The Executive Chairperson Date: 14/09/2018 Planning Authority ERA Ref: EA 00050/18 St. Francis Ravelin, Floriana

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1 The Executive Chairperson Date: 14/09/2018 Planning Authority ERA Ref: EA 00050/18 St. Francis Ravelin, Floriana Dear Sir, Planning Ref.: PA 09890/17 Description Proposal: Proposed junction upgrading and road widening to existing roads and construction of new schemed road Location: Several streets including and adjoining, Triq l-imdina, Triq iz-zaghfran, Triq Tumas Chetcuti, Triq Ferdinandu Inglott, Triq Haz-Zebbug, Triq In-Nutar Zarb, Triq Il-Belt Valletta, Triq Oliver Agius, Vjal Ir-Royal Malta Artillery, Triq L- Intornjatur, Qrib Sant' Anton, Vjal De Paule, Attard, Malta Environmental Impact Assessment Regulations, 2017 (S.L ) Reference is made to the revised Project Description Statement (PDS), which was received by the ERA on 12 th September ERA s recommendation and representation on the said development proposal are being lodged in its capacity as an external consultee and an interested party in accordance with the Development Planning Act and the Development Planning (Procedure for Applications and their Determination) Regulations, 2016 (Legal Notice 162 of 2016). 1. Outline of proposal 1.1 PA 09890/17 is a planning application for the junction improvement and upgrading of pedestrian, cycle and public transport facilities along part of Route 7 of the TEN-T Comprehensive road network from Junction WA07 (junction of Triq l-imdina with Vjal ir-royal Malta Artillery) to Roundabout Node NA15, as well as the creation of a new road link, identified in the Central Malta Local Plan 2006 as the Attard By-pass (refer to Figure 1 and 2). 1.2 A stretch of the existing road network measuring approximately 4.3 km will be affected by the works whereas the new road section will be approximately 1.3 km. The land area to be affected by the project measures approximately 183,418 m 2, of which 134,673 m 2 (73%) of this are existing road network. The PDS states that an additional 17,291 m 2 of land may be temporarily used during the construction works to facilitate access to the construction site, where necessary.

2 1.3 The PDS outlines the following main interventions: - Widening of Triq l-imdina from Junction WA07 to just west of Junction WA08 (junction with Triq Oliver Agius) to provide for three lanes in each direction and the introduction of a 3 m bi-directional cycle track. The traffic light arrangement at Junction WA07 will be replaced (by a roundabout), and there will be a by-pass lane (two lanes wide) for vehicles approaching from Vjal ir-royal Malta Artillery. - Widening of Triq L-Imdina from just west of Junction WA10 (junction with Triq Tumas Chetcuti) to Node NA15, to convert this stretch into a dual carriageway with two lanes in either direction and the introduction of a 3 m bi-directional cycle track along the northern side of the road (up to the Ta Qali junction). - Creation of the new Attard By-pass, in the form of a westbound, two-lane single carriageway road. A local access road will be constructed along the same route, to cater for local traffic. A cycle path, will be constructed between the bypass and the service road. - Rearrangement of traffic flow along Triq In-Nutar Żarb, to accommodate one-direction traffic flow in an easterly direction, along a two-lane single carriageway with west-flowing traffic using the new by-pass. An eastbound cycle path is also proposed along Triq In-Nutar Żarb. 2. Site context 2.1 The proposal lies within the Attard, Balzan and Birkirkara Local Council administrative areas. Part of the proposal lies within the Rural Area (Outside Development Zone ODZ) the 1.5 km stretch of Triq L-Imdina from the junction with Triq il-ferrovija, at the edge of the Attard Development Zone, to the junction with Triq il-belt Valletta, on the interface of the Attard and Rabat Local Council administrative areas. The widening of these roads will also involve the take up of rural (ODZ) land. 2.2 The areas to the north and east of the proposal, which lie within the Development Zone, are characterised by predominantly residential development. The Mrieħel Industrial Area is located on the eastern corner of the site. The areas to the west and south of the proposal comprise predominantly agricultural land. The area is characterised by agriculture related activities and rural structures. The arable land under cultivation includes two vineyards - the Delicata Vineyard located to the north of Triq l-imdina to the west of the Attard Development Zone, and a smaller vineyard close to Node NA15, again on the northern side of Triq l-imdina. 2.3 The majority of the site lies within the 300 m Groundwater Safeguard Zone, with parts of the site lying within the 100 m buffer.

3 3. Site history This site has been the subject of the following development permit applications: PA 04841/99: Proposed traffic calming measures (Permit granted). PA 05822/03: Re-alignment of road from Targa Gap to Srina Roundabout including Mgarr Road, Mdina Road Attard and road to Saqqajja (Permit granted). Figure 1: Location of site (in blue). Source: PA Geoserver Figure 2: Location of site (in blue) Close-up. Source: PA Geoserver 2016.

4 Figure 3: Land Take for the Scheme (Attard Node NA15). (Source: PDS). Figure 4: Land Take for the Scheme (Attard). (Source: PDS).

5 Figure 5: Land Take for the Scheme (Attard). (Source: PDS). Figure 6: Land Take for the Scheme (Attard). (Source: PDS).

6 Figure 7: Land Take for the Scheme (Attard Junction WA09 and new road link). (Source: PDS). Figure 8: Land Take for the Scheme (Balzan Junction WA08). (Source: PDS).

7 Figure 9: Land Take for the Scheme (Birkirkara Junction WA07 and WA08). (Source: PDS).

8 4. EIA Screening (citations refer to S.L , except where otherwise specified): 4.1 The proposal falls under Schedule I, Category II, Section (Construction, excavation or realignment of roads, tunnels, viaducts or bridges, not covered by Category I, if located ODZ or at the edge of the development zone). 4.2 The following impacts exerted by the proposal have been identified. Type and characteristics of potential impact/s Land and Resource Use 4.3 The project will result in the permanent loss of approximately 60,000 m 2 of agricultural land, identified in the Central Malta Local Plan 2006 as an Agricultural Area and in the North West Local Plan 2006 as an Area of Agricultural Value (awaiting classification of agricualtural value). Further land will be lost if the additional land in the buffer area shown on the plans will also be committed. The tree survey prepared with the PDS identifies a total of 3,778 existing trees and shrubs out of which 402 trees will be uprooted. In this regard, compensatory plantings are being proposed based on the importance and age of the trees to be destroyed. 4.4 The project will involve the excavation of a substantial amount of rock and top soil, which totals to 171,160 m 3. Dust deposition from the construction works may also impact agricultural activity and productivity in the wider area, albeit this impact will also likely be temporary. Whereas, any extraction of mineral resources has an impact on geology and geomorphology. Nonetheless, the PDS states that it is envisaged to reuse the excavated material on-site and off-site as fill and aggregate and for landscaping. 4.5 The loss of soft ground cover and vegetation, and the increase in hard-surfacing (soil-sealing), is likely to exacerbate storm water runoff and reduce aquifer recharge. Cultural Heritage 4.6 The Grade 1 scheduled (through GN 013/06) Wignacourt Aqueduct runs along the northern perimeter of the site on Triq l-imdina. The proposal does not encroach within the buffer zone of the aqueduct as designated in CO 230/95 (Government Notice No. 13 of 2006), and there will be no works to the structure of the aqueduct. There is also the Grade 2 scheduled (through GN 522/12) Flora Mediterranja Villa which immediately overlooks the proposal site, as well as the Ħal-Warda Tombs Complex. The PDS identifies a number of buildings and structures which will be partly or wholly demolished. There is uncertainty over the impact on the rural buildings/structures and rubble walls to be demolished/removed to accommodate the proposal, where the cultural heritage significance of these features has yet to be determined.

9 Visual Amenity and Landscape Character 4.7 The project will result in modifications to the appearance and character of the landscape all along the proposed route, as well as in changes to the visual amenity afforded by the trees that will be lost to accommodate the development. The adjacent Areas of High Landscape Values (AHLV) of Mdina and Is-Saqqajja as scheduled through GN 348/01 and GN 1236/12, respectively, along with the rural character and amenity of the western portion of the proposed project, are of concern with regards to the envisaged impacts on the landscape character. Air Quality 4.8 The implications for air quality as a result of traffic emissions are uncertain and potentially variable; there will be localised changes of different magnitude and significance depending on the location along the route, the location of the sensitive receptors, and the changes in vegetation cover. The project envisages constructing the by-pass at a lower level than the sensitive receptors, separating the by-pass from the local access road by constructing cycle paths in between the two, and planting trees bordering the cycle route and on the outer edge of the by-pass. Noise and Vibrations 4.9 Similarly, the implications for traffic noise are also uncertain with regards to the operational phase. Nonetheless,the planned construction of the by-pass at a lower level than the existing road will serve to mitigate the increased traffic noise. Moreover, the removal of the traffic bottlenecks during operation, has the potential to reduce noise emissions arising from revving engines from static and slow moving vehicles; however, an increase in traffic speed, and where additional vehicular traffic is likely to be attracted along the route, has the potential to increase traffic noise emissions at these locations. On the other hand, the noise impacts during the construction phase are envisaged to be significant given the construction phase is of 18 months and a large number of machinery and equipment is being proposed to be used.

10 5. ERA Conclusion EIA screening conclusion 5.1 In light of the above, the proposed development requires an EIA as per Schedule I, Category II, Section of the EIA Regulations, 2017 (S.L ). The EIA would need to address the following environmental issues: Land-use and loss of agricultural land; Air quality from the increase in traffic; Noise during construction and operation; Ecology, including the uprooting of trees; Geology, geomorphology and hydrology; Cultural heritage; and Landscape and visual amenity. 5.2 The applicant has been informed accordingly and further processing of the planning application should await the outcome of the EIA. Environmental permitting requirements 5.3 A Nature Permit under S.L is required given a considerable number of trees are protected and will be removed from site. Yours faithfully, Ryan Busuttil Environmental Protection Officer f/director Environment & Resources Disclaimer The above screening results, the ensuing conclusions and recommendations are without prejudice to any required changes or updates should the development proposal be eventually modified or should the information/assumptions provided turn out to be incorrect. Any deviations of the proposal from this submission would need to be re-assessed and the merits of this screening would need to be re-opened.