Letter Of Objection - Tal-Papa Farm, B'Bugia
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I would like to object to the inclusion of the Tal-Papa area in the Birzebbugia development scheme as this is a prime site of great agricultural and heritage value. This farmland is a unique site; the farmhouse itself is not just an outstanding example of vernacular architecture, but it is mentioned in a 1517 contract that pre-dates the knights and other C16 documents. Although the Development Brief calls for the conservation of the farmhouse, this is not enough as an ancient threshing-floor as well as protected carob and olive trees and other ancient trees are to be found on its grounds. Many of these trees will have to be destroyed in order to accommodate the planned residential project. Although the plans provide for a 6-metre buffer zone, surrounding the farmhouse by three-floor houses will completely destroy its character, while excavations of foundations for surrounding basement garages, will further harm the precarious state of this building. Alongside the farmhouse lies the 'tal-Papa Field'; around a century ago it was laboriously quarried by hand applying ancient techniques of grooving and wedge splitting to hew out stone for neighbouring houses. Re-laying the soil created a sunken field sheltered from wind and scorching sun, perfect for its 150 mature fruit trees. To this day, much of the farming is still carried out using traditional methods and an impressive water collection system. Run-off rain water streams down the sides of the quarry and is caught by stone gutters carved into the rock walls to channel the water into the shelters. Thanks to its large main reservoir and shelters which have been converted for extra water storage, the 'Qalgha tal-Papa' is assured a constant supply of water which permits a year-round harvest of vegetables and fruit. The tal-Papa farm is also a haven of ecological bio-diversity, hosting protected trees such as olive, carob, pomegranate, chaste berry (sigret il-vireg), hawthorn (anzalora), laurel, and Sandarac Tree (sigra ta' l-Gharghar) which are protected under Legal Notice 12, 2001. These trees are flourishing in their present site in a way that the 'replacement or compensatory planting' mentioned in the Development Brief cannot guarantee. Besides different species of birds and reptiles, the shelters are home to endemic painted frogs and rare bats, both of which are protected under the EC Habitats Directive (1992), for which reason this case, Petition No. 450/2007, is being studied closely by the EU Environment Commission. The six WWII shelters carved into the rock-face of the field are also protected by our Cultural Heritage Act, and give an insight into Malta's wartime history. The tal-Papa farm not only offers a unique insight to our agricultural heritage and history, but is also a testimony to the resourcefulness of our ancestors and their attention to sustainability. Given its great potential, this site should never be built up but preserved as an agro-tourism project. In fact, preparations for an EU-funded agro-tourism project on this farm have already commenced, while it is hoped that the neighbouring farmhouse could be restored and serve as an agricultural heritage museum and nature park, while also serving as a cultural centre and tourist attraction. More rock-cut chambers of ancient origin are to be found close to the tal-Papa farm. These chambers have never been properly studied as they need to be; due to their proximity to the tal-Papa could easily be integrated within a heritage site including all three sites. Furthermore, this site cannot be considered a pocket area under the Rationalisation regulations, as it is flanked by fields on three sides and a road on the fourth. It is to be noted that Birzebbugia has over 1,000 vacant dwellings and other empty sites which can be used for residential development. As such, I feel that the building up of this site, a unique showcase of agricultural heritage and history, contradicts the Development Brief's objective: - "To encourage, where relevant, upgrading of cultural assets and infrastructure with valorization of cultural features present in the area." - To promote environment and infrastructural improvements and heritage protection. I also object to the fact that: - The land is owned by the Joint Office and as such only be used for social purposes. Its zoning as a 'Residential Area' does not fulfil this requirement. - This site was included within the Development Zones through the Marsaxlokk Bay Local Plan and the Rationalisation process however they both fail to conform to EU norms on public consultation or adherence to the Strategic Environment Assessment Directive. As such both processes are under investigation by the EU Environment Commission and are the subject of an ongoing court case. Any steps leading to the development of this land would be a breach of these processes. Birzebbugia and its residents have already suffered enough environmentally due to the gas plant, the Enemalta fuel storage tanks, the noise caused by the Freeport and the airport fly-path, as well as being deprived of the use of a beautiful beach by the pollution of the Freeport. Birzebbugia has also lost other ancient farmhouses and the 'Carthaginian Tower' due to neglect and damage from nearby building activity. The Tal-Papa farm and its surrounding fields are an important part of Birzebbugia's history and identity. The building up of the fields would destroy the area and violate MEPA's very own mission statement that: "We should carefully plan so that our heritage, this gem which we treasure, will not fade away". It would also contravene our agricultural policy, rendering us more dependent on imported foodstuffs, and would be a betrayal of Malta's environmental, heritage and tourism policies and therefore should not be considered on any account. Kindly confirm reciept of this email. Sincere regards,
