[ANALYSIS] Six reasons the debate on the Gozo tunnel has not even started

1. Surveys show overwhelming support for a tunnel connection but discussion over the past 10 years has not been informed by studies

The idea of a tunnel connecting Malta and Gozo was resurrected in the final years of the Gonzi administration probably as a way of galvanising declining support in the sister island.

For a short while, the newly elected Labour government toyed with a bridge constructed with Chinese help, but subsequently continued with geological studies on the proposed tunnel. But these studies have been kept under wraps.

The only study which has been published so far was a feasibility study authored by Gordon Cordina, commissioned the Gozo Business Chamber in 2015, which concluded that the project is economically feasible. The Environment Impact Assessment is still being conducted. Therefore, while decisions have been informed by studies, the national debate was not.

2. The financing of the project remains a mystery

When first proposed in 2011 the tunnel was costed at €150 million. The study carried out by Cordina in 2015 concluded that a tunnel costing €200 million would be viable, with a €10 fare in each direction.

But on Sunday MaltaToday revealed that with costs expected to hit the €300 million mark the government is considering stepping in and contributing millions in taxpayers’ cash to make up for the projected shortfall in toll fare revenues for the Gozo tunnel. The impression given so far was that a private company will recoup the infrastructural costs from tolls. Will the public still support the project if turns out that the government will have to fork taxpayer’s money to render it feasible?

3. It increasingly looks that the tunnel project would make land reclamation inevitable. The wider environmental impacts of the project still have to be assessed

An Environment Impact Assessment is being carried out to assess the impact of the Gozo tunnel. But a site-specific EIA may not be enough to asses the wider environmental implications of such a project, including its impact on the national waste policy.

In a screening report, the Environment and Resources Authority has already warned that the generation of one million tonnes of waste for the construction of the Gozo tunnel proposal is set to aggravate Malta’s limited space to take in waste, a move that will likely lead to greater pressure for land reclamation.

Neither does it make any sense to approve such a project before any decision is made on how the extra waste gets disposed of. We may well end up with a domino effect, with the approval of the tunnel setting in motion other environmentally questionable projects.

One way to assess these wider environmental impacts would be through a Strategic Environment Assessment, a requirement by EU law for any plan or programme which has a direct impact on the environment, particularly on protected habitats.

4. Everyone agrees that Gozitans deserve a faster and more reliable connection to Malta. But should we assess the pros and cons of the different options available before opting for a tunnel?

A Strategic Environmental Assessment (SEA) could be widened to also assess the environmental impact of different options aimed to improving connectivity between the two islands.

For example, although a bridge may have unacceptable visual impacts, it will require less excavations and therefore produce less construction waste. Restricting the tunnel to public transport may reduce one of the project’s most negative impacts: that of increasing car traffic in Gozo itself.

Neither has anyone assessed whether the aim of improving connectivity between the islands can be achieved through an improvement of maritime connections through a fast ferry service, which would have no impact in terms of construction waste and the disturbance of protected habitats.

5. The Gozo tunnel discussion may be premature in view of decisions which need to be taken with regards to a national mass transit system

Replying to questions by MaltaToday, the Transport Ministry has already hinted that the tunnel infrastructure will probably not accommodate a mass transit connection between the two islands. This raises the question: does it make sense to assess the Gozo tunnel in the absence of a wider discussion on a national mass transit system?

Would it make sense to improve connectivity for those using private cars before ensuring a fast connection for commuters between the two islands who are using the public transport network?

Sure enough, restricting the tunnel to a public transport option may have its drawbacks; it may be not even be financially viable as it would deprive the operators of their main source of income: tolls paid by drivers. Yet this cost may well be factored in the financial feasibility of a national metro system.

Another option would be that of infrastructural works which allow for a combination of private transport lanes and another lane which could be integrated in a mass transit system at some future date. But this option may well result in more extensive excavations in sensitive areas (including a larger entrance at Pwales and Ta’ Kenuna) and the creation of even more construction waste.

Moreover, while the proposed Imbordin route may help to alleviate traffic on the Xemxija junction, other bottlenecks may be created in other areas in Malta and Gozo.

6. A final decision on whether a permit for the tunnel is issued or not has still to be taken by the Planning Authority’s board

Mercieca’s declaration suggests that the Planning Authority’s board approval of the project is automatic, reducing the planning process to a rubber-stamping exercise. The advice of the Superintendence for Cultural Heritage and the Environment and Resources Authority should also be crucial.

Archaeologist Dr Keith Buhagiar has recently warned that the excavation of the tunnel entrance on the Malta-side portal, in the hamlet of l-Imbordin, may destroy troglodyte dwellings dating back to the late medieval period. If that remains the case the PA will also be expected to heed the advice of the Superintendence for Cultural Heritage.

Preliminary studies also show that the proposed tunnel will be excavated underneath the Ghadira reserve and major road cuttings are also envisaged to take place behind the hinterland of the Simar reserve.

Birdlife has expressed concern on the impact of the estimated traffic increase of 6,000 to 7,000 vehicles daily passing by the buffer zone of the Simar reserve through the Pwales Valley.

ERA has also expressed concern the construction of the proposed tunnel portals and its ancillary connections to the existing or realigned road network, is likely to be significant in terms of land use.