The Interdiocesan Environment Commission (KA) in a statement on Thursday, said that “in the absence of published studies on the alternatives, the Gozo tunnel is not justified.”

The KA noted that that the Government has issued a call so that an entity is chosen to build and operate a tunnel between Malta and Gozo.

It went on to say that it is disappointed that the Government has not yet published all the studies that have been carried out on this project, “and more importantly, without implementing long-promised alternatives to improve accessibility between the Islands.”

The KA has today issued a report regarding the proposed Malta-Gozo tunnel which is shown in full below:

“The KA expressed its opinion on this issue on various occasions including in October 2013, May 2017 and March 2019. The KA would like to express once again its opinion on the subject.

The need for the publication of serious analyses and studies of all alternatives for better accessibility The KA believes that there exists no sound and reliable information in the public domain which could help one make a good analysis of the possible alternatives which would truly improve accessibility between the Islands.

The KA expects that a Cost-Benefit Analysis (CBA) of the various alternative options to the tunnel for vehicular transit is carried out and published in its entirety.

These options include a fast ferry service, an additional ship for Gozo Channel line, a completely new fleet for Gozo Channel Co. Ltd and an underground rail system (as suggested by the Gozo Tourism Association), which would form part of a national system of mass transit for the Maltese Islands.

The tunnel is being presented as the sole solution for improved accessibility. The strategy to present a project as the sole solution to address a particular issue was used years ago when it was declared that golf courses were indispensable for the future of Malta’s tourism industry and therefore for the economy in general.

These projects did not materialise, time passed and the disasters that were forecast to befall the tourism industry and the Maltese economy did not occur.

Addition of a fourth Gozo Channel vessel, fast ferry service and helicopter service

In spite of past promises, the permanent addition of a fourth vessel to the Gozo Channel fleet and a fast ferry service are, as yet, unfulfilled. The introduction of a fourth vessel in the last months helped in improving the service.

The vessel has been leased for a definite period until an international call is issued to procure a vessel on a permanent basis. Months have passed since such news and the international call has not yet been issued.

The KA is disappointed that the current fourth vessel that has been leased is not accessible to all, in spite of promises made that the vessel was to be withdrawn from service for some time to improve its accessibility.

It is unacceptable that persons with a disability, elderly people who cannot make use of stairs and those who suffer from asthma, are presented with the choice of either making the trip in the car deck below or to wait for the next service operated by one of the other vessels.

The KA expected that the authorities, especially those responsible for safeguarding the rights of such persons, would insist that the vessel would be accessible to everybody and that nobody would be considered as a second-class citizen.

In the absence of an improvement in the service for all and/or the introduction of new services which do not require a hefty capital expenditure when compared to a tunnel, a stronger case is made for a tunnel as the only solution to improve accessibility between the islands.

The KA notes that two other promises, namely a fast ferry service and a helicopter service have not materialised. It is strange that both in the case of the call for tenders for a fast ferry service and the helicopter service, the process was stalled on the basis of objections on the grounds that either the final decision or the tender documents were discriminatory or appeared to give advantage to particular commercial interests.

One would have expected that the preparation of the tender documents or the decision-making process following the call for tenders would be of the highest governance standards. In the meantime, after years of waiting, there is no news about the fast ferry service.

With the tunnel project what would become of Gozo Channel Co. Ltd?

With or without the tunnel, there would still be a need for a ferry service between Malta and Gozo for various reasons including touristic ones. But above all, such a service would be required if an emergency crops up.

The KA asks: if the tunnel becomes a reality what would become of Gozo Channel Co. Ltd and its Public Service Obligation (PSO) Would the company still be allowed to be supported by public funds? Would it be in a position to replace its current fleet?

Charges for accessibility services

The KA reiterates what it said about the subject in October 2013 and March 2019, namely that for a mature decision to be taken on the final project, the charges that would be imposed for using any accessibility service (under the different alternatives) have to be carefully studied and made public.

The Government seems to be choosing the tunnel alternative without publishing the evaluations that have been carried out on the charges that would be imposed under the various alternatives. The charges are going to be negotiated with the selected bidder at the end of the process.

In the meantime, the Infrastructure Minister announced that even with the current traffic volumes, the tunnel project is feasible. The KA therefore invites the Government to publish in full the tunnel feasibility report that it possesses.

Economic, environmental, social and cultural impacts of the various options on Gozo

These impacts deserve to be carefully studied. A tunnel may cause Gozo to lose the beauty of its characteristic landscape, just as is happening in various Maltese localities.

One must also identify the impacts on the communities who have occupied the areas where the entrance and exit to the proposed tunnel will be located (L-Gherien, L-Imbordin and Manikata).

To have a project which ignores the interests of small communities, even when these are a testimony to the richness of our history and culture, poses a danger to every small community in Malta and Gozo that endeavours to safeguard the unique cultural heritage of our islands.

In these circumstances, the KA asks: What studies have been carried out on the impacts of the tunnel on domestic tourism? What would the impact be on the owners of farmhouses/tourist apartments in Gozo? If, according to media reports, the Gozitan economy grew at a higher rate than Malta even without the tunnel, what then is the added value of the tunnel project to Gozo? How was the environmental impact of this project measured?

The highest standards in the process of choosing the best option for improved accessibility

Every accessibility project between Malta and Gozo has to enjoy the highest standards of transparency, value for money, trustworthy competition between all interested parties, and should be sustainable in the environmental, social and economic aspects, without creating more problems than it expects to solve.

Therefore, as it has done in March 2019, the KA repeats its appeal to the Planning Authority, the Environmental Resources Authority (ERA), the Strategic Environment Assessment Focal Point and Transport Malta, to ensure that the Environmental Impact Assessment and the Strategic Environment Assessment Directives be strictly adhered to.

The KA appeals to the Department of Contracts and to the Auditor General to ensure that the procedure for the choice of the option or number of options for better accessibility between the islands will truly be above board and one that give good value for money for the development of Gozo.

The amount of material that would be excavated because of the tunnel would be of an unprecedented scale. One hopes that the decision on the option chosen for better accessibility across the channel would not be influenced by the interests of whoever sees personal gain from land reclamation.

At the same time, the problem of where to store this resource, or where it would be dumped for reclamation purposes, should not be delegated to ERA without this authority being satisfied that all studies of the alternatives to a tunnel have been made and that the reasons why these alternatives were discarded are valid. ERA must insist that it needs to be convinced that the best option for improved accessibility between the islands is a tunnel and not any other alternative.

Arguments put forward without being substantiated by evidence which is published

The Government has again stated (without publishing any studies to substantiate its claim) that for an underground or railway system to be viable, the population on Gozo would have to increase. The increase in population which has now been quoted is that of 120,000.

The KA invites the Government to publish the study that substantiates this claim. Even if this argument is a valid one if taken in isolation, then with the same logic various localities in Malta and Gozo cannot be served by gas distributors or public transport since such routes on their own would not be feasible.

The point has also been made that the tunnel was an electoral promise and therefore there is mandate that this project takes place. The KA would like to make the point that such an electoral promise was made in the absence of all the necessary studies having been carried out and those that were undertaken not being published.

Good governance requires that such an important decision be taken after a national scrutiny of all studies carried out so that it can be established whether a tunnel should be the solution for improved accessibility.

Conclusion

When one considers how to improve accessibility between Malta and Gozo, transparency in the way decisions are taken, based on rigorous studies of all alternatives, is crucial so that the negative impacts of the final decision are minimal and the socio-economic gain is the desired one.

Transparency in all processes is crucial for the final option chosen to be implemented is a serious one and is sustainable from all angles.

The KA insists that such transparency should include the publication of all studies that have been carried out on all alternatives and how each alternative is better or worse than another, both from an environmental point of view as well as from a socio-economic standpoint.

The KA notes with satisfaction, speeches that indicate Government’s commitment towards sustainable development.

However, the KA reminds Government that the environment in the Maltese Islands is already compromised in various areas due to unrestrained development which does not look beyond the very short-term interests of the so-called “developer” and which takes place in the name of “balance.”

The environment has to be safeguarded more than ever before, otherwise people’s quality of life which is derived from a healthy environment will continue to be negatively affected both immediately and in the future.

If one is not careful, the Malta-Gozo tunnel can be a case where Government would have wholeheartedly relied on one accessibility alternative.

In this way, it would have adopted a ‘tunnel vision’ that would put it in a weak position when negotiating with a contractor of such a project, with the environmental and socio-economic consequences being suffered by present and future generations of Maltese and Gozitans.”

Photo by Alain Salvary

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