A of I) for the geology study was taken to be the extent of the

Scheme site, having regard to the nature of the Scheme and to the extent of the

excavation works in particular. The A of I for the hydrology / hydrology study is

shown in Figure 5.1.

Geo-environment Methodology

5.8. The geo-environment study involved:

Identification and description of the geology, geomorphology and hydrogeology of

the A of I;

Identification, mapping and description of the structural features present, outcrop

formations, members, or bed sub-divisions, including their palaeontologic content;

Identification and description of aquifers, water courses, drainage patterns;

surface run-off; and springs and wells (as identified); and

Identification of features protected by legislation, or which warrant such

protection, and their appropriate level of protection, as necessary.

5.9. The study resulted in the preparation of the following:

Geological Map;

Hydrology Map;

Report of the quality of the stone material to be excavated and its potential

reuse. Two boreholes were also drilled as part of the baseline survey; the

location of these boreholes is shown in Figure 5.2.

16 Debono, G. and Scerri, S., 1996. North Harbours Local Plan Geology Survey Report. Prepared by Malta

University Services for the Planning Authority, Floriana, Malta; 72 pp. + 210 data cards + 15 figures + 20 plates. 17 Mallia, A., Briguglio, M., Ellul, A.E., and Formosa, S., 1999. Population, Tourism, Land-Use and Non-

Renewable Resources in the State of the Environment Report for Malta 1998, commissioned by the

Environment Protection Department, Government of Malta, Malta Council for Science and Technology, Malta.

99

Figure 5.1: Hydrology / Hydrogeology Area of Influence

101

Figure 5.2: Geo-technical investigation: Location of Boreholes

103

BASELINE: GEOLOGY

Stratigraphy

5.10. The five late-tertiary formations exposed on the Maltese Islands are:

Upper Coralline Limestone (youngest);

Greensand;

Blue Clay;

Globigerina Limestone; and

Lower Coralline Limestone (oldest).

5.11. In addition to these formations, Quaternary continental deposits are also known to

occur sporadically on the Maltese Islands. An unconformity and an erosional surface

separate this unit from the underlying marine sedimentary succession.

5.12. In a geology survey undertaken for the EPS for a former development permit

application on the same site (PA 05616/0118), examination of the formations was carried out at the quarry at “Il-Bur Ta’ Dingli”, which adjoins and is lower than the

Scheme site. Of the five rock formations listed above, the only unit exposed within

the A of I is the Lower Globigerina Limestone Member (Franka) of the Globigerina

Limestone Formation (see Figure 5.3). The base of the unit has not been reached in

the quarry at Il-Bur Ta’ Dingli as it lies some 40 m below ground level (see Figure

5.4), but can be observed at Wied Ħanżira, about 1.5 km to the west, where the Lower Coralline Limestone is exposed. Lower Coralline Limestone can be best

observed in the gorge of the watercourses in this valley.

5.13. The Middle and Upper Globigerina Members of the formation are not preserved in

the area. The nearest good exposure of these two units is at Laferla Cross about 5

km west of the Scheme Site.

18 Adi Associates Environmental Consultants Ltd, 2003, Environmental Planning Statement for PA5616/01 To

Sanction a Softstone Crusher and a Concrete Block Making Machine at Triq il-Belt Valletta, Mqabba. San

Gwann.

105

Figure 5.3: Geological Map of the Area of Influence (OED, 1993)

107

Figure 5.4: Geological cross section

Lithology of the Lower Globigerina Limestone member

5.14. This member is mostly composed of several beds sometimes bounded by laterally

discontinuous phosphate pebble or conglomerate beds.

5.15. The only bed identified in the quarry at Il-Bur Ta’ Dingli is the Globigerinid bed,

which basically makes up the whole Lower Globigerina Limestone member, as the

other beds are usually less than 1 m thick. In the area of the Scheme site, it is

estimated to be 40 m thick.

5.16. This bed is composed of soft cream to yellow, intensely bioturbated, medium to fine

calcarenite. The microfaunal content is dominated by benthonic and planktonic

microforaminifera that account for its lighter colour and can be defined as a

globigerinid wackestone. Macrofauna are represented by pectinid bivalves, echinoids

and vertebrate debris. The most common trace fossils are represented by

Thalassinoides. In complete sections, this unit is terminated by an erosional surface

representing a hardground (Felix, 1973), termed the terminal Lower Globigerina

Hard Ground (Pedley, 1976), and is succeeded by a flat-topped phosphate

conglomerate bed of the Middle Globigerina Member.

5.17. In the building industry the Lower Globigerina Limestone can be divided into two

principal beds:

Franka stone at the top

Soll at the base

5.18. Franka stone comprises an upper massive light white or yellow to cream, fine to

medium grained, soft porous limestone. Judging by the depths of the quarries within

the A of I, this is estimated to be about 15 m to 20 m thick.

108

5.19. It is underlain by a thickly-bedded, cream clayey limestone of similar thickness. The

latter is locally known as Soll and unlike the upper bed is characterised by evident

burrows, thick to very thick bedding with thick patches or entire beds of bluish grey,

clayey limestone that weathers by flaking.

5.20. The region around Ħal Kirkop, L-Imqabba and il-Qrendi contains some of the best quality Franka stone resource in the Maltese Islands and this explains the prevalence

of a high density of franka stone quarries in the region.

Structural Geology

5.21. The Maltese Islands have two main faulting systems. The Magħlaq Fault runs along

the northwest – southeast coast and has resulted in the northeast tilt of the Maltese

Islands. The Great Fault runs from Pembroke to Fomm ir-Riħ, dividing the island of

Malta into two main blocks. The north of the Great Fault is characterised by horst

and grabens (that is, ridges and rifts), whilst to the south is flat land, with the

exception of the Rabat - Dingli Uplands. In the southern part of Malta, the Upper

Coralline Limestone and Greensands formations have been eroded away and what

remain are the Globigerina Limestone and the Lower Coralline Limestone

formations. The predominant rock type is the Lower Globigerina Limestone

Member.

5.22. The Mqabba and Qrendi area appears to lie in a graben, possibly explaining the

thickening of the franka stone resource bounded by the Siġġiewi and Wied iż-Żurrieq

faults both striking NE-SW.

5.23. No major fault traverses the Scheme site. The nearest fault is the Siġġiewi Fault that passes some 1.2 km to the west of the site. The strata dip at about 5° to the

northeast.

Quality of the Stone Material

5.24. The geo-technical investigation involved the drilling of two boreholes within the

Scheme site (see Figure 5.2 above). The cores extracted consisted entirely of

Lower Globigerina Limestone; some 10 - 15 cm of reinforced concrete was present

at the top of the cores extracted from the boreholes. The Lower Globigerina

Limestone extracted from BH1 had some ‘rust’ stains. The tests conducted showed

that the rock has a low fracture frequency and over all is of good quality. Unconfined

Compressive Strength results vary from 13.6 to 19.7 MPa, which is normal for this

type of rock. With regards to BH2, the first 70 cm were drilled with open hole: the

first 10 cm consisted of concrete, 30 cm was fill, and the rest was rock.

Soils

5.25. Maltese soils reflect the young age of the Maltese rocks, which has resulted in the

close similarity of the soil with the parent material.

5.26. Lang (1960) used the Kubiena classification system to categorise the different soils of

109

the Maltese Islands. He identified four main categories of soils, namely, the

Carbonate Raw Soils, the Terra Soils, the Xerorendzinas, and the Soil Complexes

and Rdum Sequence.

5.27. The A of I is dominated by Tas-Siġra series (Terra soil) and Tad-Dawl complex (soil

complex). Tas-Siġra series is characterised by its typical flateness, complete lack of lapis or out rock surfaces, and almost complete lack of terracing. Tad-Dawl complex is similar

to the Xagħra series, which is a very fertile Terra soil found in karstic environments, but which contains more minerals and lacks the profile characteristics of the

Xagħra series.

BASELINE: GEOMORPHOLOGY

Geomorphic Features

5.28. The Scheme site is located in the flat land that characterises the central and southern

areas of Malta (south of the Great Fault). There are no traces of limestone

formations, and other formations, above the surface Lower Globigerina Limestone,

since the overlying layers have been eroded off.

5.29. The A of I is also affected by the Magħlaq fault, which runs from the northwest to the southeast. As mentioned, this faulting system has also contributed to Malta’s

northeast tilt.

5.30. There are no specific geomorphic features within the Scheme site or in the A of I.

The A of I is characterised by extensive anthropogenic activity related to mineral

extraction from quarries. The closest geomorphic features are Wied Silani (1.5 km

from the Scheme site), Wied Garnaw (2 km from the Scheme site), and the Maqluba

subsidence solution structure (2.5 km from the Scheme site).

BASELINE: HYDROGEOLOGY

5.31. As mentioned, the exposed geological formation at the Scheme site is the Lower

Globigerina Limestone Member of the Globigerina Limestone Formation. The Lower

Globigerina formation is the most widely exposed formation in the central and

southern areas of Malta. Globigerina Limestone is a fine grained limestone and, as

such, presents an almost impermeable layer and is therefore a barrier to infiltration.

Nevertheless, varying degrees of fissuring in all directions through the rock stratum

gives rise to a wide range of permeability. The A of I does not manifest tectonic

faults, with the closest fault lines running through iż-Żurrieq, approximately 1.2 km to

the southeast, and 1.6 km to the northwest at Ħal Farruġ.

Surface Hydrology

5.32. The Scheme site lies adjacent to a road - Triq il-Belt Valletta. The Scheme will lie at a

slightly higher elevation than the road, therefore, potentially-polluted storm water on

Triq il-Belt Valletta will not flow into the site. On a rainy day during the survey, it

was noted that rainwater collected in small puddles along Triq il-Belt Valletta. During

110

the survey, it was also observed that there is no stormwater infrastructure along Triq

il-Belt Valletta, which likely accounts for this. Excess water is likely to run off into

low-lying fields and into the quarries bordering the road. There are no valleys in the

area through which excess runoff could flow. This means that any contaminated

surface runoff that is generated at or around the site is unlikely to travel far, and that

the polluting effect will be geographically contained.

Runoff Generated Within the Scheme Site

5.33. Runoff within the Scheme site when the Scheme comes into operation will arise

from:

The uncovered forecourt; and

Roofs and canopies of the buildings and structures.

5.34. The roof and canopy areas will cumulatively measure approximately 1,200 m2. Runoff

from these surfaces will be channelled into a 720 m3 capacity reservoir and the water

so collected is envisaged to be used in the car wash area. With an annual rainfall of

553 mm and using a run-off coefficient of 0.9, the amount of rainwater that is likely to

be collected annually amounts to 597 m3, all of which can be contained in the

reservoir, leaving a 15% contingency. This reservoir will only overflow if the supply

exceeds demand, year after year, in which case the reservoir will overflow into Triq

il-Belt Valletta.

5.35. It is envisaged that surface runoff from the forecourt will be diverted to a Class 1 fuel

retention separator (as described in Chapter 3 of the EPS). The remaining areas

will drain to Triq il-Belt Valletta..

5.36. The car wash area will be contained within a system of peripheral surface drainage

channels, designed to collect and divert the wash water into a recycled water

reservoir (capacity of 44 m3) having first been filtered through a Class I oil / water

separator. It is projected that 60% of the water used in the car wash operation will

be recovered and recycled.

Mean Sea Level Aquifer

5.37. The Scheme site overlies the Mean Sea Level Aquifer, which is located at sea level

and exists in the Globigerina and Lower Coralline Limestone Formations that also

form the geological strata at the site. The Scheme site lies approximately 82 m above

the Mean Sea Level Aquifer of Malta.

5.38. The main recharge area to this Aquifer is the extensive Globigerina Limestone

Formation outcropping to the south of the Victoria Lines, of which the Scheme site

forms part. The first rains during the winter months serve to saturate the soil water

deficit; prolonged rainfall results in the generation of runoff and infiltration to the

aquifer. Water balance estimates for the Maltese Islands indicate ground water

recharge as being 20-25% of rainfall. Runoff and evapo-transpiration losses account

for 5% and 70% of rainfall, respectively. On a regional level, these figures may vary,

111

depending on topography, soil cover, underlying geology, slope and other factors.

5.39. The Scheme site is located within the Groundwater Protection Zone, as established

by the Malta Resources Authority; however, it lies outside the 300 m Groundwater

Safeguard Zone established by the former Malta Environment and Planning Authority

(MEPA).

5.40. There are four private boreholes and two Water Services Corporation boreholes

located within the A of I (see Figure 5.5).

113

Figure 5.5: Hydrology map showing features of interest within the Area of Influence

114

ASSESSMENT OF IMPACTS

Impact Significance

5.41. The following criteria were used to assess the significance of the negative impacts of

the Scheme on the geo-environment:

Not significant:

o Little or no change to the geological, geomorphological and

hydrogeological regime.

Minor significance:

o Changes to the geological, geomorphological and hydrogeological regime

that may affect neighbouring properties but which may be offset by

mitigation measures.

Major significance:

o Changes to the geological, geomorphological and hydrogeological regime

that may affect neighbouring properties and which may not be offset by

mitigation measures (if negative) or may be enhanced by mitigation

measures (if positive).

Prediction and Significance of Impacts

Extraction of Resources

5.42. As discussed above, the two cores that were drilled within the Scheme site show

that part of the site is partly infilled. Old survey sheets show that part of the site is a

former quarry that has been infilled with inert material (this was also confirmed by

the Applicant). The predicted impact of the Scheme on the underlying geology is

therefore considered to be of minor to major negative significance, since it involves

some extraction of mineral resources and removal of inert dumped material. The

extent of the infilling is unknown hence the impact being judged minor to major. It is

envisaged that approximately 2,353 m3of material will be excavated from the site.

5.43. The impact of water consumption from the car wash is considered to be of minor

significance due to the fact that 60% of the water will be recycled.

Change in quality of aquifer

5.44. In terms of quality of the aquifer, the predicted impact of the Scheme is considered

to be of minor significance, subject to the appropriate mitigation measures being in

place. Given the nature of the Scheme, there is a potential risk of contamination of

the aquifer; however, the mitigation measures included in the Scheme would avoid

this risk. The underground fuel storage tanks will have double skins and a leak

detection system; they will also be installed within special pits that have been

115

rendered impermeable to avoid accidental leakage. Above ground, the forecourt will

also be rendered impermeable to avoid losses to the aquifer, and oil-water

separators will also be installed, as described in Chapter 3 of the EPS.

Change in quality of run-off

5.45. Without mitigation, spillage of large quantities of fuel above ground would see the

run-off flowing downstream. However the mitigation measures designed into the Scheme will reduce this risk substantially. As mentioned, the surface of the site will

be impermeable and any spill will be directed towards the oil-water interceptors.

Hence, the predicted impact of the Scheme in relation to the quality of surface water

run-off is considered to be minor, subject to the appropriate mitigation measures

being in place.

MITIGATION

5.46. Mitigation measures to protect hydrogeological resources are:

Construction of the Scheme in accordance with all the appropriate industry

standards for fuel service stations, including the installation of the underground

fuel storage tanks with double skins, leak detection systems and surrounded by

impermeable bunding, and the installation of an impermeable forecourt and oil-

water interceptors. The mitigation measures are discussed in Chapter 3 and the

risks of the operation are described in Volume 2 of the EPS.

Preparation of a Construction Management Plan that also addresses issues of

groundwater and surface water pollution arising from the construction of the

Scheme; and

Adoption of operational management practices designed to monitor the performance of pollution control measures, including leak detection systems for

the tanks, pipework and dispensers, regular emptying of the oil-water interceptor

chambers, and regular inspections of the surface water drainage system

(particularly after storms) to avoid contaminated surface water run-off entering

the watercourse.

RESIDUAL IMPACTS

5.47. With the mitigation measures in place, the impact on the aquifer and on surface

water is considered to be of minor significance. Residual impacts will remain as being

of minor to major negative significance, depending on the extent of mineral resource

to be extracted.

117

Table 5.1: Summary of Impacts on the Geo-environment

Predicted

Impact

Beneficial

/Adverse

Nature, Scale and Type of Impact Probability of

Impact

Occurring

(Likely/

Unlikely/

Remote/

Uncertain)

Significance

of Impact

(Major/

Moderate/

Minor/Not

Significant)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major/

Moderate/

Minor/Not

Significant)

Constr’

n

/Oper’n

Extent

of

Impact

(Nat/

Local

/Site)

Direct/

Indirect

S’term

/

L’term

Perm/

Temp

Revers/

Irrevers

Mineral

resources /

geological

features

Adverse Constr’n Local Direct Long-

term Perm Irrevers Likely

Minor to

major

significance

Re-use of

excavated material

Minor to

major

significance

Water

resources Adverse Oper’n Local Direct

Long-


Minor

significance

Collection of

water from the

canopy for re-use;

Re-cycling of water

used in the car

wash facilities

Minor

significance

Change in

the quality

of ground

water

Adverse Constr’n

/ Oper’n Local Indirect

Short-

term /

Long-

term

Perm Irrevers Likely Minor

significance

Construction in

accordance with

industry standards

for pollution

avoidance

CMP

Operational

management

practices to

monitor

performance of

pollution control

measures.

Minor

significance

Change in

the surface

water run-

off patterns



Minor

significance

Minor

significance

119

6. CULTURAL HERITAGE

6.1. This chapter describes the cultural heritage within the Scheme site and the wider

Area of Influence (A of I). The potential key issues with regards to cultural heritage

are:

Key Issues:

Loss or damage to features of cultural heritage significance

Alteration or degradation of the quality of the setting of the features

of cultural heritage significance as a result of the Scheme

Terms of Reference

6.2. The Terms of Reference provided by the Environment and Resources Authority

(ERA) are provided in Technical Appendix 1: Terms of Reference and Method

Statements.


Objectives of the Assessment

6.3. The objectives of the cultural heritage desktop study were to:

Identify, document, and present information on the known archaeological and

cultural heritage features within the A of I;

Identify the potential for additional archaeological remains within the A of I, from

desk study research;

Assess the cultural heritage significance of the A of I;

Describe and assess the impact of the Scheme on the archaeological and cultural

heritage features within the A of I;

Describe any mitigation measures designed to minimise any adverse impacts on

the archaeological and cultural heritage features within the A of I; and

Describe appropriate monitoring measures to safeguard archaeological and

cultural heritage features during the construction and operation of the Scheme.

120

Standards and Policy Guidance

National Policy and Legislation

6.4. Guidance on the protection of cultural heritage in the context of planning was taken

from the Cultural Heritage Act 2002, and the urban conservation and archaeology

policies of the former Structure Plan for the Maltese Islands 199219.

Cultural Heritage Act, 2002

6.5. This Act provides overall protection to all “movable or immovable objects of artistic,

architectural, historical, archaeological, ethnographic, palaeontological and geological

importance and includes information or data relative to cultural heritage pertaining to Malta

or to any other country (section 2)”. It also includes “archaeological, palaeontological or

geological sites and deposits, landscapes, groups of buildings…which have an historical

value”. In Section 3, it also specifies that “For the purposes of this Act, an object shall not

be deemed to form part of the cultural heritage unless it has existed in Malta, including the

territorial waters thereof, or in any other country, for fifty years, or unless it is an object of

cultural, artistic, historical, ethnographic, scientific or industrial value, even if contemporary,

that is worth preserving”.

6.6. Furthermore, “No person shall make any interventions on such cultural property or classes

thereof without first having obtained a permit therefore from the Superintendent” (Section

44.3). Applications are determined subject to the results of prior investigation:

“Before determining an application under sub-article (3) hereof the Superintendent may

require such information including the results of such tests, examinations or inspection by

such persons accredited under this Act for the purpose as may be required by the

Superintendent” (Section 44.4).

6.7. The restrictions on archaeological excavations are stated in Section 43(1), whereby

“Archaeological or palaeontological excavations or explorations on land as well as in the

territorial waters or in the contiguous zone of Malta can only be made by the

Superintendent, or with written permission of the Superintendent”. Chance discoveries of

archaeological remains are also regulated by Section 43(2): “Any person who, even

accidentally, discovers any object, site or building to which this Act applies in accordance with

article 3, shall immediately inform the Superintendent, keep the object found in situ, and

shall not for a period of six working days after informing the Superintendent proceed with

any work on the site where the object of cultural property is discovered”. The details

regarding rights and obligations by all parties in the eventuality of an archaeological

discovery are described in Sections 43(3), 43(4), 43(5), 43(6), and 43(7).

19 The Structure Plan for the Maltese Islands 1992 has been superseded by the Strategic Plan for the Environment

and Development 2015 (SPED); however, the SPED does not outline policy guidance for cultural heritage in the

level of detail that it was outlined in the Structure Plan. In the absence of specific policy guidance, and

specifically in respect of the classification of cultural heritage features, reference is still made to the relevant

policies of the Structure Plan.

121

Structure Plan Policies

6.8. The Structure Plan for the Maltese Islands, 1992 contains policies relating to the

classification of archaeological features. The classification system is outlined in

POLICY ARC 2 and POLICY ARC 3; POLICY ARC 6 and POLICY ARC 7

provide further guidance on the classification system.

6.9. POLICY ARC 2 provides for a four-tier classification system, with Class A

representing the most important sites / features, where development that is

considered would adversely affect the natural setting of the site / feature will not be

allowed. The policy prescribes a development-free buffer zone of at least 100 m

around the periphery of a Class A site / feature. Class B sites / features are regarded

as very important, to be preserved at all costs, where adequate measures must be

taken to preclude any damage from immediate development. In the case of Class C

sites / features, every effort must be made for preservation, but these features may

be covered up after proper investigation, documentation and cataloguing, with

provision for subsequent access being provided. Class D features are those of which there are numerous examples; these features may be covered up or destroyed after

recording. Subsequent to the publication of the Structure Plan, a fifth category –

Class E – was introduced (through the Local Plans) to cater for those sites that were

recorded in the past but have since gone missing and hence would require further

investigation to determine their continued existence.

6.10. Permissible effects of development on archaeological remains are addressed in

POLICY ARC 3: “… development affecting ancient monuments and important

archaeological areas and sites, including areas and sites having such potential, will normally

be refused if there is an overriding case for preservation. Where there is no overriding case

for preservation, development of such sites will not normally be permitted until adequate opportunities have been provided for the recording and, where desirable, the excavation of

such sites”.

6.11. As provided by POLICY ARC 7, any catalogued archaeological feature may be

included in the National Protective Inventory (NPI), for which protection is provided

by means of POLICY ARC 6.

6.12. The Structure Plan is weak on the protection of individual archaeological artefacts;

the principal thrust of the Structure Plan is to protect sites, buildings and

monuments. Artefacts are afforded better protection under the Cultural Heritage Act.

Policy Importance of Archaeological Features

6.13. The classification of archaeological features according to their policy importance is

guided by legislation, including the Cultural Heritage Act 2002, the Environment

Protection Act 2016, the Structure Plan policies (referred to above), and Government

and / or Legal Notices regarding specific archaeological and cultural heritage features.

Each of these assigns its own degree of importance and remedies. In applying these

122

to the EIA process three categories are used:

Features of International Importance (major importance);

Features of National Importance (major importance); and

Features of Local Importance (minor importance).

6.14. Table 6.1 summarises the cultural significance of different features.

Table 6.1: Protection Ratings and Cultural Significance

Cultural Significance Class Grade Protection

Major

National Importance A 1 Conserve, plus 100 m buffer zone

Medium

Local Importance B 2 Conserve

Minor C 3 Record / may be covered

None D - May be covered, destroyed, or recycled

Uncertain E - Further investigation is required

6.15. The laws, policies, classification systems, etc., pertaining to the conservation of

buildings or other structures have been assigned to these categories of policy

importance as follows:

Features of International Importance

6.16. Cultural features of international importance are those:

Protected specifically by legislation;

Qualifying as Class A features under Structure Plan POLICY ARC 2; or

Similarly identified by the Minister responsible for cultural heritage or the

Superintendence of Cultural Heritage.

Features of National Importance

6.17. Features of international importance would also be of national importance.

Additionally, cultural features of national importance are those:

Qualifying as Class B features under Structure Plan POLICY ARC 2; or



123

Features of Local Importance

6.18. Cultural features of local importance are those:

Qualifying as Class C or Class D features under Structure Plan POLICY ARC 2;

or



Remaining Features

6.19. All catalogued cultural heritage features may be included in the NPI, and those not

already protected are afforded protection under Structure Plan POLICY ARC 6,

which provides that all sites / features listed in the NPI will be protected in

accordance with the Environment and Development Planning Act (now the

Environment Protection Act and the Development Planning Act) powers and by

reference to the classification ratings outlined in Structure Plan POLICY ARC 2.

Area of Influence

6.20. The A of I for the cultural heritage study is illustrated in Figure 6.1.

Methodology

6.21. The methodology for the cultural heritage desktop study consisted of a research-

based baseline survey of the cultural heritage assets (artistic, architectural, historical,

archaeological, and ethnographic assets) and an evaluation of their importance.

Literature Search

6.22. The literature search included primary and secondary sources: analysis of

cartographic and photographic material; analysis of secondary written sources; and

analysis of conservation legislation.

Mapping

6.23. The archaeological, rural, vernacular, historical, and cultural heritage features within

the A of I were mapped, primarily through consultation of documentary sources.

Cataloguing

6.24. The relevant information for each feature was recorded on cards and using digital

media, in the format currently used by ERA. Each feature was individually identified

using a consecutive numbered reference; the information for each feature includes:

A short written description of the feature;

Co-ordinates recorded up to 5 digits for each Eastings and Northings, based on

the local UTM grid reference;

124

Locality and address;

Site map (Scale 1:2500);

Colour photograph(s);

Sketch of the feature showing the most significant details (wherever possible);

Conservation importance of the site / feature (proposed grading in accordance

with Structure Plan policies);

Existing and / or proposed legislative and physical protection;

Current and proposed use / enhancement;

References; and

Name of cataloguer and date of compilation.

Evaluation

6.25. An archaeological assessment and significance of the archaeological, rural, vernacular, historical, and cultural heritage features was undertaken from the desktop study. The

conservation importance of the identified sites / features has been identified with

reference to relevant legislation standards, guidance and practices as described above.

125

Figure 6.1: Area of Influence for Cultural Heritage Study

127

DESKTOP SURVEY RESULTS

6.26. The A of I lies within the L-Imqabba and Ħal Kirkop Local Council administrative areas. The Scheme site is located on the outskirts of the locality of L-Imqabba, which

has in the region of 3,223 inhabitants20. The environs of the village of L-Imqabba are

dominated by quarrying activities, related industrial uses, and agriculture.

Prehistory

6.27. There have been a number of pre-historic archaeological finds at L-Imqabba.

Remains of extinct animals were discovered at Ta’ Kandja and at Tax-Xantin to the

northwest and north of L-Imqabba settlement respectively. Quaternary deposits

were discovered within a cave within one of the quarries at Bur Mogħoż. The site included animal remains and Neolithic inhumations. Other artefacts found included

ceramics, flints, and shell ornaments. The area is also known to have included

megaliths.

Classical Antiquity

6.28. L-Imqabba and its surrounding area are also rich in evidence of human activity during

the classical period. A number of destroyed or filled in rock-tombs where recorded

at Cuttalf Gandolf, which falls within the A of I. Excavations in 1911 uncovered

Punic-type pottery. Glass fragments and bronze objects also found during the

excavation dated the tombs to around the second or third century BC.

6.29. One of the most prominent features from the Classical period is the Tal-Wilga

Punico-Roman tower, located to the north-west of L-Imqabba. The round tower

was constructed using large ashlar blocks. Only the eastern side of the tower has

survived, and it is currently in a good condition. The tower was probably used up to

the third century AD. The tower was discovered by Dr Ashby in 1908, who

considered it be from the prehistoric period. The area around the tower was

excavated in 1910, and the pottery uncovered during this excavation was of the Punic

type.

6.30. The remains of a Roman villa at Tad-Dawl21 were excavated and recorded in 1910;

however, the remains were subsequently destroyed. The site included two cisterns

and olive pressing instruments.

6.31. The Tal-Mintna Catacomb complex is located within the village of L-Imqabba. The

complex is richly decorated and includes an agape table.

20 Census of Population and Housing 2011: Final Report. ‐ Valletta: National Statistics Office, 2014, p. 3 21 Bonanno, A. (1977) ‘Distribution of Villas and some of the Maltese Economy in the Roman Period’ in Journal

of the Faculty of Arts 6(4) : 73-81

128

Medieval and Early Modern Periods

6.32. The village of L-Imqabba has a number of churches, chapels, and niches that date

from the medieval period. The oldest church in L-Imqabba is dedicated to St Basil

and it has been extended multiple times. The chapel was already in place in the late

fifteenth century and has a Norman style façade. An adjacent chapel is dedicated to

St Michael. Both chapels are Grade 1 scheduled buildings.

6.33. The village also has eighteenth century features, a hospital, which was used during the

outbreak of plague, and the Vincenti Tower, which forms part of Ta’ Torri Spero

country residence complex. This country residence complex is currently rented out

as a short-let holiday accommodation.

6.34. The area surrounding the village of L-Imqabba includes rural vernacular features that

likely also date from the medieval and early modern periods. These features include

rubble walls, agricultural rooms, and farmhouses.

Cultural Heritage Features

6.35. Figure 6.2 shows the location of the identified cultural heritage features within the

A of I; Table 6.2 lists these features. A detailed description of all the identified

cultural heritage features is given in Technical Appendix 3: Cultural Heritage

Baseline Study.

Table 6.2: Cultural Heritage Features

Feature Ref. No. Feature Class / Grade / Level

(as relevant)

KKP001 Rural room Merits Grade 3

KKP002 Underground rural room (?) Unclear

KKP003 Farmhouse Merits Grade 2

MQB001 Tal-Kalonku Farmhouse Merits Grade 2

MQB002 Rural structure Merits Grade 3

MQB003 Farmhouse Merits Grade 2

MQB004 Rural room n/a

MQB005 Rural building n/a


MQB007 Rural building Merits Grade 3


MQB009 Residence with modern bas-relief n/a

MQB010 Rubble mound n/a

MQB011 Commemorative plaque Merits Grade 2

KKPMQB001 Old road alignment n/a

KKPMQB002 Rubble walls n/a

129

Figure 6.2: Cultural Heritage Features within the Area of Influence

131

6.36. There are no scheduled heritage features within the A of I. However, the South

Malta Local Plan (SMLP) identifies a Grade E Archaeological Sensitive Area (ASA)

close to the Scheme site. In this area, a rock-cut tomb located in the corner of a

built marble / stone work plant had been identified but its exact location has gone

missing. The identified buffer zone to the feature extends to the southeast corner of

the Scheme site (see Figure 6.2).

6.37. The A of I includes a number of buildings / structures / features that are considered

to be important for their cultural heritage significance. The closest of these features

to the Scheme site is a rural room, where newer structures have been built adjoining

and surrounding the original structure (see Feature KKP001 in Figure 6.3).

Figure 6.3: Rural Room close to the Scheme Site (KKP001)

6.38. The A of I is rich in cultural features related to agricultural activity, including

farmhouses, rural rooms, and rubble walls. These features vary in age and state of

repair.

6.39. One of the most interesting features is a farmhouse (MQB003), which could have

possibly been built for defensive purposes due to its towering dimensions and

features (see Figure 6.4). This structure, located approximately 160 m to the

northwest of the Scheme site, merits consideration as a Grade 2 scheduled building.

6.40. Some of the rubble walls are built with traditionally-sized rubble stones; others show

frequent interventions with the introduction of modern blocks (see Figure 6.6).

132

Figure 6.4: Farmhouse (MQB003)

133

Figure 6.5: Another two farmhouses within the Area of Influence - KKP003

(top) and MQB007 (bottom)

134

Figure 6.6: Rubble walls (KKPMQB002)

135

ASSESSMENT OF IMPACTS

Determining Impact Significance

6.41. The significance of the impacts of the Scheme on cultural heritage is dependent upon

the importance assigned to each of the cultural heritage features, either through

legislation or by the Consultants, and the degree of disturbance or damage likely to

arise from the construction and / or the operation of the Scheme.

6.42. A summary of the significance of the impact was judged in terms of whether the

impact is considered to be not significant, of minor significance, or of major

significance. The assessment criteria applicable in relation to determining the

significance levels are described in Table 6.3.

Table 6.3: Impact Significance Criteria

Potential Damage or

Destruction to Features

Class or Grade of Cultural Heritage Feature

Major

Class /

Grade A / 1

Medium

Class /

Grade B / 2

Minor

Class /

Grade C / 3

None / Not

graded

No material change to the cultural

heritage feature

Not

significant

Not

significant

Not

significant

Not

significant

Small scale changes to the cultural

heritage feature (i.e. alterations),

which are unlikely to affect the

integrity of the feature

Major Minor Minor Not

significant

Loss of, or disturbance to, the

cultural heritage feature which is

likely to affect the integrity of the

feature

Major Major Minor Not

significant

Prediction and Significance of Impacts

6.43. There are no identified cultural heritage features within the Scheme site. The site is a

former softstone quarry that has been infilled and concreted over. Notwithstanding,

there is the potential for impacts on cultural heritage arising from possible loss of, or

damage to, unrecorded archaeological artefacts during the excavation. The extent of

this impact is uncertain, as it will depend on whether artefacts are present, their

importance, and the extent of any loss or damage. However, any potential impact

would be ascertained through the presence of an archaeology monitor during

excavation works and the necessary mitigation / documentation taken.

6.44. The artefacts in close proximity to the site include a rural building (Feature MQB005

in Figure 6.2) to the west of the Scheme site and a rural room (feature KKP001 in

Figure 6.2) to the east of the site. These rooms are remnants of a former rural

activity in the area but since the opening of the quarries and the subsequent open

storage / industrial use of the area, their setting has been significantly altered and they

136

remain as solitary reminders of the former use of the area. The introduction of a

modern fuel station, complete with industrial canopy, signs, lights, etc, while removing

the dusty activity from the site, is likely to further alter the setting of these rooms

and of the general area.

6.45. It is also unlikely that there will be any impact on the structural integrity of these

structures arising from vibrations during the construction of the Scheme. British Standard (BS) 7385: 1993 - Part 222 outlines limit values for transient vibration, above

which cosmetic damage23 to buildings / structures would occur24. Also considering

vibration monitoring data for excavations collected by MEPA in Malta25, the level of

vibration is likely to be lower than the trigger value for cosmetic damage to buildings

/ structures prescribed by the relevant standards.

6.46. There is also unlikely to be any significant impact from the operation of the Scheme

on these structures, given the nature and scale of the development and the distance

between them.

6.47. Although there might be a rock-cut tomb in the vicinity of the site, the Scheme

boundary is just outside the buffer zone of the Grade E tomb. Given the limited

excavation and also noting that the Scheme is outside the buffer zone then there are

unlikely to be impacts on this feature from the excavation.

6.48. The route to be used for heavy vehicles during the construction of the Scheme is not

expected to have an impact on any of the cultural heritage features within the A of I,

including the rubble walls.

MITIGATION MEASURES

6.49. In the event that the Scheme proceeds, and in view of the potential for impacts on

cultural heritage arising from possible loss of, or damage to, unrecorded

archaeological artefacts, it is recommended that the Superintendence of Cultural Heritage is consulted to determine whether archaeology monitoring is required.

This monitoring would ensure that in the eventuality that uncharted artefacts are

encountered, any cultural heritage features removed from the Scheme site would be

appropriately recorded and, wherever possible, significant features should be

salvaged. This should be carried out in accordance with the directions issued by the


22 BS 7385: 1993, Evaluation and Measurement for Vibration in Buildings – Guide to Damage Levels from

Ground Borne Vibration: Part 2, British Standards Institution. 23 Cosmetic damage is defined as “the formation of hairline cracks on drywall surfaces, or the growth of existing

cracks in plaster or drywall surfaces; in additional the formation of hairline cracks in mortar joints of brick/ concrete

block construction”. 24 15 mm/s at 4 Hz. 25 Vibration monitoring data indicates that at 7 m the level vibration is lower than the 15 mm/s value prescribed

by BS 7385.

137

RESIDUAL IMPACTS

6.50. The residual impacts are uncertain, as this will depend on whether artefacts are

present within the Scheme site, the importance of these artefacts, and the extent of

any loss or damage to the artefacts.

6.51. Table 6.4 summarises the impact assessment.

MONITORING REQUIREMENTS

6.52. It is recommended that prior to the excavation and construction of the Scheme, the

Superintendence of Cultural Heritage is consulted on the requirement for

archaeology monitoring.

139

Table 6.4: Summary of Impacts on Cultural Heritage

Predicted

Impact

Beneficial/

Adverse/

Neutral

Nature, Scale and Type of Impact Probability

of Impact

Occurring

(Likely,

Unlikely,

Remote,

Uncertain)

Significance of

Impact

(Major/Minor/

Not

Significant)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major/Minor

/Not Significant)

Constr’n

/ Oper’n

Extent of

impact

(Nat /

Local /

Site)

Direct/

Indirect

S-term /

L-term

Perm /

Temp

Revers /

Irrevers

Loss or damage

to unrecorded

archaeological

or cultural

heritage

artefacts on site

Adverse Constr’n Site Direct L-term Perm Irrevers Uncertain

Uncertain,

depending on

whether

artefacts are

present, their

level of

importance,

and the extent

of any loss or

damage

Archaeological

monitoring

during excavation

/ recording of

features /

salvaging of

significant

features, if

requested by

SCH

Uncertain

(depending on

whether artefacts

are present, their

importance and the

extent of any loss

or damage)

Alteration or

degradation of

the structural

integrity and

quality of the

setting of the

rural rooms

close to the

Scheme Site

Adverse Constr’n /

Oper’n Local Direct L-term Perm Irrevers Likely

Not significant to

minor None

Not significant to

minor

141

7. LANDSCAPE AND VISUAL AMENITY

INTRODUCTION

7.1. This chapter addresses the potential impacts of the Scheme on landscape and visual

amenity. It describes the existing landscape and visual amenity of the Scheme Site

and its surroundings, and assesses how this might change through the development of

the Scheme.

7.2. Assessment of landscape and visual amenity involves examination of the wide range of

factors that contribute to the qualities and attributes of the existing landscape and

that may contribute to the landscape of the Scheme. This involves consideration of

the evolution of the landscape and the factors that have led to its current condition,

from the underlying geology through to anthropogenic activities.

7.3. Landscape and visual impacts are distinct, albeit strongly related. Landscape impacts

result from the interaction between a development and the existing landscape

resources, experienced through changes to any element or combination of landscape

elements. Visual impacts relate to the effect that a development would have on the

amenity of sensitive receptors (those experiencing views of the site), relating to the

actual or perceived visible changes to the character and quality of the landscape.

7.4. The key issues for the assessment are:

Key Issues:

Effects on the landscape setting of the Scheme

Changes in views of key receptors

OBJECTIVES OF THE ASSESSMENT

7.5. The objectives of the landscape and visual amenity study were to:

Undertake a baseline survey and characterisation of the landscape and visual

amenity at and around the Scheme Site, using desk top and field survey

techniques;

Evaluate the landscape character of the Scheme site and its setting;

Establish the Zone of Theoretical Visibility (ZTV)26 for the Scheme and identify

the key viewpoints and receptors;

26 In accordance with the Guidelines for Landscape and Visual Impact Assessment (Third Edition) (2013), the term

Zone of Theoretical Visibility (ZTV) is being used in place of the term Zone of Visual Influence (ZVI) since it

makes clear that the area thus defined shows land from which the proposal may theoretically be visible and

does not take account of potential screening by vegetation and buildings.

142

Input the potentially beneficial design measures to the Scheme;

Predict the impacts of the Scheme on the visual amenity in the ZTV;

Assess the significance of the impacts on the landscape and visual amenity of the

ZTV; and

Describe the mitigation measures designed into the Scheme to minimise adverse

impacts and enhance any beneficial impacts on the landscape and visual amenity.

LEGISLATION AND POLICY GUIDANCE

7.6. The Constitution of Malta (Section 9) declares that the State shall safeguard the

landscape and the historical and artistic patrimony of the Nation. These are the only

aspects of the environment referred to in the Constitution, underlining the

importance of the landscape and historical heritage.

South Malta Local Plan

7.7. The South Malta Local Plan (SMLP) 2006 is relevant to the Scheme. The site is

surrounded by quarries to the north and agricultural land to the south. The site itself

lies within a white area (see Figure 7.1).

7.8. POLICY SMCO 06 describes Areas of High Landscape Value designated in the

SMLP region within which, the policy states, there will be a presumption against

development of new built structures. Activities and interventions that will upgrade

and enhance these areas, such as establishment of cycling routes, will be encouraged.

Reference to ensuring that light pollution is avoided is also included in the Plan’s text

accompanying the policy. The AHLVs listed in the policy are the following:

Wied tal-Baqqiegħa (Haż-Żebbuġ) and Wied Ħesri (Is-Siġġiewi);

The slopes flanking Wied Ta’ Kandja (Is-Siġġiewi);

Wied Qirda (Haż-Żebbuġ / Is-Siġġiewi);

Għar Ħanzir and Wied Sillani (Is-Siġġiewi);

Wied il-Kbir (Is-Siġġiewi / Ħal-Luqa);

Wied ta’ Ħas-Saptan (Ħal-Għaxaq);

Wied ta’ Ħal-Saflieni (Ħal-Luqa);

Wied il-Qoton (Ħal-Għaxaq);

The rocky steppe at Ta’ Ħaxum (Ħal-Għaxaq);

The promontory of Għassa tal-Munxar (Wied il-Għajn);

The afforested sites along is-Swar tal-Kottonera (Iż-Żabbar, Il-Fgura); and

143

Between Żonqor Point (Wied il-Għajn) and Blata l-Bajda (Ix-Xgħajra).

7.9. As indicated in Figure 7.1, the Scheme site does not lie within an AHLV.

Landscape Assessment Study of the Maltese Islands

7.10. MEPA’s Landscape Assessment Study of the Maltese Islands was undertaken in 2004

as part of the Structure Plan Review. The Study does not provide an assessment

methodology to use in order to consider the impacts of a specific development; it

does however provide a useful baseline assessment of the prevailing landscape

character of the Maltese Islands. The primary purpose of the Study appears to have

been as a topic paper to identify Areas of High Landscape Sensitivity and inform the

Structure Plan Review.

7.11. The Scheme site lies within Landscape Character Area M40 which describes the

Mqabba Quarry Area. This area includes a number of large quarries; however, due

to the general flatness of the area, the quarries are generally not noticeable in long-

distance views.

7.12. The Scheme site borders Landscape Character Area M38 which describes the South

Airport Hinterland, which includes the settlements of Il-Qrendi, L-Imqabba, Ħal

Kirkop, Iż-Żurrieq, and Ħal Safi. Similarly to the Ħal Għaxaq – Il-Gudja hinterland, the

settlements are each dominated by a parish church. This large plain includes

extensive areas of dry farmland between the settlements. A number of rural

buildings are largely associated with cultivation as well as animal husbandry although a number of buildings are also associated with micro-industry and quarries are also

frequent.

Standards and Guidelines

7.13. In view of the fact that there are no Malta-specific landscape and visual amenity

assessment guidelines, ERA requested that the landscape and visual assessment be carried out in line with the UK’s Guidelines for Landscape and Visual Impact Assessment

2013 (GLVIA)(Institute of Environmental Management & Assessment (IEMA) and the

Landscape Institute).

7.14. The photomontages were prepared by Perit Joseph A. Pace in accordance with the

Malta Environment and Planning Authority’s (MEPA) 2015 Best Practice Guide Visual

Simulations.


Desk Study Methodology

Landscape Assessment

7.15. The landscape baseline conditions were determined through desk study and field

surveys. The desk study included:

A review of the information shown on the base map of the area and reference to

144

the maps prepared for the geo-environment and land use aspects of the EPS;

An analysis of aerial photographs to determine land use trends; and

A review of existing baseline information from:

o Literature searches;

o Previous environmental and planning studies undertaken in the area;

o Historic maps; and

o Legislation and policy documents.

Landscape Character, Value and Sensitivity

7.16. As mentioned, MEPA’s Landscape Assessment Study of the Maltese Islands was

carried out as part of the Structure Plan review. This study characterised the

landscape at a national level into a series of units known as landscape character areas

(LCAs). It describes landscape characteristics, qualities and influences on the

landscape. The landscape character area of the site and its surroundings consider MEPA’s Landscape Assessment Study as well as the results of the desk and field

studies when characterising the landscape in the area.

7.17. The value of the landscape receptor should also be considered. The value of a

landscape character receptor is a reflection of its importance in terms of any

designations that may apply, or its importance in itself as a landscape or townscape

resource, which may be due to its ecological, cultural, or recreational value. The

higher the value of the receptor, the greater is its sensitivity to the development.

Value is assessed as being high, medium, or low in line with the following criteria:

High landscape value – high importance and rarity, no or limited potential for substitution. Importance may be on an international, national, regional or local

scale e.g. Areas of High Landscape Value.

Moderate landscape value – moderate importance and rarity, limited potential for substitution. Importance on a regional or local scale e.g. undesignated but value

perhaps expressed through non-official publications or demonstrable use.

Low landscape value – low importance and rarity with considerable potential for substitution on a local scale, e.g. areas identified as having some redeeming

feature or features and possibly identified for improvement or recovery.

7.18. The condition of the landscape was assessed using the following criteria:

Good landscape condition: where the landscape and its features are in good

repair / good quality and have a high contribution to landscape character.

Moderate landscape condition: where the landscape and its features are in average repair / average quality and make a medium contribution to the landscape

character.

Low landscape condition: where the landscape and its features are in poor repair

145

/ poor quality and make a low contribution to landscape character.

7.19. Landscape sensitivity is a complex issue. The GLVIA refer to consideration of a

landscape’s susceptibility to change, meaning ‘...the ability of the landscape receptor...to

accommodate the proposed development without undue consequences for the maintenance

of the baseline situation and/or the achievement of landscape planning policies and

strategies.’

7.20. Landscape character sensitivity was then defined in accordance with the criteria set

out in Table 7.1.

Table 7.1: Landscape Character Sensitivity

Landscape Condition

Good Moderate Low

Landscape

value

High High High Moderate

Moderate High Moderate Low

Low Moderate Low Low

Magnitude of Change to Landscape Resource

7.21. The GLVIA describe that the identification of the magnitude of change depends on (i)

the size or scale of change in the landscape that is likely to be experienced as a result

of each effect; (ii) geographical extent over which the landscape effects will be felt;

and (iii) the duration and reversibility of the landscape effects. The magnitude of

change in a landscape depends on the loss, change, or addition of any feature, or any

change in the backdrop to, or outlook from, a landscape that affects its character.

Table 7.2 presents criteria for magnitude of change to a landscape resource.

Table 7.2: Magnitude of Change to Landscape Resource

High Medium Low Imperceptible change

An obvious change in

landscape characteristics

and character

Discernible changes to


and character

Small changes to


and character

A largely imperceptible

change to landscape

characteristics and

character

Visual Amenity Assessment

7.22. The Zone of Theoretical Visibility (ZTV) was defined using a combination of desk and

field-based techniques. The extent of the viewshed (ZTV) is shown in Figure 7.2

and was verified in the field along with the four representative viewpoints that were

agreed with the PA for the visual amenity assessment (see below). A fifth viewpoint

was added following consultation with the l-Imqabba Local Council (see below). The

digital terrain model (DTM) was used to establish the ZTV. The DTM considers the

bare-earth surface, that is, the bare ground surface without any objects or structures

such as vegetation and buildings. This model is the model recommended by the

MEPA’s 2015 Best Practice Guide - Visual Simulations. One of the shortcomings of

146

this model is that in reality vegetation and buildings may in fact screen the proposed

scheme even though the DTM viewshed may indicate that it is visible from particular

view points.

7.23. The digital surface model (DSM) does consider vegetation and buildings. A

shortcoming of this model, however, is that Scheme visibility is considered from the

top of any structure such as tree canopies and rooftops.

7.24. In view of the above shortcomings, both models were used to determine viewpoints.

The roads that fall within the viewsheds of both the DTM and the DSM are the areas

from where the proposed scheme is likely to be visible. It is important to identify

solid areas within the DSM viewshed as fragmented parts correspond to vegetation

and rooftops. Thus, when selecting viewpoints, areas where the DTM and DSM

overlap were considered as the most appropriate options. These were then verified

through ground truthing in the field before selection of the final viewpoints. Figure

7.3 shows the DTM and DSM.

7.25. ERA’s agreement to the location of the viewpoints was sought before the visual

amenity study was undertaken. The viewpoints include short and medium distance

views from publicly accessible locations and were identified within the ZTV. These

were agreed with ERA as a basis for assessing changes to visual amenity that may

result from the Scheme. The existing views from these locations were

photographed, photomontages created, and the visual amenity and changes thereto as

a result of the Scheme appraised.

7.26. During a consultation meeting with l-Imqabba Local Council, the Mayor enquired

about the visual impact from Triq il-Belt Valletta, expressing concern about the view

specifically when leaving Mqabba. As a result an additional viewpoint (VP5) was

added during the formulation of the EPS.

7.27. Figure 7.4 shows the selected viewpoints.

Photomontages

7.28. When carrying out the assessment, single frame 50 mm focal length images are used

for proximity views, whereas single frame 75 mm focal length images are used for all

other views, which are prepared in accordance with the 2015 MEPA’s Best Practice

Guide Visual Simulations.

Sensitivity of Visual Receptors

7.29. The sensitivity of visual receptors is dependent on the location from where the

receptors experience the view, their expectations, occupation or activity at the

viewpoint, and the importance of the view. UK Guidelines note that the most

sensitive receptors may include:

Users of outdoor recreation facilities whose attention or interest may be focused

on the landscape;

147

Communities where the development results in changes to the landscape setting

or valued views enjoyed by the community;

Visitors to heritage assets, or to other attractions, where views of the

surroundings are an important contributor to the experience; and

Occupiers of residential properties with views affected by the development.

7.30. The Guidelines also note that other receptors could include people engaged in

outdoor sport or recreation other than those involving an appreciation of the

landscape, people travelling through the area, and people at their place of work. The

latter are regarded as the least susceptible to changes in view.

7.31. The following definitions are used to categorise the sensitivity of receptors:

High sensitivity receptors: those who repeatedly re-visit the viewpoint to partake

of the view. Such views are generally highly valued by the community;

Moderate sensitivity receptors: itinerant visitors (mostly tourists) to the

viewpoint; and

Low sensitivity receptors: road users, workers, etc.

7.32. Residents are not included above because views from private property are not

protected under planning law or other public policy, except in so far as the zoning of

the land implies certainty as to the type of development that may be permitted. The

rights of nearby residents are, however, somewhat protected through the planning

system, since they can object to any change of land use (or airspace). The EIA

process does not assess the impacts of a development on the rights or values of

individuals, but rather on the public collectively, and those rights and values are as

expressed in legislation and planning policy. It is for this reason that this EPS does

not address the effects of loss of view from private properties, land ownership, etc.

Magnitude of Visual Change

7.33. Identification of the magnitude of change depends on the size or scale in change in

view (relating to the extent of visibility, degree of screening, angle of view and

distance from the development) and the degree of contrast or integration of any new

features with existing features as well as the duration and reversibility of visual

effects. Table 7.3 defines magnitude of visual change.

Table 7.3: Magnitude of Visual Change

High Medium Low Imperceptible Change

A substantial change in

view affecting a large

number of viewers

A moderate change in

view affecting many /

some viewers

A smaller change in view

affecting a low number

of viewers

A small, barely perceptible

or no change in view

148

Field Survey Methodology: Landscape

7.34. A comprehensive field survey was undertaken, in accordance with the Guidelines for

Landscape and Visual Impact Assessment (IEMA and the Landscape Institute 2013). The

field survey served to record objective and subjective impressions of the landscape,

and details of landscape condition, land use, and management. It contributed to the

delineation of local landscape tracts and the identification of potentially sensitive

landscape receptors in accordance with the Guidelines.

7.35. Table 7.4 describes the identified landscape receptors.

Table 7.4 Landscape Receptors

Landscape elements

Broad plain: Dominated by the Malta International Airport (MIA) and

runways, providing an open feel and long distance views out of the area

to include views of the sea at Birżebbuġa and visibility of the cranes at

the Freeport.

Apart from the airport and associated structures, such as the hangar,

the plain supports a rural environment dominated by dry farmland and

interspersed with settlements. Parish churches present focal points on

the skyline throughout the plain; a number of countryside chapels are

also noted.

Areas dominated by quarries are also located on the plain, and are

mainly noticeable from short-distance views.

Valleys: The dominant Wied il-Kbir valley system can be described in

the Is-Siġġiewi area. This particular valley system has experienced

development, including industrial development; terraced fields also

feature on the valley sides. The valleys leading to Birżebbuġa are more

associated with agricultural land and less with associated development;

the valley sides are relatively steep in areas.

Landscape characteristics

The MIA is located in the middle of the plain and allows a number of

long distance views out of the area. In addition to the airport, the plain

is largely made up of dry farmland, traditional village settlements, and

quarries.

The Wied il-Kbir valley system has experienced a degree of disturbance

that has degraded the landscape in a number of areas where industrial

activities, rural structures, and urban development have encroached

onto the valley sides. The valley systems leading to Birżebbuġa present

a relatively rural scene and a green environment with little negative

effects from dumping.

Landscape character

The distinct and recognisable pattern of elements that occurs

consistently in the landscape, and how this is perceived. Landscape

character areas have been defined and are illustrated in Figure 7.5.

Field Survey Methodology: Visual Amenity

7.36. The extent of the visibility of the Scheme site was verified during the field survey, and

the ZTV and publicly accessible viewpoints confirmed. The field survey also

confirmed the areas from which the site is not visible.

7.37. Potential sensitive receptors identified in the course of the field survey (in order of

descending sensitivity) were:

149

Recreational users of areas in the vicinity of the Site, walkers and joggers;

Tourists / visitors viewing the area from long to medium distance viewpoints;

Road users (vehicle occupants and pedestrians); and

Workers.

151

Figure 7.1: South Malta Local Plan Map (Scheme Site outlined in red)

153

Figure 7.2: Zone of Theoretical Visibility

155

Figure 7.3: Zone of Theoretical Visibility using both the digital terrain model (DTM) and the digital elevation model (DEM)

157

Figure 7.4: Zone of Theoretical Visibility (DTM + DEM) and selected viewpoints

159

Figure 7.5: Landscape Character Areas and Local Landscape Tracts

161

DETERMINING IMPACT SIGNIFICANCE

7.38. The significance of impacts on the landscape and visual amenity is dependent upon

judgements about the value of the existing visual amenity compared to the new visual

amenity that would be created, the number of people affected, the receptors’

sensitivity to change, the magnitude, duration and permanency of the changes, and subjective judgements about the degree to which these changes would matter to

those concerned

Landscape Assessment

7.39. The significance of landscape impacts has been defined based on the sensitivity and

magnitude criteria as described in Table 7.3 and Table 7.4, as follows:

Major significance: Large negative changes in the landscape that are out of character with the landscape. Where the extent of the negative impact on the

landscape setting is large in scale or magnitude and the landscape sensitive

receptor is of high sensitivity to change and / or a high intrinsic value and, as a

consequence, the integrity of the setting would be significantly altered. The

impact would be of international or national importance. The impact would be of

a long-term nature (or very severe short-term in the case of construction

impacts), irreversible, and certain or likely to occur;

Moderate significance: Discernible changes in the landscape that are out of character with the landscape. Where the extent of the negative impact on the

landscape character is medium in scale and landscape sensitive receptor is of

medium sensitivity to change and/or of medium intrinsic value. The impact would

be of a long-term nature, irreversible and likely to occur;

Minor significance: Small changes in the landscape that are out of character with

the landscape. Where the extent of the negative impact on the landscape setting is small in scale or magnitude and the landscape sensitive receptor is of a low

sensitivity to change or a low intrinsic value. The impact would be of local

importance. The impact would be of a long or short-term nature, and likely to

occur;

Not significant: No perceptible changes to the landscape setting. Where the extent of the negative impact on the landscape setting is of limited importance in

scale or magnitude and the landscape sensitive receptor is of a low sensitivity to

change and / or a low intrinsic value. The impact would be of local importance.

The impact would be of a long to short-term nature, and / or unlikely to occur.

Visual Amenity

7.40. The significance of visual impacts has been assessed in relation to:

The number and sensitivity of receptors affected;

The duration of the changes;

162

The extent of visibility and distance from the Scheme;

The type of view – proportion of development visible, focus on Scheme due to

proximity and whether it is fixed, transient, or sequential;

The changes to the view from the identified view points as shown by the

photomontages; and

The scope for mitigation / enhancement measures to screen the development.

7.41. Based on the above criteria, an assessment of the significance of the visual impact on

each of the agreed viewpoints was made in terms of whether it is considered to be

of:

Major significance - substantial changes in the view. Where the extent of the impact on the view would be large in magnitude and affect a large number of

receptors or is of particular importance to the viewers affected. May be an

advertised viewpoint and/or a view with high amenity and scenic qualities and

few intrusive elements in the view;

Moderate significance – moderate change to the view. Where the extent of the

impact on the view would be moderate in magnitude or extent and affect a

moderate number of receptors or is of some importance to the viewers affected.

May be a viewpoint from which there is a view with some visual amenity /

intrinsic value (this may include views across, or within, a regionally or locally

designated landscape) and potentially some intrusive elements to the view;

Minor significance – smaller changes to the view. Where the extent of the impact on the view would be small in magnitude or extent, and affect relatively

few receptors, or a larger number of receptors with passing interest in their

visual environment. The view would have a low visual amenity / intrinsic value or

with intrusive man-made elements within the view; or

Not significant - little or no obvious changes to the view. Where the extent of the

impact on the visual amenity would be of limited importance in scale or

magnitude, or affect persons of low sensitivity to change, and / or be a view of

low intrinsic value. Alternatively, the impact would affect very few people, be

transient and only affect a small part of the Scheme or panorama.

7.42. Table 7.5 identifies impact significance in a tabular format. It should be noted that there is a gradual transition between categories and magnitude and sensitivity are not

necessarily evenly weighted such that the final decision on significance comes down

to a professional judgement. Impact significance is recorded as one of the four

categories (not significant, minor, moderate, or major).

163

Table 7.5 Identification of Impact Significance

Magnitude of change

Imperceptible Low Medium High

Sensitivity of

Receptor

Low Not significant Not significant or

Minor Minor Minor or moderate

Medium Not significant Minor Moderate Moderate or major

High Not significant Minor or moderate Moderate or major Major

EXISTING CONDITIONS

Landscape

7.43. The Scheme site is currently used as an open storage area. It is situated within a

relatively large area that is dominated by quarries, located largely within the confines

of L-Imqabba. On the ground, evidence of the quarries is generally noticeable in the

immediate vicinity where apart from the quarries themselves, some of the roads are

badly surfaced, and other areas have been used for dumping of construction waste

and storage of large items (e.g. pontoons). In places, amenity has been improved to

a degree through the restoration of the quarries and reclamation to agricultural land.

However, given the extent of quarries in the area, dumping, and badly surfaced roads,

the overall feel of the landscape remains one associated with intense quarrying

activity.

7.44. South of the site, the area is dominated by a rural landscape interspersed with

traditional village settlements. Parish churches associated with these villages including

Ħal Kirkop, L-Imqabba, Iz-Żurrieq, Ħal Safi, and Il-Qrendi break the skyline providing an attractive, distinctive element to the landscape. The agricultural land in the area is

relatively well maintained and a number of chapels are also present in the

countryside.

7.45. A micro-electronics plant acts as somewhat of a landmark feature on the approach to

Ħal Kirkop and L-Imqabba and it is also a dominant feature from certain long distance

views.

7.46. The Malta International Airport (MIA) is located to the north, extending to the east

and partly to the west around the Scheme site area. The entire MIA is located on a

large plain. Most of the area is taken up by the runways, allowing long distance views

beyond the site. The landscape around the runways includes an extent of greenery,

particularly in the vicinity of Ħal Safi and Il-Gudja. Other dominant features in the

area include aircraft hangars, the old airport building, and other associated structures.

The terminal itself is situated at a slightly lower level than street level and this reduces its dominance on the landscape during the day; however, lighting of the

airport at night results in the area dominating the landscape. SkyParks is also a

significant feature when approaching the airport from all directions.

164

7.47. The landscape to the north-east of the Scheme site, beyond the MIA footprint is, in

fact, similar to the rural landscape to the south, with the settlements of Ħal Għaxaq and Il-Gudja dominating the settlement skyline. Directly north, the landscape differs

in that the rural environment is not dominant with the presence of Ħal Luqa and the

Marsa Industrial Estate. Nonetheless, the Addolorata Cemetery, Għammieri Farm

and the Marsa Sports Club contribute to providing a green element to the landscape.

7.48. The area west of the Scheme site is characterised by the Wied il-Kbir valley system

and the Is-Siġġiewi and Haż-Żebbuġ villages, located further away. In the vicinity of

the airport the Ħal-Farruġ settlement is a dominant landscape feature. Industrial

uses, including a construction related plant and a gas plant are also located in this

area and have dominated the landscape, encroaching onto the valley. In addition,

animal husbandry structures and farms as well as a number of green houses are

located at the top of the valley sides. The Tal-Ħandaq Industrial Estate faces Wied Qirda (part of the Wied il-Kbir valley system). Lower down the valley sides, terraced

fields are the main landscape features in places.

Landscape Characterisation

7.49. The landscape types and character areas that provide the landscape context to the

Scheme site are described below. The distinction between the types and areas is

defined in the assessment as:

Landscape Character Types - describe distinct and homogeneous generic landscape

units that share common combinations of elements (listed and described in

Table 7.6); and

Landscape Character Areas - single unique areas that represent the discrete

geographical areas of a particular type. Each Landscape Character Area may be

divided into Local Landscape Tracts (LLT) that describe potential problems and

pressures affecting the landscape character (illustrated in Figure 7.4 and

described in Table 7.6).

Table 7.6: Landscape Character Types and Landscape Character Areas

Defined area / Attribute Summary Description

Character Areas

Malta International Airport Includes the entire footprint of the MIA, which is largely taken up by

the runways but also includes associated buildings of which aircraft

hangars are dominant. Other structures include the old airport.

Landscape Sensitivity

Moderate

South Airport Hinterland Also, largely situated on the plain the Local Landscape Tracts in this

area include:

o The settlements of L-Imqabba, Ħal Kirkop, Ħal Safi, Il-Qrendi and

Iż-Żurrieq

o Active and restored quarries, batching plant

o Agricultural land


o Moderate

LLT: Settlements o Traditional villages, each of which include a parish church that

165


breaks the skyline

o Modern development on the outskirts detracts from the

traditional sense of these settlements


o High

LLT: Quarries o Series of operational and disused quarries including rock crushing

plant

o Dumping in the area

o Storage of large bulky items


o Low

LLT: Agricultural land o Dry farming

o Cultural heritage features including chapels and rubble walls

o Large carob trees


o High

North Airport Dominated by Luqa and Marsa. Some greenery associated with Marsa

Sports Club, Għammieri farm and the Addolorata cemetery,

providing a ‘green belt’.

o The settlements of Ħal Luqa and Il-Marsa

o Marsa Industrial Estate

o Green belt


o Moderate to low

LLT: Settlements o Settlements that include some modern buildings that detract from

the townscape

o Traffic congestion particularly at Marsa


o Low

LLT: Industrial estate o Industrial estate, dominated by factories, and warehouses,

dilapidated in areas

o Associated with low urban quality


o Low

LLT: Green belt o Trees and greenery in the area due to the presence of Addolarata

Cemetery, the Malta Sports Complex and the Għammieri Farm


o Moderate to high

Ħal Għaxaq Il-Gudja Hinterland Also, largely situated on the plain the Local Landscape Tracts in this

area include:

o The settlements of Ħal Għaxaq and Il-Gudja

o Agricultural land


o Moderate

LLT: Settlements o Traditional villages, each of which include a parish church that

breaks the skyline


o Moderate

LLT: Agricultural land o Dry farming

o Cultural heritage features including chapels and rubble walls

o Large carob trees


o High

Is-Siġġiewi-Haż-Żebbuġ Foreland Landscape of rolling hills and valleys:

166


o The settlements of Is-Siġġiewi, Haż-Żebbuġ and Ħal-Farruġ

o Tal-Ħandaq Industrial Estate

o Wied il-Kbir Valley system


o Moderate

LLT: Settlements o Is-Siġġiewi with a dominant parish church

o Haż-Żebbuġ parish church less dominant, townscape affected in

places by modern development

o Housing estate of Ħal-Farruġ, provides a sense of a gated

community, located almost adjacent to MIA footprint and

runways.


o Low to moderate

LLT: Industrial Estate o Poor urban quality and industrial areas

o Dumping and tipping in adjacent areas including encroachment

onto the valleys


o Low

LLT: Wied il-Kbir valley system o Designated as an AHLV in the Local Plan

o Impacted from development and industry in Is-Siġġiewi, Haż-

Żebbuġ and Ħal Qormi

o Major tributary system in the Maltese Islands


o High

Il-Birżebbuġa Valleys Valleys leading to Birżebbuġa dominate this character area and are

designated AHLVs in accordance with the Local Plan, including Wied

il-Qoton and Wied ta’ Ħas-Saptan. Valley sides include terraced

fields. Enemalta fuel storage tank facility located in Wied ta’ Ħas-

Saptan, in the vicinity of the Special Area of Conservation (SAC),

Għar Dalam.


High

Visual Amenity: Zone of Theoretical Visibility

7.50. Figure 7.2 illustrates the computer-generated ZTV. In the field it was ascertained

that, as a result of buildings, vegetation, and distance, the Scheme site was not visible

from all areas within the ZTV. The field survey was carried out to select the best viewpoints insofar as could be determined prior to the generation of photomontages

and to identify the long, medium, and short distance views from public places. As

mentioned above, the selected viewpoints were agreed with ERA and are shown in

Figure 7.4.

Scheme Site Visibility

7.51. In assessing views, there is often likely to be a continuum in the degree of visibility of

the development from full view to no view. Table 7.7 summarises the situation in

respect of the Scheme and with regard to the following:

167

Extent of site visibility – full view, partial view, glimpse or no view into the site at

all demonstrates the exposure of the site and the processes thereon to public

view.

o A glimpse of the Scheme site can be seen from Viewpoints 1 and 5 and the

site is partially visible from Viewpoint 2. The site is not visible from

Viewpoint 3 and Viewpoint 4.

Proportion of development visible – expresses the proportion of the

development (the Scheme) that would be visible from the viewpoints: full, most,

some, small amount, or none.

o Some of the Scheme is visible from Viewpoints 1, 2, and 5. The proposed

development will not be visible from Viewpoint 3 and Viewpoint 4.

Focus on Scheme due to proximity – is an indicator of the distance from the Scheme site and whether the viewpoint would focus on the development due to

its proximity (i.e., it is the only thing to look at), or whether the Scheme is part of

a panorama.

o Viewpoints 1, 2, and 5 are proximity viewpoints. The Scheme cannot be

seen from Viewpoints 3 and 4.

Transient or sequential view – the principal receptors will have sequential views

of the Scheme site. Transient views are those that pass quickly (like looking

through a doorway as one walks past), and sequential views expose the receptor

to different yet sequential views of the site. The latter allows the site to be

viewed for a longer period and from different and changing perspectives.

o Viewpoints 1, 2, and 5 are sequential.

Table 7.7: Summary of Scheme Site Visibility from Viewpoints

Viewpoints

VP1 VP2 VP3 VP4 VP5

Distance from Scheme (m) 80 3 960 799 201

Extent of Scheme visibility Partial Partial Not visible Not visible Partial

Proportion of Scheme visible 25% 20% 0% 0% 5%

Focus on Scheme due to proximity Proximity Proximity N/A N/A Proximity

Transient or sequential view Sequential Sequential N/A N/A Sequential

168

CHANGES IN THE LANDSCAPE AND VISUAL AMENITY

7.52. Changes to the landscape and visual amenity of the ZTV are anticipated as a result of

the Scheme. This section focuses on the likely impacts of the Scheme on landscape

and visual amenity, and points to possible mitigation measures, where relevant.

Changes in the Landscape and their Significance

7.53. The changes to the landscape during the construction and operation of the Scheme

are considered together. In terms of landscape character, the impacts likely to occur

as a result of the operation of the Scheme were assessed for all LLTs. No impact

was identified for the following character areas and their LLTs: Birżebbuġa Valleys,

Ħal Ghaxaq – Il-Gudja hinterland, Malta International Airport, North Airport, and Is-

Siggiewi – Haż-Żebbug Foreland. The impact assessment identified an impact on the

LLTs within the South Airport Hinterland as described in Table 7.8.

Table 7.8 Changes in Landscape Character and Significance of the Impacts

Location Changes Effects & Significance

South Airport

Hinterland

Character Area

LLT: Settlements

The introduction of a petrol station

to the approach road towards L-

Imqabba changes somewhat the

current use of this area which is

dominated by quarries and similar

activities and the site itself which is

currently used for open storage.

However, the Scheme site is located

on a road in an area that does not

pass through a settlement directly.

Indirect effects on settlements need

to be considered. As identified by the

visual impact assessment ( see below),

long-distance views will not be

affected, however, other effects on

the landscape could include traffic

implications as well as odour.

Chapter 8 includes an assessment of

odour impact on residential sensitive

receptors, and potential impacts from

the Scheme were assessed to be

negligible. Traffic impacts were also

considered in a separate study, with

no major disruptions identified.

Therefore, the change to the

landscape of this LLT is considered to

be small.

Small scale change to a landscape of

high sensitivity.

Impact: Minor significance

South Airport

Hinterland

Character Area

LLT: Quarries

The Scheme site is located within this

LLT and introduces an entirely new

feature to this landscape, resulting in a

large change.

A large change to a landscape of low

sensitivity.

Impact: Moderate significance

South Airport

Hinterland

Character Area

LLT: Agricultural

The Scheme lies adjacent to this LLT

and introduces a new feature to the

landscape, although it is not

considered to have a direct effect on

A small to medium change to a

landscape of high sensitivity.

Impact: Moderate significance

169

Location Changes Effects & Significance

land this LLT.

Changes in Visual Amenity and their Significance

7.54. The assessment of the impact of the Scheme on the visual amenity of the ZTV takes

account of the:

Scale of change resulting from the Scheme;

Degree of contrast or integration resulting from the change;

Duration and nature of the effect;

Angle of view in relation to the main activity of the receptor;

Distance of the viewpoint from the Scheme site;

Extent of the area over which the changes would be visible; and

Number and level of sensitivity of sensitive receptors who may experience the

views.

7.55. The changes to the visual amenity and their significance are described below. For

Viewpoint 3 and Viewpoint 4, the photomontages indicate that the Scheme will not in

fact be visible from these viewpoints. This is illustrated through the wireframes.

Therefore, with no change to these viewpoints, no impacts are identified and no

assessment is presented.

171

Viewpoint

1

Date: 14th July 2017

Location Triq il-Belt Valletta, L-Imqabba

Key

features

View down the distributor road which is flanked on either

side by Pine trees providing a degree of shading. An

installation is visible on the right hand side over the boundary

wall.

Low visual amenity, low intrinsic value.

Sensitive

receptors

Motorists.

Moderate number of sensitive receptors of low sensitivity.

Change to

Visual

Amenity

The Scheme introduces a modern building which is noticeable

on the right hand side of the road; and some trees have been

removed, creating a gap in the tree-lined road border.

Impact A noticeable change affecting a view of low intrinsic value and

impacting on low sensitive receptors.

Impact: Minor.

173

Viewpoint

2


Location Back road behind Triq il-Belt Valletta, L-Imqabba (passes

through site)

Key

features

The view from the back road is onto the rear of the Scheme

site where fork lifters and storage of concrete bricks occurs

and are visibile. Higher structures are also visible. Trees

flanking the distributer road of Triq il-Belt Valletta are

noticeable behind the Scheme site.


Sensitive

receptors

Motorists; users of the site.

Low numbers of low sensitive receptors

Change to

Visual

Amenity

Introduction of a more modern-looking structure, taller than

any existing structures on site which blocks long distance

views out of the site such that the trees in the distance are

largely no longer visible.

Impact A noticeable to large change affecting a view of low intrinsic

value and impacting on low sensitive receptors.

Impact: Minor to moderate.

175

Viewpoint

3


Location Triq il-Belt Valletta, (route to Iż-Żurrieq)

Key

features

View dominated by the road. Vegeatation flanks the road, and

is also noticeable in the distance. A high fence is visible to the

left of the viewpoint.


Sensitive

receptors

Motorists.

Moderate numbers of low sensitive receptors

Change to

Visual

Amenity

None. Refer to wireframe which illustrates that Scheme will

be completely screened from this viewpoint.

Impact N/A

177

Viewpoint

4


Location Triq Danny Cremona, Ħ al Kirkop

Key

features

View from a crossroads towards the site. Not much is visible

over the boundary wall which forms the main feature of this

view. Vegetation can be seen to a degree above and around

the wall as well as a long (horizontally) building in the distance.


Sensitive

receptors

Motorists, pedestrians.

Low to moderate number of sensitive receptors of low to

moderate sensitivity.

Change to

Visual

Amenity

None. Refer to wireframe which illustrates that Scheme will

be completely screened from this viewpoint.

Impact N/A

179

Viewpoint

5

Date: 5th September 2017

Location Triq il-Belt Valletta, L-Imqabba

Key

features

View down the distributor road which is flanked on either

side by Pine trees providing a degree of shading. A building is

visible on the right hand side over the boundary wall. A

relatively tall rust-coloured silo is noticeable on the

Application Site on the left hand side of the road in between

the trees; some lower grey structures can also be seen on the

skyline though they are not as noticeable.


Sensitive

receptors

Motorists.

Moderate number of sensitive receptors of low sensitivity.

Change to

Visual

Amenity

The change to the view relates to a slight change in the lower

lying grey structures behind the trees on the left hand side of

the road, however, the change is barely noticeable.

Impact An unnoticeable change affecting a view of low intrinsic value

and impacting on low sensitive receptors.

Impact: Not significant.

181

7.56. The impacts of the Scheme on the visual amenity of the areas portrayed in the above

photographs and photomontages from the agreed viewpoints range from being of

minor to minor / moderate significance. Significance is dependent on the scale of

change to the landscape and the visual amenity of the area, the intrinsic value of the

view, and the sensitivity of receptors that will view the Scheme. The Scheme will not

be visible from Viewpoint 3 and Viewpoint 4.

MITIGATION

7.57. The Scheme includes some landscaping. Figure 7.6 and Figure 7.7 provide

photomontages of Viewpoints 1 and 2 (for which impacts were identified) following

10 years from planting the landscaping scheme.

RESIDUAL IMPACTS

7.58. The proposed landscaping does not provide any screening to the development from

the considered viewpoints and residual visual impacts therefore remain.

7.59. Table 7.9 summarises the landscape and visual amenity impact assessment.

183

Figure 7.6: Viewpoint 1 photomontage 10 years into growth of plants used in landscaping

185

Figure 7.7: Viewpoint 2 photomontage 10 years into growth of plants used in landscaping

187

Table 7.9: Summary of Impacts on Landscape and Visual Amenity

Predicted Impact

Beneficial

/Adverse

/Neutral


of Impact

Occurring

(Likely/

Unlikely/

Remote/

Uncertain)

Significanc

e of

Impact

(Major/

Moderate/

Minor/Not

Significant

)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major/

Moderate/

Minor/Not

Significant)

Constr’n

/Oper’n

Extent of

Impact

(Nat/

Local

/Site)

Direct/

Indirect

S’term/

L’term

Perm/

Temp

Revers/

Irrevers

Landscape

Malta International

Airport Character Area

Neutral Oper’n Local Direct L-term Perm Revers Likely Not

significant

None Not significant

South Airport

Hinterland Character

Area : LLT: Settlements

Adverse Oper’n Local Direct L-term Perm Revers Likely Minor None Minor

South Airport


Area : LLT: Quarries

Adverse Oper’n Local Direct L-term Perm Revers Likely Moderate None Moderate

South Airport


Area : LLT: Agricultural

land


North Airport

Character Area

LLT: Settlements


significant


North Airport

Character Area

LLT: Industrial estate


significant


North Airport

Character Area

LLT: Green belt


significant


Ħal Għaxaq – Il-Gudja

Hinterland Area

LLT: Settlements


significant


188

Predicted Impact

Beneficial

/Adverse

/Neutral


of Impact

Occurring

(Likely/

Unlikely/

Remote/

Uncertain)

Significanc

e of

Impact

(Major/

Moderate/

Minor/Not

Significant

)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major/

Moderate/

Minor/Not

Significant)

Constr’n

/Oper’n

Extent of

Impact

(Nat/

Local

/Site)

Direct/

Indirect

S’term/

L’term

Perm/

Temp

Revers/

Irrevers

Ħal Għaxaq – Il-Gudja

Hinterland Area

LLT: Agricultural land


significant


Is-Siġġiewi – Haż-

Żebbuġ Foreland

Character Area

LLT: Settlements


significant



Żebbuġ Foreland

Character Area

LLT: Industrial estate


significant



Żebbuġ Foreland

Character Area

LLT: Wied il-Kbir

Valley System


significant


Birżebbuġa Valleys

Character Area


significant


Visual Amenity

Viewpoint 1: Triq il-Belt

Valletta, L-Imqabba

Adverse All Local Direct L-term Perm Revers Likely Minor None Minor

Viewpoint 2: Back road

behind Triq il-Belt

Valletta, L-Imqabba

Adverse All Local Direct L-term Perm Revers Likely Minor to

Moderate

None Minor to

Moderate

189

Predicted Impact

Beneficial

/Adverse

/Neutral


of Impact

Occurring

(Likely/

Unlikely/

Remote/

Uncertain)

Significanc

e of

Impact

(Major/

Moderate/

Minor/Not

Significant

)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major/

Moderate/

Minor/Not

Significant)

Constr’n

/Oper’n

Extent of

Impact

(Nat/

Local

/Site)

Direct/

Indirect

S’term/

L’term

Perm/

Temp

Revers/

Irrevers

(passes through site)


Valletta, (route to Iż-Żurrieq)

N/A

Viewpoint 4: Triq

Danny Cremona, Ħal

Kirkop

N/A


Valletta, L-Imqabba

Adverse All Local Direct L-term Perm Revers Likely Not

significant

None Not

significant

191

8. AIR QUALITY

INTRODUCTION

8.1. This chapter addresses the potential impacts of the emissions from the operational

aspect of the Scheme on air quality.

8.2. The key issue for the assessment is:

Key Issue:

Effects of air emissions and odours arising from the operation of the Scheme on sensitive receptors

Terms of Reference

8.3. The Terms of Reference (ToR) for the air quality assessment, issued by the

Environment and Resources Authority (ERA), are reproduced in Technical

Appendix 1: Terms of Reference and Method Statements.

Objectives of the Assessment

8.4. The objectives of the air quality study were to:

Quantify the expected emissions of benzene from the operational aspect of the

Scheme;

Assess the potential impacts of the Scheme from benzene emissions on air quality

sensitive receptors;

Establish the odour baseline and assess the potential impacts of odour from the

Scheme operations on sensitive receptors; and

Describe the mitigation measures to minimise potential adverse impacts on air

quality.

Legislation and Guidance

8.5. Guidance on air quality related to benzene emissions in the Maltese context is

available in the following national legislation:

Legal Notice 478 of 2010: Ambient Air Quality Regulations, LN 478 of 2010 (as

amended, S.L.549.59);

Legal Notice 291of 2002: National Emission Ceilings for Certain Atmospheric

Pollutants Regulations (as amended, S.L.549.32); and

192

Legal Notice 228 of 2016: Control of VOC Emissions (Storage and Distribution of

Petrol from Terminals to Service Stations) Regulations (S.L. 549.52).

8.6. This legislation is assessed in detail in Chapter 4 of the EPS.

8.7. Maltese and EU regulations do not set a target or limit value for Volatile Organic Compounds (VOCs) in ambient air, and there are no local guidelines for total VOC

levels in ambient air. However, the Ambient Air Quality Regulations set a limit value

for benzene in ambient air of 5 µg/m3 (annual average).

8.8. In the absence of local guidance on the assessment of air quality from fuel service

stations, European guidance is relevant. UK guidance27 states that petrol stations

fitted with Stage II recovery systems do not need to be included in a detailed

assessment for compliance against the benzene limit value and proposes a method to

be used when assessment is required; this method is being used since the ToR

require benzene assessment.

8.9. In the absence of local regulations or guidance on the assessment of odour impacts

from fuel service stations, UK guidance has been referred to (Defra, 2010;28 IAQM,

201429).


8.10. As agreed with ERA30, the air quality assessment focused on the potential impacts on

air quality as a result of emissions from fuel delivery to the station and emissions

during vehicle refuelling.

8.11. The need for assessment of air quality arising from the construction of the Scheme

and from increase in traffic during Scheme operation were scoped out since the

Traffic Impact Assessment indicates that there will be a negligible increase in traffic as

a result of the development; therefore the applicable trigger levels31 are not reached by the Scheme. Additionally, although the construction processes are expected to

generate dust emissions, the site is already concreted over and there will be minimal

excavation; therefore such emissions are expected to be minor and temporary, and

can also be mitigated to some extent.

8.12. In the absence of Regulations or local guidelines establishing limit or target values for

27 Defra (2016) Local Air Quality Management Technical Guidance (TG16)

https://laqm.defra.gov.uk/documents/LAQM-TG16-April-16-v1.pdf. 28 Defra (2010) Odour Guidance for Local Authorities

www.gov.uk/government/uploads/system/uploads/attachment_data/file/69305/pb13554-local-auth-guidance-

100326.pdf. 29 Institute of Air Quality Management (2014) Guidance on the Assessment of Odour for Planning

http://www.iaqm.co.uk/text/guidance/odour-guidance-2014.pdf. 30 A method statement was submitted to ERA on 27th April 2017 and accepted on 10th May 2017. This method

statement is included in Technical Appendix 1: Terms of Reference and Method Statements 31 The trigger levels are: daily traffic flows will change by 1,000 AADT or more; or Heavy Duty Vehicle flows

will change by 200 AADT or more. (Design Manual for Roads and Bridges; Volume 11, Section 3).

https://laqm.defra.gov.uk/documents/LAQM-TG16-April-16-v1.pdf

http://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69305/pb13554-local-auth-guidance-100326.pdf


http://www.iaqm.co.uk/text/guidance/odour-guidance-2014.pdf

193

total VOC in ambient air, benzene was selected as the VOC used in the air quality

assessment.

8.13. Since there is no instrument that can be used to objectively measure odours, and

since the human nose is more sensitive to certain odours associated with particular

gases than any instrument, odour assessment was based on the “sniff test”, as

recommended by Defra (2010).32

Sensitive Receptors

8.14. The nearest residence is located over 250 m to the southwest of the Site, as shown

in Figure 8.1. Residences are classified as high sensitivity receptors according to

Institute of Air Quality Management (IAQM) guidance on odour33.

8.15. As shown in Figure 8.1, the predominant land uses in the surroundings are

industrial (including quarries and storage activities) and agricultural. These types of

receptors are considered to be low sensitivity receptors according to IAQM odour

guidance33. In view of the distance of the Scheme site from the nearest residential

receptor, such receptors are also considered in the odour assessment; however, they

are not considered in the benzene assessment. This is since the averaging period for

the benzene limit value is one year; therefore this limit value applies to locations

where members of the public might be regularly exposed (such as residences), but

not the other locations where public exposure is expected to be short term (such as

workplaces or industrial sites).34

Baseline Data

Benzene

8.16. An average of ERA’s long-term diffusion tube data for the year 2016 from the sites

shown in Figure 8.2 was used to obtain a baseline indicating current levels of

benzene. It has therefore been assumed that this baseline (without the Scheme)

currently applies at the nearest residential receptor.

8.17. As a precaution, it was assumed that current benzene concentrations will remain

constant in the future. This is a conservative assumption since the increasing uptake

of vapour recovery systems in petrol stations, and lower hydrocarbon emissions

from newer vehicles are expected to lead to a reduction in ambient benzene levels.

32 Defra (2010) Odour Guidance for Local Authorities

www.gov.uk/government/uploads/system/uploads/attachment_data/file/69305/pb13554-local-auth-guidance-

100326.pdf 33 Institute of Air Quality Management (2014) Guidance on the Assessment of Odour for Planning

http://www.iaqm.co.uk/text/guidance/odour-guidance-2014.pdf. 34 Defra (2016) Local Air Quality Management Technical Guidance (TG16)

https://laqm.defra.gov.uk/documents/LAQM-TG16-April-16-v1.pdf.



http://www.iaqm.co.uk/text/guidance/odour-guidance-2014.pdf

https://laqm.defra.gov.uk/documents/LAQM-TG16-April-16-v1.pdf

195

Figure 8.1: Surrounding Land Uses

197

Figure 8.2: ERA Diffusion Tube Locations for Benzene Baseline Data

199

Odour

8.18. Baseline odour levels were established through a sniff test carried out by two Adi

Associates staff members; details of the survey are given in Table 8.1. The survey

was carried out by noting the odours currently experienced at the nearest residential

receptor and close to the site boundary; the locations are shown in Figure 8.3.

Records were made of any existing odours, including frequency, intensity, duration

and offensiveness, and weather data was also noted.

Table 8.1: Baseline Odour Survey Details

Survey

Date Time

Location

(Figure 8.3) Description

23rd June

2017

10:18 – 10:33 1

Outside residential receptor, surroundings are largely

agricultural with manure application having occurred

recently

10:52 – 10:58 2 Outside Scheme site, industrial surroundings, adjacent to

busy road

8.19. A scale published by the Institute of Air Quality Management (2014) was used to

record odour intensity, as shown in Table 8.2.

Table 8.2: Odour Intensity Categories

Odour Strength Intensity Level Description

No odour / not perceptible 0 No odour

Slight / very weak 1 There is probably some doubt as to whether the odour is

actually present

Slight / weak 2 Odour is present but cannot be described using precise

word or terms

Distinct 3 Odour character is barely recognisable

Strong 4 Odour character is easily recognisable

Very strong 5 Odour is offensive. Exposure to this level would be

considered undesirable

Extremely strong 6 Odour is offensive. An instinctive reaction would be to

mitigate against further exposure

201

Figure 8.3: Baseline Odour Survey Locations

203

Emissions

Benzene

8.20. When there is no abatement, emissions of Volatile Organic Compounds (VOC) in

service stations arise mainly from the following activities related to the handling of

petrol (gasoline):

Tank emissions: vapour displacement when an incoming bulk delivery of petrol is

received into storage tanks; and

Emissions during vehicle refuelling: occur when gasoline is transferred from

storage tanks to transport vehicles. They are a combination of vapour from the

larger tank’s contents and the vapour evolved in the car’s tank as a result of

splashing and turbulence during filling.

8.21. However, Stage IB and Stage II vapour recovery will be installed at the Scheme, to

abate emissions arising during petrol delivery into the storage tanks and vehicle

refuelling respectively.

8.22. Emission factors for benzene emissions from the Scheme (Table 8.3) were derived

using the latest Tier 2 emission factors from the EMEP / EEA inventory35, on the basis

that gasoline has a maximum benzene content of 1%36.

Table 8.3: Benzene Emission Factors

Emission Source Abatement

Type

Abatement

Efficiency

Benzene Emission Factor

(after abatement)

Storage tank filling Stage IB 95% 0.012 g/m3 throughput/ kPa TVP

Storage tank breathing - - 0.030 g/m3 throughput/ kPa TVP

Vehicle refuelling Stage II 85% 0.056 g/m3 throughput/ kPa TVP

Drips and spills during vehicle

refuelling - - 0.02 g/m3 throughput/ kPa TVP

Overall Emission Factor 0.118 g/m3 throughput/ kPa TVP

8.23. The values in Table 8.3 were used to calculate annual benzene emissions by

multiplying the overall emission factor by the annual petrol throughput (in m3)37 and

the True Vapour Pressure (TVP) of petrol (in kPa).

35 EEA (2016) EMEP/EEA air pollutant emission inventory guidebook 2016: Technical guidance to prepare national

emission inventories http://www.eea.europa.eu/publications/emep-eea-guidebook-2016. 36 Legal Notice 44 of 2008 as amended, the Quality of Fuels Regulations (S.L. 423.39). 37 The annual petrol throughput is estimated at 1,330 m3, on the basis that around 110,000 trips to the Scheme

are expected annually, a 60.6% share of petrol vehicles (NSO Transport Statistics 2016), and an estimated 20 L

per petrol refuelling trip.

http://www.eea.europa.eu/publications/emep-eea-guidebook-2016

204

8.24. A TVP of 36.8 kPa was used, calculated using the EMEP/EEA formula:

TVP = RVP x 10AT+B

where:

A = (0.000007047 x RVP) + 0.0132;

B = (0.0002311 x RVP) – 0.5236;

T is the annual average ambient temperature in Malta, 18.6 oC;38

RVP is the Reid Vapour Pressure of petrol (in kPa). A RVP of 66 kPa was used,

based on 2012 data39.

8.25. The assessment of impacts was carried out using a nomogram developed by Defra40

for benzene emissions from fugitive and low-level sources such as petrol stations (see

Figure 8.4).

Figure 8.4: Emissions of Benzene giving rise to an Annual Mean Ground-

level Concentration of 0.22 µg/m3 at Receptors

8.26. To use the nomogram, the line that corresponds to the height of the stack under

consideration was first identified. A conservative stack height of 3 m was used,

38 Galdies (2011) The Climate of Malta: Statistics, Trends and Analysis 1951-2010

https://nso.gov.mt/en/publicatons/Publications_by_Unit/Documents/B3_Environment_Energy_Transport_Agric

ulture_Statistics/The_Climate_of_Malta.pdf. 39 Malta Resources Authority, personal communication (27th January 2014). 40 Defra (2009) Local Air Quality Management: Technical Guidance LAQM.TG(09)

https://laqm.defra.gov.uk/documents/LAQM-TG-(09)-Dec-12.pdf.

https://nso.gov.mt/en/publicatons/Publications_by_Unit/Documents/B3_Environment_Energy_Transport_Agriculture_Statistics/The_Climate_of_Malta.pdf

https://nso.gov.mt/en/publicatons/Publications_by_Unit/Documents/B3_Environment_Energy_Transport_Agriculture_Statistics/The_Climate_of_Malta.pdf

https://laqm.defra.gov.uk/documents/LAQM-TG-(09)-Dec-12.pdf

205

despite the tank vents being at least 4 m high.

8.27. The point on this line which corresponds to the nearest residential receptor was

identified (that is, around 250 m on the x-axis), and the associated emission rate on

the y-axis was read.41 This emission rate (in tonnes per annum) corresponds to an

increase in ground-level concentration of benzene of 0.22 µg/m3 at the sensitive

receptor.

8.28. The emission rate obtained from this assessment was compared with the actual

annual emission rate for the Scheme (calculated using the emission factors described

earlier), and the increase in benzene ambient levels was estimated using simple

proportion.

Odours

8.29. To establish whether a fuel station equipped with Stage IB and II vapour recovery

(such as the Scheme) has the potential to cause odour impacts, a sniff test was

undertaken in the vicinity of another operational petrol station in Triq Buqana, Rabat.

This petrol station is equipped with Stage IB and II vapour recovery, and so would be

expected to generate similar odour emissions as the Scheme.

8.30. The sniff test was carried out at a distance from the petrol station that approximates

the distance of the nearest air sensitive receptor from the Scheme site, and close to

the site boundary of the petrol station; both locations were downwind of the petrol

station at the time of the survey. Details are given in Table 8.4; the odour survey

locations are shown in Figure 8.5.

Table 8.4: Odour Survey Details (operational petrol station)

Survey

Date Time

Location

(Figure 8.5) Description

23rd June

2017

12:45 – 12:55 A

Small road surrounded by agricultural land, close to an

agricultural building, and located approximately 250 m

east of the operational petrol station

13:13 – 13:22 B Agricultural land about 35 m east42 of the operational

petrol station boundary

8.31. During the test, records were made of the frequency, intensity, duration,

offensiveness and location of any odours, as well as the relevant weather conditions.

41 The graph shows a logarithmic scale. 42 It was not possible to do the survey at the eastern site boundary since this was not accessible.

207

Figure 8.5: Odour Survey Locations (operational petrol station)

209

DETERMINING IMPACT SIGNIFICANCE

Benzene

8.32. The significance criteria in Table 8.5 were used to assess the significance of impacts

arising from the Scheme on air quality. These have been calculated as proportions of

the limit value, as is common practice when other pollutants are assessed in EIAs.

Table 8.5: Criteria of Significance: Benzene Annual Levels

Baseline Annual

Levels of Benzene

Change in Annual Benzene Levels due to the Scheme

≥0.05 to <0.25 µg/m3 ≥0.25 to <0.5 µg/m3 ≥0.5 µg/m3

>5 µg/m3 Slight adverse Moderate adverse Substantial adverse

≥4.5 to <5 µg/m3 Slight adverse Moderate adverse Moderate adverse

≥3.75 to <4.5 µg/m3 Negligible Slight adverse Slight adverse

<3.75 µg/m3 Negligible Negligible Negligible

Odours

8.33. The mean odour intensity (Imean) and the percentage odour time tI≥4, i.e. the

percentage of samples where the odour strength was definitely recognisable by the

assessor (therefore having an odour intensity of 4 or more), were first calculated.

IAQM guidance states that when the mean odour intensity is 0, the odour effect can

be considered to be negligible; additionally, when the mean odour intensity is 1 but

tI≥4 is 0%, the odour effect can also be considered to be negligible. However, when

the odour levels exceed these thresholds, the odour effect is then calculated using

the odour exposure matrix for neutral and unpleasant odours in Table 8.643.

Table 8.6: Odour Exposure Matrix

Mean Odour

Intensity

Percentage Odour Time (tI≥4)

≤10% 11 to 20% 21 to 30% 31 to 40% ≥41%

6 Large Very large Very large Very large Very large

5 Medium Large Large Very large Very large

4 Small Medium Medium Large Large

3 Small Medium Medium Medium Medium

2 Small Small Medium Medium Medium

43 Based on IAQM (2014). The matrix would need to be adjusted for pleasant odours, since they cause less

annoyance at the same intensity as unpleasant / neutral odours.

210

1 Small Small Small NA NA

8.34. The odour exposure obtained from the above matrix is then used to assess odour

impact by using a matrix that classifies the odour effect at individual receptors

according to the receptor sensitivity (Table 8.7). As mentioned, residential

dwellings are classified as high sensitivity receptors.

Table 8.7: Matrix to Assess the Odour Effect at Receptors

Overall Odour

Exposure

Receptor Sensitivity

Low Medium High

Very large Substantial adverse Substantial adverse Substantial adverse

Large Moderate adverse Moderate adverse Substantial adverse

Medium Slight adverse Slight adverse Moderate adverse

Small Negligible Negligible Slight adverse

BASELINE AIR QUALITY

Benzene

8.35. ERA’s benzene data is summarised in Table 8.8.

Table 8.8: Benzene Baseline Data

Locality Diffusion Tube Code

(Figure 8.2)

Average Concentration

in 2016 (µg/m3)

Mqabba MQB 3 1.1

MQB 4 0.9

Kirkop KKP 1 1.0

KKP 2 0.7

Luqa LQA 5 1.0

Average 0.9 0.1

8.36. In the existing baseline scenario, all concentrations are well below the limit value of

5 µg/m3.

Odour

8.37. Weather conditions during the baseline odour survey, as measured / observed on

site, were as indicated in Table 8.9. Both monitoring locations were approximately

downwind of the Scheme site during the survey.

211

Table 8.9: Weather Conditions (baseline odour survey)

Date Survey

Location

Weather

Conditions Temperature Wind Direction

Wind

Speed

23rd June 2017

1 Sunny 28 oC NNE 1 m/s

2 Sunny,

minimal wind 31 oC N 0 m/s

8.38. The results of the baseline odour survey are presented in Table 8.10.

Table 8.10: Results of Baseline Odour Survey

Location

Nature

of

Odour

Frequency44

Odour

Intensity (I) 45 Duration

Percentage

Odour Time

(tI≥4)

Offensiveness Mean Max.

1 (outside

residence)

Manure 45% 2 5 Whiffs of a

few

seconds

each to

continuous

40% Unpleasant

2

(industrial

environs)

Vehicle

exhaust

2% 0 1 Whiff 0% Neutral

8.39. Using IAQM criteria, the above results indicate that in the baseline scenario:

The residential receptor experiences a medium odour exposure to manure, which is

considered to have a moderate adverse odour effect. However, considering that the

location is a rural one, the receptors are more likely to be accustomed to and

amenable to accepting such odours. Additionally, it is noted that such odours are

typically transient in nature, occurring in the days after manure spreading, and

therefore on other days the baseline odour effect could be lower.

The odour effect at the industrial surroundings close to the Scheme can be considered negligible, since the odour experienced (vehicle exhaust) had a mean

odour intensity of 0.

44 Monitoring was carried out over 5 minutes consisting of 30 ten-second intervals. The frequency was

calculated on the basis of whether the odour was noted during a particular interval. The results obtained by

the two assessors were then averaged. 45 On a scale of 0 (no odour) to 6 (extremely strong), as per Table 8.2.

212

ASSESSMENT OF IMPACT FROM THE SCHEME

Benzene

8.40. Multiplying the benzene emission factor of 0.118 g by an annual petrol throughput of

1,330 m3 and a TVP of 36.8 kPa gives emissions of benzene from the Scheme that

amount to 0.006 t (6 kg) annually.

8.41. From the nomogram in Figure 8.4, a distance of 250 m between the emission

source and the nearest air sensitive receptor corresponds to around 0.55 t of

benzene emissions. Therefore at this distance, if 0.55 t of benzene are emitted

annually, the benzene concentration at the sensitive receptor would increase by

around 0.22 µg/m3. By simple proportion, it is estimated that 0.006 t of benzene would result in an increase in benzene concentration at the sensitive receptor of

0.002 µg/m3. The predicted concentrations with the Scheme and resultant impact are

presented in Table 8.11. The results show that the impact of the Scheme

operations on benzene concentrations is negligible.

Table 8.11: Predicted Benzene Concentrations at Air Sensitive Receptor

Baseline Change with Scheme Baseline plus Scheme Impact

0.9 µg/m3 0.002 µg/m3 0.902 µg/m3 Negligible

Odours

8.42. Weather conditions during the odour survey in the vicinity of the operational fuel

service station were as indicated in Table 8.12. The activities underway at the

operational petrol station during the survey at location B were observed to include

vehicle refuelling and vehicle washing. Both monitoring locations were

approximately downwind of the Scheme site during the survey.

Table 8.12: Weather Conditions (survey at operational fuel station)

Date Survey

Location

Weather

Conditions Temperature Wind Direction

Wind

speed

23rd June

2017

A Sunny, mild

wind gusts 29 oC W 2 m/s

B Sunny, windy 29 oC W 4 m/s

8.43. The odour survey results at an existing operational fuel station (off-site) are

presented in Table 8.13. According to IAQM criteria, odour effects from the fuel

station are classified as negligible, since all odours noted (including soap / car wax

from the fuel station) had a mean odour intensity of 0. It is noted that fuel odours

were not observed during the survey.

213

8.44. Therefore the odour impacts from the Scheme on the odour sensitive receptors

considered in this study are expected to be negligible.

MITIGATION AND RESIDUAL IMPACTS

8.45. The design of the Scheme includes a number of measures to minimise emissions;

these have been described in detail in Chapter 3 and include Stage IB and II vapour

recovery systems.

8.46. Since these mitigation measures are expected to result in insignificant impacts on air

quality, no further mitigation is considered necessary, and the residual impacts would

remain as described in the previous section, negligible.

8.47. Impacts on air quality are summarised in Table 8.14.

FUTURE MONITORING REQUIREMENTS

8.48. No monitoring of air quality is recommended since the air quality assessment has

shown that emissions from the Scheme operations will have a negligible impact on

benzene concentrations and odours. The Applicant should ensure that vapour

recovery systems are maintained regularly in accordance with manufacturer

specifications and permit conditions applied to ensure their continued effective

operation.

214

Table 8.13: Results of Odour Survey (operational service station)

Location Nature of Odour Frequency Odour Intensity (I) 46

Duration Percentage Odour

Time (tI≥4) Offensiveness

Mean Max.

A

(agricultural

area around

250 m east of

the petrol

station)

Soil 3% 0 1 Continuous 0% Neutral

Vegetation 5% 0 3 Whiffs of a few seconds each 0% Pleasant / neutral

Canine faeces 3% 0 3 Whiffs of a few seconds each 0% Neutral

B

(agricultural

land close to

petrol station

boundary)

Vegetation 5% 0 3 Whiffs of a few seconds each 0% Neutral

Manure 3% 0 3 Whiffs of a few seconds each 0% Unpleasant /

neutral

Soap / car wax 8% 0 4 Whiffs of a few seconds each 5% Unpleasant /

neutral

Flowers 3% 0 4 Continuous 3% Pleasant

46 On a scale of 0 (no odour) to 6 (extremely strong), as per Table 8.2.

215

Table 8.14: Summary of Impacts on Air Quality

Predicted

Impact

Beneficial

/ Adverse

/ Neutral

Nature, scale and type of impact Probability

of Impact

Occurring

(Likely /

Unlikely /

Remote /

Uncertain)

Significance

of Impact

(Major /

Minor / Not

Significant)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major /

Minor / Not

Significant)

Const’n

/ Oper’n

Extent of

Impact

(Nat /

Local /

Site)

Direct /

Indirect

S-term /

L-term

Perm /

Temp

Revers /

Irrevers

Benzene

emissions

from Scheme

operation

Adverse Oper’n Local Direct L-term Perm Revers Likely Not significant None47 Not significant

Odour

emissions

from Scheme

operation

Adverse Oper’n Local Direct L-term Perm Revers Likely Not significant None47 Not significant

47 Stage IB & Stage II vapour recovery are included as part of the design.

217

9. SUMMARY OF KEY IMPACTS, INTERACTION

BETWEEN IMPACTS AND MITIGATION

INTRODUCTION

9.1. The purpose of this chapter is to provide a summary of the key environmental

impacts, their interaction and cumulative effects, and their mitigation. The chapter

addresses the requirements set out in the Terms of Reference (ToR) to describe

mitigation measures to “prevent, eliminate, reduce or offset (as relevant) the identified

significant adverse effects of the project” and to identify cumulative and residual impacts.

The chapter concludes with a summary of the mitigation measures proposed in the

Environmental Planning Statement (EPS) as well as a description of the required

authorisations.

SUMMARY OF KEY IMPACTS

9.2. Chapters 5 to 8 describe the predicted impacts of the Scheme in relation to geo-

environment, cultural heritage, landscape and visual amenity, and emissions to air, in

accordance with the environmental topic areas identified in the ToR.

9.3. For each predicted impact, an assessment has been made as to whether the impact is

likely to be of major or minor significance, or of no significance; the criteria that were

used to judge significance are described in each of the chapters. Predicted major and

minor impacts have been identified and, in the case of negative impacts, there is a description of how these could be mitigated. All the residual impacts identified are

summarised in Table 9.1 at the end of this Chapter.

9.4. Although the only potentially major impact relates to the impact on geo-environment

as a result of the excavation (the impact is minor to major because part of the site is

infilled), moderate impacts arose during the assessment with respect to the visual

amenity and landscape.

9.5. These impacts, relevant mitigation measures, and the residual impacts are discussed

hereunder.

Geo-environment

9.6. The impact on geological resources is considered to be of potentially minor to major

negative significance, since it will likely involve some extraction of mineral resources.

However, the geo-environment survey, as well as knowledge of the area, suggests

that at least part of the excavated material will be inert material, arising from the

filling in of a former quarry at the site. The extent of the infilling is unknown, hence

the impact is judged as being of minor to major significance, depending on the

amount of rock that will actually be excavated.

9.7. The Scheme is judged to have an impact of minor significance in relation to the use of

water resources, the quality of the groundwater and surface run-off, and the impact

218

on surface water drainage.

Cultural Heritage

9.8. There is the potential for impacts on cultural heritage arising from possible loss of, or

damage to, unrecorded archaeological artefacts during the remaining excavation to

be carried out. The extent of this impact is uncertain, as it will depend on whether

artefacts are present, their importance, and the extent of any loss or damage.

Landscape and Visual Amenity

9.9. The impact on landscape character is considered to be of moderate negative

significance in relation to the ‘South Airport Hinterland Character Area Local

Landscape Tract (LLT): Quarries’ and the ‘South Airport Hinterland Character Area

LLT: Agricultural Land’. The impact on the landscape character is considered to be

of minor negative significance in relation to the ‘South Airport Hinterland Character

Area (LLT): Settlements’

9.10. The impact on visual amenity is considered to be of minor to moderate significance in

relation to the view from the back road behind Triq il-Belt Valletta (which passes through site). The impact on views westwards from along Triq il-Belt Valletta is

considered to be of moderate significance, when approaching from Ħal Kirkop.

However, when approaching from l-Imqabba the impact is considered to be not

significant.

9.11. The EIA considered the impact on visual amenity from two other viewpoints –

looking northwards from along Triq il-Belt Valletta and looking northwards from

along Triq Danny Cremona, Ħal Kirkop. The photomontages indicate that the

Scheme will not be visible from these viewpoints.

Emissions to Air

9.12. The impact on air quality as a result of benzene emissions and odour emissions from

the operation of the Scheme is considered to be not significant. Notably, Stage IB

and Stage II vapour recovery are included as part of the Scheme design.

INTERACTION OF IMPACTS

9.13. The interaction of impacts with the current baseline is also described in Chapters 5

to 8. The interactions are summarised in Table 9.1 below. The interaction

between impacts describes the potential cumulative or reactive nature of the various

disturbances caused by the Scheme during construction and operation.

9.14. The fact that a row of mature pine trees will be removed to make way for the

Scheme will adversely affect the visual amenity of the site and its surroundings. In

addition, the ability of the trees to provide screening from dust will also be lost.

9.15. There were no major impacts identified from the Scheme during its operation.

219

CUMULATIVE IMPACTS

9.16. Cumulative impacts are those that result from incremental changes caused by other

past, present, or reasonably foreseeable actions together with the Scheme.

9.17. The various impacts identified in Chapters 5 to 8 were assessed in the context of

the existing baseline (encompassing the past and present context). No major

developments were noted to be underway in the immediate area of the Scheme site

during the baseline surveys, and there are no known committed major developments

in the area.

9.18. The Scheme involves development of the entire site and it is not planned as part of a

phased development, nor is it intended that there will be any further development on

the site once the Scheme has been constructed. Hence, it is likely that there will be

no consequential development on site because of the Scheme.

MITIGATION

9.19. The EPS, including its supporting Technical Appendices, reports the findings of the

EIA, in accordance with the ToR. Where appropriate, mitigation measures have been recommended; these are described at the end of each of Chapters 5 to 8 and

summarised in Table 9.1. It would be appropriate for, and it is recommended that,

these mitigation measures be taken account of in the conditions of any eventual

development permit.

REQUIRED AUTHORISATIONS

9.20. The required authorisations are referred to in the relevant topic area chapters

(Chapters 5 to 8). The Scheme will require an environmental permit / registration

from the Environment and Resources Authority (ERA), and potentially a license /

permit from the Regulator for Energy and Water Services (REWS) and the Malta

Resources Authority. Archaeological investigations / monitoring will require

authorisation from the Superintendence of Cultural Heritage.

221

Table 9.1: Summary of Impact Assessment

Predicted Impact

Beneficial/

Adverse

/Neutral


of Impact

Occurring

(Likely/

Unlikely/

Remote/

Uncertain)

Significance

of Impact

(Major/

Moderate/

Minor/Not

Significant)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major/

Moderate/

Minor/Not

Significant)

Constr’n

/Oper’n

Extent

of

Impact

(Nat/

Local

/Site)

Direct/

Indirect

S’term

/

L’term

Perm/

Temp

Revers/

Irrevers

Geo-environment

Mineral resources /

geological features Adverse Constr’n Local Direct

Long-


Minor to

major

significance

Re-use of

excavated rock

as fill material

Minor to

major

significance

Water resources Adverse Oper’n Local Direct Long-


Minor

significance

Collection of

water from the

canopy for re-

use;

Re-cycling of

water used in

the car wash

facilities

Minor

significance

Change in the

quality of ground

water


Oper’n Local Indirect

Short-

term /

Long-

term

Perm Irrevers Likely Minor

significance

Construction in

accordance

with industry

standards for

pollution

avoidance

CMP

Operational

management

practices to

monitor

performance of

Minor

significance

Change in the

surface water run-

off patterns



Minor

significance

Minor

significance

222

Predicted Impact

Beneficial/

Adverse

/Neutral


of Impact

Occurring

(Likely/

Unlikely/

Remote/

Uncertain)

Significance

of Impact

(Major/

Moderate/

Minor/Not

Significant)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major/

Moderate/

Minor/Not

Significant)

Constr’n

/Oper’n

Extent

of

Impact

(Nat/

Local

/Site)

Direct/

Indirect

S’term

/

L’term

Perm/

Temp

Revers/

Irrevers

pollution

control

measures.

Cultural Heritage

Loss or damage to

unrecorded

archaeological or

cultural heritage

artefacts on site

Adverse Constr’n Site Direct L-term Perm Irrevers Uncertain

Uncertain,

depending

on

whether

artefacts

are

present,

their level

of

importanc

e, and the

extent of

any loss or

damage

Archaeologic

al monitoring

during

excavation /

recording of

features /

salvaging of

significant

features, if

requested by

SCH

Uncertain

(depending

on whether

artefacts are

present, their

importance

and the

extent of any

loss or

damage)

Alteration or

degradation of the

structural integrity

and quality of the

setting of the rural

rooms close to the


Oper’n Local Direct L-term Perm Irrevers Likely

Not

significant to

minor

None

Not

significant to

minor

223

Predicted Impact

Beneficial/

Adverse

/Neutral


of Impact

Occurring

(Likely/

Unlikely/

Remote/

Uncertain)

Significance

of Impact

(Major/

Moderate/

Minor/Not

Significant)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major/

Moderate/

Minor/Not

Significant)

Constr’n

/Oper’n

Extent

of

Impact

(Nat/

Local

/Site)

Direct/

Indirect

S’term

/

L’term

Perm/

Temp

Revers/

Irrevers

Scheme Site

Landscape

Malta International

Airport Character

Area


significant

None Not

significant

South Airport

Hinterland

Character Area :

LLT: Settlements

Adverse Oper’n Local Direct L-term Perm Revers Likely Minor None Minor

South Airport

Hinterland

Character Area :

LLT: Quarries


South Airport

Hinterland

Character Area :

LLT: Agricultural

land


North Airport

Character Area

LLT: Settlements


significant

None Not

significant

North Airport

Character Area

LLT: Industrial

estate


significant

None Not

significant

North Airport Neutral Oper’n Local Direct L-term Perm Revers Likely Not None Not

224

Predicted Impact

Beneficial/

Adverse

/Neutral


of Impact

Occurring

(Likely/

Unlikely/

Remote/

Uncertain)

Significance

of Impact

(Major/

Moderate/

Minor/Not

Significant)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major/

Moderate/

Minor/Not

Significant)

Constr’n

/Oper’n

Extent

of

Impact

(Nat/

Local

/Site)

Direct/

Indirect

S’term

/

L’term

Perm/

Temp

Revers/

Irrevers

Character Area

LLT: Green belt

significant significant

Ħal Għaxaq – Il-

Gudja Hinterland

Area

LLT: Settlements


significant

None Not

significant

Visual Amenity

Viewpoint 1: Triq il-

Belt Valletta, L-

Imqabba

Adverse All Local Direct L-term Perm Revers Likely Moderate None Moderate

Viewpoint 2: Back

road behind Triq il-

Belt Valletta, L-

Imqabba (passes

through site)

Adverse All Local Direct L-term Perm Revers Likely Minor to

Moderate None

Minor to

Moderate


Belt Valletta, (route

to Iż-Żurrieq) N/A

Viewpoint 4: Triq

Danny Cremona,

Ħal Kirkop N/A


Belt Valletta, L-

Imqabba

Adverse All Local Direct L-term Perm Revers Likely Not

significant

None Not

significant

225

Predicted Impact

Beneficial/

Adverse

/Neutral


of Impact

Occurring

(Likely/

Unlikely/

Remote/

Uncertain)

Significance

of Impact

(Major/

Moderate/

Minor/Not

Significant)

Proposed

Mitigation

Measures

Significance

of Residual

Impact

(Major/

Moderate/

Minor/Not

Significant)

Constr’n

/Oper’n

Extent

of

Impact

(Nat/

Local

/Site)

Direct/

Indirect

S’term

/

L’term

Perm/

Temp

Revers/

Irrevers

Air quality

Benzene emissions

from Scheme

operation

Adverse Oper’n Local Direct L-term Perm Revers Likely Not

significant None48

Not

significant

Odour emissions

from Scheme

operation

Adverse Oper’n Local Direct L-term Perm Revers Likely Not

significant None48

Not

significant

48 Stage IB & Stage II vapour recovery are included as part of the design.