Minerals Summary of Public Consultation

MINERALS SUBJECT PLAN
SUMMARY OF
PUBLIC
CONSULTATION
PLANNING AUTHORITY
February 2002
CONTENTS
Page
PART 1:
PART 2:
PUBLIC CONSULTATION AND PUBLICITY

Aim
Public Participation - Approach
Summary of Public Consultation
Major Changes in Public Consultation Draft Written Statement
3
3
4
5
SUMMARY APPRAISAL OF MAIN COMMENTS
Summary of Response on:
11
Consultation Draft
Part A:
Background
Section
1 The Need for a Minerals Subject Plan
Section
2 Purpose and Scope of the Plan
Section
3 Objectives, Methodology and Land Use Strategy
11
11
11
11
12
Part B
Section
Section
Section
Section
Current Context
4 The Minerals Industry
5 Minerals and the Economy: Demand and Supply
6 Minerals and the Environment
7 An Analysis of the Existing Policy and Regulatory
Framework
14
14
14
16
17
Part C
Section
Section
Section
Section
Policies
8 Hardstone and Softstone Policies
9 General Development Control policies
10 Reclamation
11 Other Minerals
18
18
34
45
51
Part D
Section
Conclusions, Recommendations and Implementation

12 Conclusions, Recommendations and Implementation
54
54
APPENDIX
REVIEW OF THE STRUCTURE PLAN POLICIES
56
APPENDIX
MINERALS SUBJECT PLAN POLICIES
56
Supplementary Documentation
Annex 1
Permitted Boundaries For Mineral Workings In Malta And Gozo
Annex 2
Minerals Production Estimate
Annex 3
Code of Practice For Mineral Workings and Restoration
56
56
57
60
APPENDIX 1
Minerals Subject Plan Consultation List
63
APPENDIX 2
Reference List To Summary Of Response
71
APPENDIX 3
Publicity
73
PART 1:
PUBLIC CONSULTATION AND PUBLICITY
Aim
1.1
This report is a summary of the public consultation and publicity on the Draft
Minerals Subject Plan. It has been prepared to meet planning requirements
with respect to the minerals industry.(section 24 of the Development
Planning Act) and in conjunction with the ongoing Structure Plan review.
1.2
The Consultants together with the Planning Authority, submit that this
statement shows:1.
That earlier studies leading to the preparation of the Plan
have been adequately publicised (e.g. Environmental
Appraisal of Quarries; Mineral Resource Assessment,
etc.)
2.
That sufficient opportunity has been given for
representations to be made by the public and other
organisations
3.
That steps were taken to consult with, and consider the
views of other persons.
Public Participation and Consultation - Approach
1.3
A three pronged approach was adopted, consisting of consultation prior to

preparation of the consultation draft, on-going consultation during the
preparation of the draft and publicity and consultation on the actual draft.
1.4
The three main stages of publicity were:
1.
Inception Meetings (May August 1999)

These had the purpose of providing an overview of the
envisaged approach to the study indicating the various areas to
be addressed by the Plan. Views were sought either in the
meetings themselves or as a follow up to same.
2.
Ongoing Consultation
On the 2nd June 1999 the Planning Authority advertised that a
contract had been signed with consultants for the preparation of
a Minerals Subject Plan. The project was concurrently launched
at a press conference. From this point onwards and up to the
launching of the Public Consultation Draft, the areas addressed
by the Plan took into consideration any feedback received
throughout the plan preparation period.
3.
Public consultation Draft

On the 14th June 2001 the Planning Authority authorized the
publication of the Minerals Subject Plan Public Consultation
Draft for the purpose of consultation as required by the
Development Planning Act. The Public Consultation Draft was
launched on the 22nd August 2001, in the process of a
presentation to representatives of the press, attended by the
Chairman Planning Authority, the Chairman Development
Control commission, the Director of Planning, Assistant
Director for Forward Planning and Environmental Management
Unit representatives. Concurrently the full text of the
consultation document was placed on the Planning Authority
Website. Copies of the Public Consultation Draft were sent to
public libraries (Malta and Gozo) a number of Local Councils,
Planning Authority Boards/ committee members, Minerals
Resource Authority, Ministry For the Environment, House of
Representatives, University of Malta, Ministry For Gozo, NGOs
and various other members of the public. Public Consultation
Meetings were held in Malta and Gozo shortly after the
launching of the draft Plan. These meetings were subsequently
followed by a number of technical meetings directly with
members of the local minerals industry. Written comments were
invited to be submitted by the 19th October 2001. Even so,
consideration was also given to written submissions submitted
as late as the end of November 2001.
1.5
Consultation involved Government Departments; Parastatal organizations;

Unions; Employers and Professional Organisations; Local Councils; other
Bodies and Organisations; NGOs and private individuals. A full consultation
list is available at Appendix 1.
Summary of Public Consultation
1.6
Part 2 of this report includes a synopsis of all interventions made during the
public meetings and of a number of written submissions. Of note is the
feedback acquired in the process of a number of technical meetings with
members of the minerals industry. The overall view of the issues raised has
been taken into consideration in necessary revisions to the Subject Plan.
1.7
An appropriate evaluation of the submissions required that the presentation

be in the adopted format, and a faithful interpretation of the points raised has
been achieved through the summaries of the representations made. A reading
of the summaries and responses require continuous reference to the
consultation draft of the Minerals Subject Plan.
Major Changes to the Minerals Subject Plan Public Consultation Draft

1.8
As a result of this consultation process a number of amendments were made

to the Plan. The major changes are listed hereunder. All references to
paragraphs and policy numbers refer to the final draft of the Plan.
In view of the many conflicting interests involved, observations made on the
draft Plan were considered thoroughly and a compromise was reached on a
number of issues. The subject content, nature and validity of the arguments
put forward constituted the grounds for the considerations made rather than
the frequency with which specific issues figured. On the weight of
opinions/comments received, a number of draft policies warranted further
consideration.
Section
Nature of Changes
Executive Summary para.

2, line 3
Included reference to other minerals, in particular phosphate

and salt
Executive Summary para.

8, line 2
Replaced lines 2 to 6 with new text conforming to the Solid

Waste Management Strategy and ways in which the Plan
proposes to support and compliment the said strategy.1
Part A; Chap 1, para. 1.2,

line 5
Included reference to other minerals
Part A; Chap 1, para. 1.7,
Included new para. 1.7 on salt production in Malta
Part A; Chap 1, para. 1.8
Para 1.7 replaced by para. 1.8 with minor amendments to text
Part A; Chap 1, under

contents part D
Added text re actions required to implement the Plan
Part B; Chap. 4, point 4.4,

p13
The term non-porous was replaced by scarcely porous
Part B; Chap. 4, pp 16 -19
Updated statistics in tables 4.1 through 4.4
Part B; Chap. 5, p 33 para.

5.43, line 8.
Now on p 34 and included information from the Solid Waste

Management Strategy
Part B; Chap. 5, para. 5.48

p 34
Omitted and replaced by 5.48, p35, including revised figures for

achievable targets for reduction in C&D waste generation and
inert waste diversion based on the Waste Management
Strategy.
Part B; Chap. 5, para. 5.48

p 34
Omitted and replaced by 5.48, p35, including revised figures for

achievable targets for reduction in C&D waste generation and
inert waste diversion based on the Waste Management
Strategy.
= changes derived from internal consultation
Part B; Chap. 5, p 34,

Table 5.10
Table Deleted from Plan
Part B; Chap. 6, para. 6.49,

pp 47-48
Content in point 6.49 includes a brief explanation of

mechanism of water percolation through rock.
Part B; Chap. 7, pp 57
Included additional para. 7.20, reference Malta Resources

Authority
Part B; Chap. 7, para 7.21,

pp 56
Now on p 57. Added reference to amendments in 2001 to the

Development Planning Act, 1992.
Part B; Chap 7, para. 7.26,

p 58
Added new para. with reference to Section 55 of amendments to

the Act 2001

p 58
Modified text of original para. 7.34 (now 7.36, p 59) with

reference to Environmental Impact Assessment Regulations
2001.

p 58
Deleted text from original para. 7.35 (now 7.37, p 59)

p 59
Replaced by para. 7.41, p 60 and includes a reference to the

status of hardstone quarries with respect to dwellings

p 59
Replaced by para. 7.42, p 60 and includes changes to the

original content

p 63
Replaced by para. 7.62, p 64 and includes a reference to sec. 55

of the amended Act, 2001 with respect to reduction of the
impact from operational or abandoned quarry sites.

p 63
Replaced by para 7.65, p 65 and includes a reference to the

Malta Resources Authority
Part C; Chap. 8, HS6, p 7
The word permitted in line 2 of policy HS6 has been replaced

by required.
Part C; Chap 8, para. 8.22,

p 73
Included update on construction and demolition waste arisings

derived from the Waste Management Strategy.

p 73
Para. 8.23, has been omitted and replaced by new para. 8.23 re
impact of disposal of inert wastes at Maghtab and the need for
reduction and resovery as set out in the Waste Management
Strategy.

p 73
Entire para. has been omitted.
Part C; Chap 8, HS7, p 74
Now on p 75 and omitting section referring to targets for

landfill diversion of inert wastes.
(Part C; Chap. 8,
Alternative Supplies p 72
A reference to offshore dredging has been included (para. 8.33,

p 76) in the Plan as well as an additional policy HS10 as
the
Alternative Supplies p 72
p 76) in the Plan as well as an additional policy HS10 as

follows: Following a detailed investigation of existing
resources, the Planning Authority will consider proposals for
dredging/winning of sand, gravel and other sea-bed minerals,
except where such development would have significant adverse
effects on marine ecology or the environment .
Part C; Chap. 9 General
Made minor amendments to supporting text throughout chapter.
Part C; Chap. 9, DC1, p

77
Included new para. 9.4 in p 78, relating to regulation of

unconsented quarrying and highlighting the purpose of policy
DC1.
Part C; Chap. 9, p 86
Included new para. 9.36 re requirement for baseline noise

surveys as part of EIA requirements for quarrying proposals.

86
Plan has been updated accordingly to include a lower

maximum level of 55dB LAeq(1 hour) in close proximity to third
party sensitive property. Otherwise a maximum value of 60 dB
LAeq(1 hour) will be adopted.
Part C; Chap 9, DC18, p87
An additional bullet point has been included to cater for the

requirement or otherwise to cover or superficially consolidate
aggregate heaps.

89
The Plan includes a recommendation for the drawing up of

action plans by Local Plans, especially where it can be
identified that mineral workings are conducive to significant
impact on the landscape character or areas and/or the amenity of
residents.
Part C; Chap. 10, General
Made minor amendments to supporting text throughout chapter.

11.1 last line
Text no wells are envisaged in the immediate future has been

replaced by a well is envisaged in the immediate future.
(Part C; Chap. 11, p 101

11.2 last sentence)
Text Exploration activity ......... and 1980s has been replaced

by Exploration is an ongoing activity

11.3
Text over a period of 6 years has been changed to between

1 and 1.5 years

11.7)
Added Production contracts have a term of 30 years or more
Part C; Chap. 11, pp 101102
Included a section under Salt briefly describing process and

related land-use implications
Part D; Chap. 12, p 107,

General
Chapter heading changed to Implementation and contents of

chapter relating to other areas figuring under the original
heading omitted. The original structure of this section was
retained, subject to minor amendments.
Part D; Chap. 13, General
This new chapter under the heading Conclusions and

Recommendations (p 113) covers areas under same headings
originally forming part of chapter 12. The original structure of
this section was retained, subject to minor amendments.
Appendix B p 2
Included new policy HS10
Appendix C
Appendix D
A list of references(bibliography) sources was included in an

appendix to the Final Report of the Plan
Supplementary Doc.,
Annex 3, Item 3.4, p 17
Reference to EU Directive 91/692/EEC has been replaced by

EU Directive 1999/31/EC
Supplementary Doc.
Annex 1, Hardstone
Quarry boundaries
Text in plan HM19 in the Supplementary Documentation was

changed from UC to LC
Supplementary Doc.
Annex 1, Hardstone
Quarry boundaries
Text in plan HM13A in the Supplementary Documentation was

changed from LC to UC
Supplimentary Doc.
Annex 3, Appendix 1
Appendix 1; General Conditions to be included in Quarry

Permit, were omitted and shifted to the Plan Final Report under
Appendix C. Document also includes minor changes.
Supplimentary Doc.
Annex 3,
A new Appendix 1: Restoration Examples has been added to

the original document
PART 2:
SUMMARY APPRAISAL OF MAIN COMMENTS
2.1
This part of the report summarises, in order of the Chapters in the Public
Consultation Draft, the representations made by the public and other bodies
and organizations, following the programme of publicity and consultation on
the draft Plan. It concentrates on those issues of strategic importance upon
which comment has been made, and describes how the Plan has been revised
in co-ordination with the Structure Plan Review Core Team and Topic Paper
co-coordinators for final submission to the Planning Authority.
2.2
Overall expressed views on the contents and scope of the draft Plan were
favourable, although a number of issues proved to be controversial or in need
of amendment.
2.3
This section contains a breakdown and analysis of all the comments made in
response to the Public Consultation Draft of the Plan. Each of the comments
is accompanied by a response from the Planning Directorate.
2.4
The comments have been presented in the following manner:

1.
They follow the original sequence of chapters, policies and paragraphs

as appearing in the Public Consultation Draft (16 August 2001).
2.
The appropriate policy or paragraph reference is displayed in the left

hand column followed by the name or title of the particular
respondent.
3.
The comments have been cross referenced to the reference list of

submission reproduced in Appendix 2
4.
The Planning Directorate remarks in column five form the basis of the
recommended changes to the Plan. All policy and paragraph numbers
quoted in this column, refer to the Public Consultation Draft unless
otherwise indicated
5.
Some comments received, relate to the Mineral Resource

Assessment, 1996 and The Environmental Appraisal of Quarries,
1991. For completeness sake these are reported upon, although these
two documents are not reproduced in the Plan.
10
MINERALS SUBJECT PLAN CONSULTATION DRAFT SUMMARY OF RESPONSE
Policy
(Ref. Page)
Respondent/
Date
Summary of Comments Received
Ref.
Planning Directorate Remarks
General Comment
(Part A)
Mr. Clifford
Cauchi 4.12.01
Reference to sources of information used in

the preparation of the Plan
GF/170/01/27
A list of references will be included in the

final Draft of the Plan.
General content
(Part A; Chap. 1,
pp 1-4)
Mr. A. Fenech
Vella A & C.E.
29.08.01
If the Subject Plan was present before, GF/170/01/4/M

many problems would have been avoided.
According to this Plan it looks like it has
been prepared ten years late. It is important
that in the future we start listening to each
other a bit more.
Comment noted.
General content
(Part A; Chap. 1,
pp 1-4)
Mr. A.N.
Welsh 14.10.01
As everyone knows, the Maltese GF/170/01/13

countryside has been nearly ruined, and we
support your efforts to try and conserve and
improve on what we still have.
Comment noted.
General content
(Part A; Chap. 2,
pp 5-7)
Mr. V. Farrugia
25.09.01
The Minerals Subject Plan public GF/170/01/10

consultation draft is completely inadequate
and cannot be accepted as a Minerals
Subject Plan. The report is replete with
fallacious assertions that contradict the
norms and practices on quarrying adopted in
other advanced economies as in EU
This statement is completely unfounded and

cannot be accepted as constructive criticism
of the Minerals Subject Plan. Most consultees
have praised the Plan and its contents and
have contributed constructive criticism that
will help improve on the Plan. The norms
countries and North America.
and practices adopted by the Plan are

those normally adopted in other advanced
11
Policy
(Ref. Page)
Respondent/
Date
Ref.

economies. The author of this comment
has failed to substantiate his claims about
fallacious assertions found within the plan
and has limited his contribution to mere
destructive remarks.
General content
(Part A; Chap. 2,
pp 5-7)
Ms. A.
Farrugia
26.10.01
Council, with the assistance of Mr. Kevin GF/170/01/20

Morris of Planning Services Consultancy,
has studied the Minerals Subject Plan and
would like to express its appreciation and
extend its congratulations to its authors for
producing
a
well-structured
and
comprehensive document to guide quarry
development in particular over the next 10
years.
Comment noted.
General content
(Part A; Chap. 3,
pp 9-11)
Mr. V. Farrugia
25.09.01
GRTU recommends the Planning Authority

refuse in toto the public consultation draft
and further recommends that the Minerals
Board appoint a team of experts (including
a GRTU appointed expert) qualified and
experienced on quarrying and minerals
matters to revise the document.
The team that was involved in the preparation

of this Plan is well qualified in this area and
well versed with the norms and practices of
the industry. The consultant entrusted with the
preparation of the Plan was selected through
the
normal tendering procedure and
qualifications, experience and cost figured
among the criteria adopted in the selection
process.
GF/170/01/10
12
Policy
(Ref. Page)
Respondent/
Date
Ref.
General comment
Part A; Chap. 3,
pp 9-11)
Mr. V. Farrugia
25.09.01
The report cannot be accepted as a Maltas GF/170/01/10

Minerals Subject Plan and the quarrying
industry will challenge any policy
implementation based on this plan.
Overall feedback received by the Planning

Authority regarding this Plan is that it
provides good strategic guidance about the
minerals industry for the next 10 years.
Individual meetings with most of the quarry
owners have resulted in a lot of positive
feedback from the industry players
themselves. In view of this, it is highly
doubtful whether such a comment on behalf
of the quarrying industry could be considered
as representative of the industrys opinion on
the Plan.
General comment
Part A; Chap. 3,
pp 9-11)
Dr. Godwin
Debono
23.01.02
The Minerals Subject Plan consultation GF/170/01/28

draft is well prepared, comprehensive and
very comprehensible to both the industry
and the public at large. In my opinion the
issues of relevance to the extraction of
softstone and hardstone are adequately
covered,
including
the
ensuing
environmental impacts.
Comment noted. Fresh data recovered in the

process of follow up action as a direct result
of the Plan content will be taken into
consideration at the next update of the Plan.
As a result the revised Plan will be further
improved and a number of policies may need
adjustment to reflect the planning needs of
the minerals industry and national demand for
mineral resources.
General content
Part A; Chap. 3,
pp 9-11)
Mr. V.
Farrugia
25.09.01
The Quarry Owners Section in GRTU will GF/170/01/10

be submitting a professional assessment on
the draft Minerals Subject Plan . Kindly
remove limits on presentation of views
since the proposed revision cannot be done
Comment noted. Although the official public

consultation ended on the 19.10.01 meetings
with quarry owners continued way beyond
this date. All comments received up to and
including the 30.11.01 have been included.
13
Policy
(Ref. Page)
Respondent/
Date
Ref.
within the time span as proposed.

Despite this, the professional assessment of
the Plan was not received by this date

General content
(Part A; Chap. 3,
pp 9-11)
Mr. E. Aquilina
12.11.01
The period of time assigned for the process GF/170/01/22A/

of Public Consultation is too short to permit T
quarry owners to adequately evaluate the
Plan and submit comments.
Point taken. The period actually assigned for

public consultation although officially
conforming to a minimum required term of 8
weeks has actually been extended well
beyond this term. A series of round table
meetings were organised for quarry owners.
(Part B; Chap. 4,
point 4.4 p 13)
Mr. Peter Gatt

4.12.01
The use of the term non-porous in referring GF/170/01/27

to first quality hardstone is a misnomer
since there is no such thing as non-porous
rock.
Comment noted. The term non-porous will

be replaced by scarcely porous in final
draft of the Plan.
(Part B; Chap. 5,
pp 23-38)
Mr. A. Fenech
Vella 19.10.01
With reference to the circular dated GF/170/01/17

22.08.2001. Considering the scarcity of
hardstone, a Minerals Subject Plan should
evaluate the import of arbitrary truncation
of areas retaining such a resource and its
consequences on the national economy.
After all a quarry site can be somewhat
rehabilitated, but the scarcity will only
inflate costs that impinge heavily on
viability of projects.
The Plan attempts to tackle the issue of

scarcity of hardstone by adopting a
conservative approach to the exploitation of
our mineral resources. The Plan promotes the
need for a more exhaustive use, reuse and
recycling of locally quarried minerals. It

encourages the adoption of mining
techniques which will provide access to
added mineral reserves with minimal
impact on the environment. In spite of
this, subject to justification, the Plan does
not definitely rule out the possibility of
14
Policy
(Ref. Page)
Respondent/
Date
Ref.

permitting minerals exploitation in designated
and/or protected areas. Eventually, a gradual
shift to imported mineral substitutes cannot be
avoided; especially for engineering works
demanding technical specifications that
cannot be met by local minerals.
(Part B; Chap. 5,
para. 5.18 thru.
5.36, pp 26-29)
Mr. A. Bonello
17.09.01
Part B; Chap. 5, pp Dr. Godwin

32)
Debono
23.01.02
The Planning Authority was unable to GF/170/01/8

obtain any information from quarry owners
with regards to production and reserves in
existing operational quarries. It has as a
result carried out its own surveys based on
aerial photographs for the purpose of
arriving at an estimate of production and
reserves. It has however missed on a
number of important issues such as the
extent of processable resource which as a
result of excessive wastage may lead to an
exhaustion of reserves within a few years.
The statistics provided also need to
distinguish between stone quality since
depending on the quality of stone will
determine its use.
Assessment of minerals production rates and

permitted mineral reserves were based on
overall production rates. The proportion of
marketable resource to mineral waste is
dependant on this figure and on the demand
for specific types of construction materials. In
the absence of actual figures for marketed
products and generated inert waste it was
necessary to make the assumption that the
proportion of generated waste to marketed
product remained constant over the period of
the survey (1994/98). The conservative
approach adopted by the Plan is triggered by
the limited quantities of proven good quality
mineral resource coupled with the need to
preserve the resource and also in view of
envisaged environmental impacts.
The alternative and more economic use of GF/170/01/28

pure
limestone
in
non-construction
industries could be given some
Comment noted. Undoubtedly lime stones

have wide and varied applications depending
to a large extent on their physical, mechanical,
15
Policy
(Ref. Page)
Part B; Chap. 6,
para. 6.35 thru
Para. 6.74, p 45)
Respondent/
Date
Mr. A. Bonello
17.09.01
Ref.
consideration in the Policies. Such

industries include paper manufacture,
medicine, paint, etc.. The use of pure
limestone in the production of lime is
perhaps also something to include in the
Policies.
chemical and mineralogical properties

(Mineral Resource Assessment, 1996). Such
applications could be advantageously
exploited for recycling / processing
of
construction and demolition waste. However,
the methodology leading to resulting end
products are best treated within the context of
a Minerals Management Plan and not a landuse planning document, such as the Minerals
Subject Plan. Notwithstanding this, the Plan is
fully supportive of all methodologies and
practices that tend to maximise (hence
preserve and conserve) on the exploitation of
mineral resources.
The general public has a right and a duty to GF/170/01/8

express its opinion on environmental issues
irrespective of the fact that difficulties that
quarry owners are facing go a long way
further. The plan needs to address issues
related to traffic impacts, quarry access,
safety to pedestrians, the present state of
roads (damages to road surface and
underground service
utilities) and the
possibility of opening a ring road adjacent
to the airport perimeter fence. A large
percentage of inert waste that was at one
The Plan and in particular the Code of

Practice (Annex 3) assigns a lot of weight to
the environmental and social aspect of
quarrying. While it reiterates on the need for
the resource for
clearly economic and
aesthetic reasons it likewise puts great
emphasis on the need for quarrying and
related activities to abide by established
national and international standards for good
environmental practice.
16
Policy
(Ref. Page)
Respondent/
Date
Ref.
time being delivered to the Maghtab land

fill is now being diverted into a large
number of softstone quarries in Mqabba.
Part B; Chap. 6,
para. 6.49 (pp
47-48)
Part B; Chap. 7
Mr. V. Gauci
Director EPD
22.10.01
NC
Point 6.49 mentions percolation through GF/170/01/18

porous limestones. It should be clarified that
most of the water that percolates passes
through rock fissures than through the
pores. This is significant in view of the fact
that rock fissures cannot be relied upon to
effect any form of filtration of the water as
it passes through.
NC
NC
Water mainly moves down through open

fissures and joints but also to a lesser extent
through the rock mass as a result of porosity.
The higher the porosity of the rock mass and
presence or absence of open joints will
determine which of the two processes prevails
in determining the mechanism whereby water
from the surface reaches the aquifer. The
aquifer itself is situated both within the porous
rock and in joints and cavities present within
the rock mass. The Water services
Corporation insist that quarries should
maintain sufficient rock buffer between the
maximum allowed quarry depth and the top of
the water table in order to permit filtration of
the water. An adjustment on these lines to the
content of point 6.49 will be included in the
final Draft of the Plan.
NC
17
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Part C; Chap. 8,
HS1, p 70)
Mr. Paul Vella

04.12.01
Agreed. In our opinion every five years is

enough.
GF/170/01/24
Frequency at which surveys are carried out

will depend on the rate of production and
need or otherwise to reclaim parts of the
quarry. Spot levels should always be taken
prior to infilling of disused parts of the quarry.
(Part C; Chap. 8,
HS2 p 70)
Mr. Peter Gatt

29/08/01
Will permits for new quarries be granted? If

not what are the operators to do when this is
the only work they can do for a living.
GF/170/01/4/M
The Plan calls for a pragmatic type of

approach in considering new minerals
applications; this also in view of the fact that
the Plan is intended as a land use planner and
not directed at the individual.
(Part C; Chap. 8,
HS5, p 72 &
HS2 / HS3, p 70)
Mr. A. Zammit
28.09.01
It is crucial that there should be land

earmarked from before as sufficient
quarrying areas, as this will enable
developers to plan on a long term basis.
Certain operators have been for many years
planning in advance, and acquiring land in
their vicinity, which they think, is suitable
for quarrying. Now it seems that all such
planning was done in vain as the PA is
limiting further expansion and in addition it
is not indicating areas which will be given
due consideration as quarries.
GF/170/01/11
The Minerals Subject plan in reproducing the

Minerals Safeguarding Areas resulting from
a Mineral Resource Assessment carried out
earlier on, provides protection to the said
areas against sterilization of proven mineral
resources (annex 2 p. 3). Besides Policy DC 5
(p. 79) encourages minerals exploration.
Expansion of ongoing mineral workings is
being controlled in view of permitted proved
reserves well in excess of the projected
production rates over the next 5 years. A
quarry extension may on the other hand result
unacceptable on policy grounds.
18
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Part C; Chap. 8,
HS2, p 70)
Mr. A.N.
Welsh
14.10.01
Some quarries are becoming enormous

scars on the countryside, with spill over the
surrounding area. Painful and difficult
though it may be, further extension of
quarry areas has to be limited and stopped;
most with modern technology can go
deeper.
GF/170/01/13
The Subject Plan is emphatic on the need to

ensure that quarries are adequately landscaped
and conveniently tied up to approved
restoration schemes. Planning policy has
always favoured minerals extraction in the
vertical direction as against spreading
horizontally. However, in making such
considerations one needs to keep in mind that
mineral resources are strictly tied up to the
local geology and likewise that moving down
in the vertical direction is limited by the risks
of contamination to the water table.
(Part C; Chap. 8,
HS2, p 70)
Softstone
quarry owners
1.11.01
If an existing operational quarry is nearing GF/170/01/21A/

exhaustion can the quarry operator apply for T
a new permit in an area adjacent to an
existing operational quarry.
On the grounds of permitted reserves well in

excess of projected demand over the Plan
period there is a presumption against the
granting of new permits , at least until the first
review of the Plan. However the Planning
Authority will take a pragmatic approach
towards proposals for additional mineral
workings over the said period. Past
performance (Policy DC4) of the operator in
terms of site management and previous
breaches of planning conditions will be taken
into consideration when processing such an
application.
19
Policy
(Ref. Page)
Respondent/
Date
Ref.
Part C; Chap. 8,
HS2, p 70)
Hardstone
quarry owners
12.11.01
Standing by policy HS1 and HS2, it would GF/170/01/22A/

be unfair if a quarry operator whose quarry T
is nearing exhaustion and who has invested
in machinery and resources, was not
permitted to resume his activity at an
alternative site. As a direct consequence of
this policy quarry owners whose sites have
become exhausted would require to
purchase aggregate from other quarry
owners. This will lead to a market trade
imbalance
and
unfair
competition
throughout the building industry.
Estimates reproduced in the Plan (Annex 2) of

permitted mineral reserves are well and above
of the projected demand over the Plan period.
This alone justifies the need for policy HS2.
Although such issues as unfair competition
are beyond the scope of land use planning, the
Plan is supportive of efforts by individual
quarry owners towards aggregation into a
single trade association or alternatively a
limited number of cartel type groups. Such a
form of arrangement would not only permit
quarry owners to better manage the resources,
but it would also become more feasible to
extract, process and market the stone
products. A cartel type of arrangement places
quarry owners in an advantageous position to
maintain prices at a high level, and control
production, marketing arrangements, etc. in
instances where a situation such as indicated
arises the Subject Plan recommends a
pragmatic type of approach when assessing
proposals for new quarry permits.
Part C; Chap. 8,
HS2, p 70)
Mr. Paul Vella

04.12.01
We are not of the opinion that a rigid policy GF/170/01/24

in respect of applications for new permits
should be adopted. Every application should
be considered on its own merits.
Comment noted. Refer to earlier comments

with respect to this policy.
20
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Part C; Chap. 8,
HS2, p 70)
BICC (GRTU)
15.01.02
GRTU strongly objects to policy HS2 and is GF/170/01/27

of the opinion that this moratorium would
have an adverse effect on the quarry
operators and would especially penalise
those quarry operators who have exhausted
or will soon exhaust the mineral reserves
within their current quarry site. Those
seeking a new quarrys will not be permitted
to do so
Comment noted. Refer to earlier comments

with respect to this policy.
(Part C; Chap. 8,
HS3, p 70)
Ms. A.
Farrugia
26.10.01
Policy HS3 states that there have been no GF/170/01/20

significant
environmental
impacts
associated with the existing operations that
would be prolonged by the extension.
Council feels that such a question could
only be answered by way of an
environmental assessment consistent with
an Environmental Planning Statement or
full Environmental Impact Assessment.
When recommending an extension to an

existing quarry permit the Planning Authority
will examine the existing status / impacts of a
site that has been in operation for some time.
If it results that impacts connected with an
ongoing quarry development are not likely to
attenuate within the context of a new
extension, then the proposal may be refused
on policy grounds; in which case it shall not
be necessary to request an EIA.
Part C; Chap. 8,
HS3, p 70)
Hardstone
quarry owners
12.11.01
If quarry owners provided the PA with GF/170/01/22A/

details (including site plans) of land where T
they planned to quarry, will the PA indicate
whether quarrying would be acceptable on
policy grounds, irrespective of whether
they
The PA will provide information on request

that will assist quarry owners to decide
whether an application would be acceptable
on policy grounds; irrespective of the location
of such a proposal. Within given limitations It
may further provide advice with respect to the
21
Policy
(Ref. Page)
Respondent/
Date
Ref.
are adjacent to their existing operational

quarries or not.
expected mineral extraction potential of such

a site.
(Part C; Chap. 8,
HS3, p 70)
Mr. Paul Vella

04.12.01
In the case of extensions, policies should be GF/170/01/24

more flexible, thus avoiding unnecessary
expenses in E.I.A.S.
Need (incl. extent) or otherwise for an

environmental impact assessment and any
resulting mitigation measures are assessed on
a case by case basis.
(Part C; Chap. 8,
HS3, p 70)
BICC (GRTU)
15.01.02
The considerations listed in policy HS3 with GF/170/01/27

regards to applications to extend existing
quarries are considered by quarry operators
to be too stringent and onerous.
This policy is in conformity with existing

environmental and planning legislation and
further conforms to international norms and
policies on environmental controls with
regards to mineral workings. Reference
should also be made to earlier comments with
respect to this policy.
Part C; Chap. 8,
HS4, p 71)
Ms. A.
Farrugia
26.10.01
While supporting the factors to be GF/170/01/20

considered when assessing the need for the
exploitation of hardstone, it would be
helpful if further guidance were to be
included on the extent of market analysis
and the period to be covered by such an
analysis. For example, would the Planning
Authority be satisfied with a justification
that covered say one year, or should the
market analysis cover 10 years? In bringing
A careful assessment of supply and demand

projected into the Plan period should be based
on direct and indirect methods of production
estimates and market analysis. Given that
available information coming direct from the
major players is very fragmentary and to a
large extent very unreliable, assessments on
supply and demand based on such data would
result fallacious. Indirect methods that have
been attempted to obtain an estimate of
22
Policy
(Ref. Page)
Respondent/
Date
Ref.
together markets and alternative supplies,

experience elsewhere in Malta, such as at
Wied Ghomor in Swieqi, demonstrates that
it is insufficient to simply say what the
proposed markets are, rather an economic
analysis / market analysis demonstrating the
need for product is recommended.
marketed hardstone products included the

importation of cement, use of explosives.
Given the local scenario, application of more
direct methods for making long term market
demand predications may be misleading are
more subject to error than the use of more
indirect methods.
(Part C; Chap. 8,
HS5 / HS6, p 72)
Mr. N.
Formosa
28.08.01
At the present rate of land encroachment in GF/170/01/3

conjunction with urban development and
correspondingly high consumption of
mineral resources do you envisage that there
will still be land available for quarrying, say
in 50 years time. For how long are present
proven reserves expected to last.
The Plan (Annex 2) provides approximate

estimates of expected duration of proved
mineral resources. The Plan policies favour
the conservation of mineral resources through
protection against sterilization and a projected
reduction in produced mineral waste.
Estimates derived from the Mineral Resource
Assessment indicate total existing proves
reserves well in excess of 50 years.
Part C; Chap. 8,
HS5, p 72)
Mr. A. Zammit
28.09.01
At the moment one has to acquire land in GF/170/01/11

advance and apply to the PA without
knowing as to whether a permit will be
granted or not. This may result in a refusal,
hence a loss, financially for the developer,
which will in the long term backfire over
the whole country.
Prior to acquiring land, quarry owners are

advised to research through Planning
Authority and/or other local resources the
status of land that they propose to employ for
mineral exploitation purposes. The Planning
Authority is in a position to advise what how
such an application will fare on policy
grounds and may also provide information of
23
Policy
(Ref. Page)
Respondent/
Date
Ref.

a more technical nature of more direct
relevance to the mineral resources.
(Part C; Chap. 8,
HS5, p 72)
Mr. A. Zammit
17.10.01
The Minerals Subject Plan does not tackle GF/170/01/15

an important issue within the industry, and
that is allocation of new quarries. A proper
indication of land that is available for future
quarrying activities would aid proper
economical and environmental planning.
The Plan reproduces the results of a Mineral

Resource Assessment which actually had the
scope of investigating extensive areas of
land lying beyond existing permitted quarry
boundaries. On the basis of this assessment
Policy HS5 in the Plan is intended to offer
protection against sterilization of existing
proven good quality mineral resources within
the so called Minerals Safeguarding Areas.
Placing of new quarries is however not
necessarily limited to these areas.
Part C; Chap. 8,
HS5 / HS6, p 72)
Hardstone
quarry owners
12.11.01
Existing hardstone quarries are fast running GF/170/01/22A/

out of good quality mineral resources and a T
good proportion of quarries will shortly
become exhausted with no remaining option
of
further extensions as a result of
encroaching development or scheduled
land. At the same time the demand for
aggregate is very high. What contingencies
does the PA have for future demands for
mineral resources?
Policies HS5 and HS6 provide protection to

mineral resources both within the so called
Minerals Safeguarding Areas and in advance
of development that would otherwise sterilize
the resource. Besides, policy DC20 makes a
provision for a minimum of 100m buffer
between quarries/ Minerals Safeguarding
Areas and other forms of development.
24
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Part C; Chap. 8,
HS6, p 72)
Dr. Godwin
Debono
23.01.02
The possibility of accessing the Lower GF/170/01/28

Coralline limestone through exhaused
softstone quarries could also be treated in
the Policies. Such extraction of hardstone is
far less damaging to the environment than
current extractions, especially those in
valleys (e.g. Wied Incita, Wied Ghomor,
Wieq Moqbol, etc.)
Comment noted. Policy HS6 already supports

the view expressed and requires that pending
impacts, minerals should be extracted in
advance of development that would sterilise
the resource. In this respect added exploition
of spent softstone quarries would provide
additional stocks of hardstone resource, which
as correctly pointed is normally quarried in
ecologically sensitive areas such as along
valleys and adjacent to cliff faces. Policy HS6
will be applied as required to safeguard
against sterilisation of mineral resources as a
direct or indirect consequence of other forms
of development. The word permitted in line
2 of policy HS6 will be replaced by
required.
(Part C; Chap. 8,
HS6, p 72, HS7,
p 74)
Hardstone
quarry owners
13.11.01
Some quarries have for some time not GF/170/22A/T

availed of their licences to blast rock within
their permitted boundaries. This has resulted
since a number of quarry operators have
recycled substantial quantities of hardstone
resource that was excavated in conjunction
with ongoing major projects such as the
Eden Leisure, Portomaso and Pembroke.
Comment noted
25
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Part C; Chap. 8,
HS6, p 72, HS7,
p 74)
BICC
15.01.02
In the case of large-scale projects the GF/170/01/27

Planning Authority should seriously
consider the possibility of extracting stone
from the site prior to its development.
In view of the existing limited mineral

reserves and in recognising the need to
conserve and preserve local mineral
resources, the Plan is fully supportive of all
such measures that tend to prolong the
lifespan of proved mineral stocks. However
such development should not conflict with
other planned land uses or adversely effect
local communities or the environment.
Part C; Chap. 8,
HS7, p 74)
Mr. C. Grima
24/08/01
Local stone used in conjunction with fish GF/170/01/1

aggregating rafts (kannizzati) employed
during the Lampuki season should be
replaced by recycled stone the use of which
should be regulated by adequate legislation.
If necessary the Government should
subsidise any additional costs incurred
through the process of producing recycled
stone.
Comment Noted. The Plan recognizes and

prioritizes on the need for recycling of local
stone products in view of the recognized
limited reserves of mineral resources. It
further takes a conservative attitude towards
the opening of new quarries in view of the
estimated permitted reserves well in excess of
the projected demand over the Plan period.
(Part C; Chap. 8,
HS7, p 74)
Mr. V. Galea
31/08/01
What guidance and views may be derived GF/170/01/6

from the Plan with regards to investment in
machinery that will enable the additional
processing of raw mineral resource
materials into blocks of up to (3x2x2)m and
further processing by machinery already
Innovative methods of processing the raw

minerals are most welcome in as much as they
tend to maximize on the extent of marketable
end product and hence minimize on the
generation of mineral waste; hence improved
land use planning. The Plan within the context
26
Policy
(Ref. Page)
Respondent/
Date
Ref.
available at existing factories.
of land use planning promotes all innovative

concepts
leading
to
good
resource
management practice.
(Part C; Chap. 8,
HS7, p 74)
Mr. P. Zammit
Briffa 19.10.01
The plan encourages re-cycling of GF/170/01/16

construction waste but offers no framework
for this to happen. The plan does not offer
insights for a different set of standards for
re-cycled aggregate (as implemented in the
Netherlands).
Comment noted. At present and in the

foreseeable future emphasis on the need to
reuse and recycle mineral waste is mainly
targeted at inert waste generated as a result of
waste generated by softstone quarries and
through construction and demolition practice.
Almost all produced hardstone resource is
channeled into construction works. It is the
scope of the Plan to encourage quarry and
building contractors to make a more
exhaustive use of
quarried softstone.
Otherwise management plans, although
admittedly desirable, are beyond the scope of
the Plan.
Part C; Chap. 8,
HS7, p 74)
Mr. V. Gauci
22.10.01
The report adopts targets for the reduction GF/170/01/18

of C&D waste generation that do not
comply with those in the recently approved
National
Solid
Waste
Management
Strategy. The Plan should explore how the
targets in the strategy may be achieved. We
would like to see more on recycling options
Comment noted. Figures reported in the Plan

will be updated to reflect targets set within the
framework of the recently approved National
Solid Waste Management Strategy. It is
beyond the scope of the terms of reference of
the Minerals Subject Plan to propose ways
and means for achieving the said targets; the
27
Policy
(Ref. Page)
Respondent/
Date
Ref.
for C&D waste and how waste may be

reduced at the quarry site; also on economic
instruments.
The Environment Protection Department
agrees with a policy of restraint in terms of
the release of future reserves
(Part C; Chap. 8,
HS7, p 74)
Softstone
quarry owners
31.10.01
Recycled Franka spalls could effectively GF/170/01/21A/

replace the use of hardstone aggregate as T
sub-base for road works. Quarried low
quality Franka stone once used in
foundations is presently being discarded as
mineral
waste.
Especially
younger
architects are increasingly replacing the use
of softstone by concrete products. The Plan
should provide guidance as to how to
reduce the high amounts of inert waste
generation from softstone quarries and
preservation of reportedly relatively lower
reserves of hardstone mineral resources.

Waste Subject Plan would provide a better
planning tool in this respect. On the other
Hand the issue of recycling and waste
minimization is best tackled within the
context of a resource management plan.
The Plan centers around the need to manage

efficiently mineral resources; incorrect
resource management practice not only leads
to an accelerated sterilization of resources but
results in a constant crescendo of
environmental and social impacts. It is beyond
the scope of the
Plan to identify the
technicalities and management behind
methods of recycling that would be conducive
to waste minimisation. The Plan however
indirectly seeks to reduce on the extent of
generated mineral waste by limiting permitted
mineral workings to projected market
demands. In accordance with policy HS7 and
other related plan policies the Planning
Authority through the issue of development
permits shall seek to bring about
improvements in the overall mineral resource
management of local mineral resources.
28
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Part C; Chap. 8,
HS7, p 74)
Softstone
quarry owners
1.11.01
While presently only the best quality stone GF/170/01/21A/

is being marketed, a marked shift over the T
last 20 years to the use of concrete blocks
(bricks, etc.) is noted. It is strongly
recommended that while planning law
enforces existing legislation on the use of
softstone products (eg. facades etc.) a more
extensive use (third party walls etc.) of
softstone products should be demanded.
It is beyond the remits of Planning Law to

regulate the extent to which one type of
mineral resource is used as against another
resource type, or even local mineral
substitute, unless such use is in conflict with
planning policies. Planning Law will enforce
existing norms on the use of local resource as
derived from existing building regulations.
The Subject Plan in promoting the principle of
a rational exploitation of mineral resources,
indirectly seeks to strike a balance on the uses
made of the different varieties of all quarried
resource.
Part C; Chap. 8,
HS7, p 74)
Softstone
quarry owners
1.11.01
There should be an arrangement to refrain GF/170/01/21A/

from issuing further permits for concrete T
and tarmac plants. This would favour the
use of softstone and hence contribute to
reduce inert waste generation.
The Planning Authority may decide to limit

specific forms of land use only where such
land use would conflict with adjacent existing
or planned land uses, and/or if the need for
such form of development does not outweigh
the environmental impacts that are likely to
arise. The Plan is supportive of efforts on the
part of softstone quarry owners to maximize
on the extent of marketed resource as a
proportion of the total quarried resource; also
in view of the fact that construction products
derived from the relatively more limited
proved hardstone reserves occupy a
29
Policy
(Ref. Page)
Respondent/
Date
Ref.

considerably greater share of the market.
(Part C; Chap. 8,
HS7, p 74)
Hardstone
quarry owners
13.11.01
The price of stone is ridiculously low when GF/170/01/22A/

compared with the overall costs of T
construction. By raising the cost of local
building stone and other locally quarried
construction materials would not only
benefit the industry as a whole but would
provide an incentive to economise
(preserve) on the use of raw minerals and at
the same time make it more feasible to reuse
and/or recycle inert waste. On the other
hand the building industry depends heavily
on locally quarried minerals; which activity
should therefore necessarily be given all
the necessary support, in the national
interest.
Comment noted.
(Part C; Chap. 8,
HS7, p 74)
Mr. Paul Vella

04.12.01
Recycling should be introduced so as to GF/170/01/24

diminish the impact on Maghtab Dump.
Comment noted. Recycling is above all

essential in view of the limited and fast
dwindling stocks of mineral reserves.
Part C; Chap. 8,
HS7, p 74)
BICC
06.021.02
The Government and the private sector GF/170/01/29

could establish a stone depot on a P.P.P.
(Public Private Partnership) basis whereby
anyone could purchase re-cycled and re-
Comment noted. The Plan supports the idea of

such a setup not only in view of minerals
conservation and preservation policies that it
promotes, but also in view of projected
30
Policy
(Ref. Page)
Respondent/
Date
Ref.
used stone of any size. This depot should

include a crushing and screening plant in
order to offer various types of by-product
for example:
a) large boulders for landscaping:
b) smaller boulders for rubble walls,
c) crushed stone for use in mass
concrete,
d) sub base for road construction
e) graded stone for base to floor tiles
f) fine particles to be mixed with
compost and used as soil.
Furthermore, this depot should have a
separate area to stock various types of used
building stone blocks to be utilised in the
restoration and extension of old buildings.
The authority should encourage the re-use
and re-cycling of old stone.
Part C; Chap. 8,
HS8, p 74)
Mr. S. Mallia
3/09/01
A total ban on the export of Maltese GF/170/01/7

limestone classified as processed (worked)
stone should be in place since an increase in
the demand for processed stone products
directed to other countries would result in
an increase in the quarrying activity and

figures for inert waste diversion over the next
5 years from landfill for use in construction.
Aggregation into a single trade association by
individual quarry owners or alternatively a
limited number of cartel type groups increases
the chances of viability of such joint projects.
While development permits in conju7nction
with the proposed setup will necessarily be
issued by the planning Authority, all plant on
site will be regulated through Police licences.
The role of Malta Resource Authority is also
vital to the success of such a project.
Comment noted. It is highly desirable from a

minerals planning point of view to preserve
whatever limited mineral resources may still
be recovered locally. On the other hand the
planning process can only discourage such
practice in a very limited way through the
31
Policy
(Ref. Page)
Respondent/
Date

resulting depletion of
resource.
Ref.
this valuable

issue of development permits.
(Part C; Chap. 8,
HS8, p 74)
Softstone
quarry owners
1.11.01
In view of the large quantities of inert waste GF/170/01/21A/

being dumped at the Maghtab landfill would T
it not be recommendable to consider
increasing export of local stone products.
Besides, recycled stone products could fetch
favourable markets abroad, making it
feasible to recycle/reuse construction and
demolition waste which would otherwise
end at the landfill.
Given the limited mineral resource reserves

the Subject Plan discourages the export of
indigenous supplies of limestone. However
activity directed at recycled stone products
that can be advantageously marketed abroad
would receive favourable consideration.
Within limits export of decorative/sculptured
stone products would also be acceptable.
(Part C; Chap. 8,
HS9, p 74)
Mr. Paul Vella

04.12.01
Policy content is not considered viable
Given the present market price of local

mineral resources, mining may not be a viable
option. However the Plan does not exclude
such a form of activity, especially when it can
be linked to engineering works (tunneling) in
progress. On the other hand should market
forces influence/raise the cost of the resource
such underground operations would not only
become feasible but would be desirable in
view of the expectedly limited derivable
impacts and added access to additional
mineral stocks.
GF/170/01/24
32
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Part C; Chap. 8,
HS9, p 74)
BICC (GRTU)
15.01.02
Proposals for underground mining are not GF/170/01/27

considered feasible and are impractical
given that underground mining would
within the local pricing context be
economically unfeasible. Such operations
would also entail considerable financial
investment that current quarry operators can
ill-afford. Also, there is no local tradition or
expertise in underground mining.

Comment noted. Feasibility of underground
mining may be maximised subject to the
adopted methodology of extraction and the
market value that the product fetches on the
open market both locally and abroad. Thus for
example it would profit more to mine prime
quality hardstone for processing as marble
products rather than for aggregate used in
concrete products. The right choice of site
(rock quality, access, etc.) are also
determining factors that need to be considered
prior to undertaking such mining ventures.
The Plan is fully supportive of innovative
technologies that tend to maximise on the
extent of mineral products that may be
recovered and consequently marketed
Tradition or existing local experties should
not constitute valid criteria for not introducing
innovative technoligies where such are
justified. After all hardstone quarrying
presently controlling a major portion of the
local construction industry is not traditional to
Malta. Reference should also be made to
earlier comments with respect to this policy.
33
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Part C; Chap. 8,
Alternative
Supplies p 72
Dr. Godwin
Debono
23.01.02
It may be possible to make reference, in the GF/170/01/28

Policies, to the possibility of offshore
dredging of sand and deep sea-bed minerals
for economic use.
Offshore development inclusive of marine

dredging whether for sand, gravel or sea-bed
minerals is regulated by Planning law.
Pending impacts offshore dredging will be
permitted. The Plan will include a reference to
offshore dredging and an additional policy
HS10 will be included.
Part C; Chap. 8,
HS3, p 70) (Part
C; Chap. 9, DC13,
p 83)
Hardstone
quarry owners
12.11.01
It is neither practical nor convenient for GF/170/01/22A/

extensions to existing quarry depths to be T
approved at 15m intervals. Since the rock
quality varies both horizontally and with
depth, good quarry practice requires that
minerals are quarried from different
locations/levels and suitably mixed or
otherwise
separately
marketed
in
accordance with engineering specifications.
Alternatively it is not possible to
manage/market the minerals efficiently if
an extension of 15m is only approved on the
presumption that all the minerals have been
exploited/ excavated within the preceding
15m depth.
Given the variable quality of hardstone,

especially with respect to the Upper Coralline
formation, it would greatly benefit resource
management if
at least the maximum
allowable depth of quarrying that would be
permitted at any given location was known
well in advance of the single permitted
quarry phases. It is hoped that such data will
shortly
be
made
available
through
consultation with the Malta Resources
Authority. Data on strata variations may be
obtained through core sampling at individual
quarry sites.
Part C; Chap. 9,
DC1, p 77)
Mr. A.N.
Welsh 14.10.01
As it has been reported that the majority of

quarries are in breach of planning
Comment noted. Thanks
GF/170/01/13
34
Policy
(Ref. Page)
Respondent/
Date
Ref.
regulations or consents we can only hope

that the PA can gain some sort of control of
quarrying.
(Part C; Chap. 9,
DC1, p 77)
DC2, p78
Softstone
quarry owners
31.10.01
If quarry operators apply to sanction illegal GF/170/01/21A/

development within the stipulated 6 months T
time limit from the approval of the Subject
Plan, what will be their position with
respect to pending enforcements, such as in
the case of fines, etc. Are any advantages
envisaged in complying and what are the
implications if the quarry operators do not
comply within the stipulated time frame.
Applications submitted within the stipulated

time frame will normally be exempted from
the requirement to carry out a full
Environmental Impact Statement. An
Environmental Planning statement will
normally be required. The provisions of the
law will be applied in full in cases of failure
to comply with the requirements of policy
DC1.
(Part C; Chap. 9,
DC1, p 77)
Softstone
quarry owners
2.11.01
In applying to sanction illegal quarry GF/170/01/21A/

development why should quarry operators T
be required to pay for drainage and road
fees in areas where there is no drainage
system in place or even envisaged,
especially in ODZ areas that will normally
be restored to agriculture or ecology.
Depending on a case by case basis

development control applications in ODZ
areas need to contribute towards road fees and
in most cases also for drainage. Contributions
are necessary since the proposed land uses
will necessarily benefit from the existing
and/or planned road network adjacent to the
quarry which may also need to connect to an
existing or planned drainage utility.
If an application has been refused either on

policy grounds or on lack of data required to
process the application, irrespective of
whether a new application has been
If a planning application to sanction has been

refused on policy grounds and a new
35
Policy
(Ref. Page)
Respondent/
Date
Ref.
submitted, to what extent (proportion of

original application fee) and when is the
applicant expected to be refunded back the
monies from the original application.

application has been submitted a partial
refund will be returned to the applicant once
the new application has been decided.
(Part C; Chap. 9,
DC2, p 78)
Mr. Mario Gatt

28.08.01
Why is it necessary to carry out an GF/170/01/3/G

Environmental Impact Assessment when
applying to sanction illegal quarry activity
that has been in operation for some time.
The area of influence that is normally

addressed by an EIA extends beyond the
perimeter of a specific landuse that is being
investigated/assessed. Besides, an EIA also
addresses the afteruse of the site and issues of
social/public
nature
in
addition
to
environmental issues.
(Part C; Chap. 9,
DC3, p 78)
Mr. Noel
Formosa
28.08.01
Once it cannot be avoided that trucks GF/170/01/3/G

associated with quarry operations make use
of roads for which Local Councils are
responsible, then the owners should be
required to contribute towards road
maintenance. Such foreseeable impacts that
are normally addressed by an EIA need to
be followed up and acted upon; otherwise it
would all be money down the drain.
Comment noted.
Part C; Chap. 9,
Para. 9.6, DC3, p
78)
Ms. A.
Farrugia
26.10.01
Information in Support of Planning GF/170/01/20

Applications: It would be useful to include
a baseline noise and dust survey in the
information to be provided. Guidelines as to
Comment noted. Recommended changes will

be included in the revised Plan. Guidelines
and extent of survey will be those
recommended in the approved
36
Policy
(Ref. Page)
Respondent/
Date
Ref.
the extent or the survey and standards to be

followed would be required.
Environmental
Impact
regulations, September 2000.
Assessment
(Part C; Chap. 9,
DC3, p 78)
Mr. Paul Vella

04.12.01
There should be more co-operation and GF/170/01/24

flexibility between the various government
departments. Otherwise, it would be
impossible for a new permit to be issued.
Comment noted. Minerals Advisory Board is

expected to serve this function.
(Part C; Chap. 9,
DC5, p79)
Hardstone
quarry owners
12.11.01
Obtaining core rock samples for the purpose GF/170/01/22A/

of investigating the quality of the mineral T
resource in conjunction with a new quarry
site or an extension to an existing quarry
involves additional costs/expenses and
given the variable quality of the rock does
not produce satisfactory results.
Accuracy of results will depend on the nature

of the area investigated. There is a limit to the
extent of core sampling that may be carried
out at a given site. Satisfactory results are
normally obtained if the number and siting of
the drill holes is based on a preliminary
geological survey of the quarry area and
immediate surroundings.
(Part C; Chap. 9,
DC6, p 80)
Ms. Gillan
Martin
28.08.01
Is the emanation of radioactivity from GF/170/01/3/G

hardstone quarries an issue of concern and
to what extent is it addressed by EIAs
Radiation of a very limited extent is emanated

and would normally fall within the context of
public health. It is not normally addressed by
EIAs.
(Part C; Chap. 9,
DC6, p 80)
Mr. Twanny
Baldacchino
29/08/01
The Planning Authority should sustain the GF/170/01/ 4/M

costs for environmental impact assessments
(EIA) that are requested in conjunction with
minerals development. It is felt that a lot of
hustle is created over the preparation of
The Planning Authority in admitting that

preparation of EIAs is very costly would
wherever applicable be prepared to issue calls
for tenders for the preparation of EIAs in
conjunction with individual or a number of
37
Policy
(Ref. Page)
Respondent/
Date
Ref.

minerals related applications. The Planning
Authority is presently in the process of
assessing professional bodies/consultants that
are qualified to carry out EIAs.
EIAs and then no use is made of the related

document.
(Part C; Chap. 9,
DC6, p 80)
BICC (GRTU)
15.01.02
Prohibitive costs are being incurred by

quarry
operators
in
commissioning
Environmental Impact Assessments that are
requested by the Planning Authority when
there is a request to extend an existing
quarry. Such costs shall be further increased
as a direct consequence of the introduction
of more stringent information requirements.
Joint EIA should be prepared for adjoining
quarries since this would reduce costs. It is
further recommended that requested
information be streamlined as much as
possible in order to minimise costs.
GF/170/01/ 27
The terms of reference that is normally

requested in conjunction with minerals
applications are derived on the basis of the
approved Environmental Impact Assessment
regulations, September 2000. However such
terms of reference are in the majority of cases
site specific and the extent of detail that will
be expected will depend on the nature of the
sites upon which an application has been
submitted and ensuing conflicts with adjacent
landuses. Whenever possible there should be
no objection to the preparation of joint EIA
incorporation two or more adjacent mineral
applications, as long as the EIA terms of
reference are addressed in full. Reference
should also be made to earlier comments with
respect to this policy.
art C; Chap. 9,
DC6, p 80)
Softstone
quarry owners
31.10.01
Is it necessary for quarry operators to carry GF/170/01/21A/

out EIAs in areas where the good quality of T
the resource can be proved on the basis of
The scope of an EIA is not limited solely to

the assessment of mineral resource quality but
to the coordinated assessment of all
38
Policy
(Ref. Page)
Respondent/
Date
Ref.

cumulative impacts that may be associated
with mineral workings at a specific location.
The method that will be adopted for
investigating mineral quality will be assessed
on a case by case basis, depending on the
nature of the site and more or less direct
access to information on the type/quality of
the resource within the site.
adjacent exposed quarry rock faces; hence

saving on unnecessary costs.
Part C; Chap. 9,
DC6, p 80)
Mr. Paul Vella

04.12.01
Contents of policy may apply to new

applications but not for extensions.
GF/170/01/24
The policy applies in various degrees to all

applications whether for new quarries or for
extensions to existing quarries. Permits need
to address and mitigate impacts that already
exist by virtue of existing mineral workings
or are envisaged as a result of new
operations.
Part C; Chap. 9,
DC7, p 81)
Mr. P. Zammit
Briffa
19.10.01
The Plan does not offer a blueprint for the

proper environmental impact assessment of
quarrying. This deficiency has resulted in a
non-standard assessment of environmental
impacts of quarries by the Planning
Authority.
GF/170/01/16
It is not the role of the Plan to address such an

issue. Terms of Reference for environmental
impact assessments for quarries are derived
on the basis of the Environmental Impact
Assessment Regulations, September 2000. It
would be fallacious to expect that standard
EIA terms of reference could be applied to
different types of land use proposals and in
different locations/ situations. The scale of
39
Policy
(Ref. Page)
Respondent/
Date
Ref.

the development,location and sensitivity of
different sites present different environmental
and social scenarios which should necessarily
be assessed on their own merits.
(Part C; Chap. 9,
DC8, p 81)
Mr. Paul Vella

04.12.01
Guarantees are excessive and should be GF/170/01/24

more moderate.
Bank guarantees should normally reflect the

real cost of undertaking restoration and
landscaping schemes by independent third
parties should the developer fail to comply in
accordance with permit conditions. In this
respect the Plan is recommending the setting
up of a single trade association that will
among other functions be expected to
accommodate this issue and involving the
least burden on the industry.
(Part C; Chap. 9,
DC11, p 83)
Ms. A.
Farrugia
26.10.01
The differentiation between grades of SSI GF/170/01/20

etc. is appreciated and supported. However,
further guidance is needed in respect of the
criteria and methods to be used to
demonstrate that the need to extract the
mineral outweighs the impact / loss of SSI,
etc.
Comment noted. While comment is upheld in

principle it is beyond the scope the Plan to
indulge into such detail. The criteria/methods
are normally addresses within the context of
an EIA.
40
Policy
(Ref. Page)
Respondent/
Date
Ref.
Part C; Chap. 9,
DC13, p 83)
Mr. P. Zammit
Briffa
19.10.01
The plan introduces restrictions on quarries GF/170/01/16

which
will
adversely
affect
the
environment. As quarries will be restricted
from excavating deeper, they will be
constrained to expand laterally thereby
increasing their impact on the natural
environment and settlements close to
quarries.
The Plan favours (DC 13) vertical extensions

as against lateral extensions to existing
quarries. However vertical extensions are
dependent upon resource availability and is
restricted by the water table. Otherwise
pending feasibility the Plan recommends
underground mining of mineral resources.
(Part C; Chap. 9,
DC13, p 83)
Softstone
quarry owners
1.11.01
In reopening old partially reclaimed GF/170/01/21A/

quarries that have been originally cut T
(deepened) using primitive equipment, from
which level is the approved quarry depth
(say 15m) measured. Similarly, given an
approved permitted quarry depth and given
that the mineral resource is covered by
loose sediment/overburden, from which
level should the quarry depth be measured.
In applying for a permit to resume quarrying

at an existing reclaimed ex-quarry site the
applicant should submit a survey of the
existing topographic surface of the quarry and
of the rock surface immediately underlying
the overburden (rubble fill). Subject to the
existing reduced quarry level the Planning
Authority in consultation with the Malta
Resource Authority will decide to what depth
(above mean sea level), if any, further
deepening of the site is acceptable.
(Part C; Chap. 9,
DC13, p 83)
Mr. Paul Vella

04.12.01
Policies in respect of water protection GF/170/01/24

should be revised, taking into consideration
conclusions reached in more recent studies.
Comment noted.
41
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Part C; Chap. 9,
DC15, p 84)
Mr. Paul Vella

04.12.01
Most Local Councils are imposing GF/170/01/24

unreasonable and exaggerated restrictions.
The Plan in admitting the strategic importance

of Minerals also emphasis within reason, the
need to mitigate and address any deriving
impacts.
Part C; Chap. 9,
DC16, p 85)
Softstone
quarry owners
31.10.01
Buildings related to quarry operations GF/170/01/21A/

should be considered as an integral part of T
quarry operations and should therefore not
require a separate application for the
specified proposed development
In the absence of a quarries management plan

it is not possible to distinguish development
that is strictly an integral part of quarry
operations (hence strictly required for the
quarry to operate efficiently) and other
development that is considered as ancillary to
the mineral workings. In applying for new
quarry sites or extensions to existing mineral
workings, quarry owners are advised to
submit full details of development that is
considered as ancillary or is strictly related to
quarry management.
Part C; Chap. 9,
DC17, p 86)
Ms. A.
Farrugia
26.10.01
The proposed noise limits need to be GF/170/01/20

specific, not a range. (The proposed
guidance is like saying the speed limit is 70
to 100 kph, take your pick!). It is
recommended that the policy refer to 55dB
LAeq(1 hour) in keeping with the specimen
conditions at Appendix 1 of Volume 2 (and
as recommended by the UK guidelines
Comment noted. The lower maximum level as

recommended (55dB LAeq(1 hour) ) will be that
applied if a quarry lies in close proximity to
sensitive third party property. Otherwise a
maximum value of 60dB LAeq(1 hour) will be
adopted. Plan will be updated accordingly.
42
Policy
(Ref. Page)
Respondent/
Date
Ref.
(MPG11).
(Part C; Chap. 9,
DC17, p 86)
Mr. Paul Vella

04.12.01
More reasonable measures should be GF/170/01/24

introduced. (Surely quarries produce less
noise than places of entertainment such as
discos.
The yardstick used to control impacts from

mineral workings is that recommended as per
recognised
international standards (BS,
USBM).
Part C; Chap. 9,
DC17, p 86) DC
20, p 89)
Hardstone
quarry owners
12.11.01
Building Development schemes should not GF/170/01/22A/

be allowed to encroach on to existing T
permitted mineral workings and hence
sterilise precious mineral resources. From
past experience neighbouring communities
are notorious for complaining against
quarry operations.
Policies DC17 and DC20 provide the

necessary safeguards that are on the one hand
expected to offer protection to mineral
workings and on the other hand minimize
deriving impacts on
neighbouring
communities by maintaining a minimum safe
distance between the two different land uses.
(Part C; Chap. 9,
DC18, p 87)
Ms. A.
Farrugia
26.10.01
Stockpiles should be covered, or if long GF/170/01/20

term, planted to prevent dust.
Comment noted. A further bullet point will be

included to cater for the requirement or
otherwise to cover or superficially consolidate
aggregate heaps.
Part C; Chap. 9,
DC19, p 88)
Hardstone
quarry owners
13.11.01
Is it necessary to monitor every single blast GF/170/01/22A/

since charging for blast monitoring is an T
additional production cost which constitutes
a further economic burden that must be
borne by the quarry owners at a time when
Regular Blast monitoring in quarries is

entirely in the interest of the quarry operator
as much as it is in the interest of neighbouring
third parties. All other options would spell
headaches on the part of quarry operators who
43
Policy
(Ref. Page)
Respondent/
Date
Ref.
marketing price of the quarried resource is

unsustainable.

more often than not shall need to sustain/
justify resulting impacts with neighbours. On
the other hand the Planning Authority requires
the data recorded from each individual blast in
order to ensure compliance with permit
conditions and the Code of Practice for
Mineral Workings and Restoration.
Part C; Chap. 9,
DC19, p 88)
Mr. Paul Vella

04.12.01
Conditions are already too rigid
GF/170/01/24
(Part C; Chap. 9,
DC20, p 89)
Mr. E. Magri,
12.12.01
No effort should be spared in emphasizing

the importance of restricting the granting of
building permits near to existing quarries
that have the potential of expanding to fully
exploit the resource in the area. In this
respect reference should also be made to
Structure Plan Policy MIN 1.
(Part C; Chap. 9,
DC22, p 89)
Ms. A Farrugia
26.10.01
Cumulative Impacts:
GF/170/01/20
The assessment of cumulative impacts is
vital, however, the implementation of this
GF/170/01/25
Conditions that will relate to the use of

explosives for rock excavation purposes, will
within reason conform to the need for limiting
and mitigating any resulting impacts;
especially in view of generally resulting close
proximity to third party property.
Comment noted.
Irrespectively of whether a quarry is

owned/managed by a single or multiple
entities, the quarry licence/permit is tied to the
44
Policy
(Ref. Page)
Respondent/
Date
Ref.
policy is fraught with difficulties, especially

where the quarries are owned by 2 or more
companies, and operate under separate
licences
and
differing
management
philosophies. Where the opportunity does
arise, however, such as that area around
Wied Moqbol, as discussed with your
Minerals Planning Unit, it would be
appropriate to draw up an action area plan
under the auspices of the subject plan. It
would be appropriate to mention this under
Policy DC22. In fact, it would also be
appropriate to indicate that such an action
plan would be mandatory for the extension /
new quarries proposed in the Wied Moqbol
area. We are sure that other areas could also
be mentioned.
(Part C; Chap. 10,
p 91)
Mr. E. Magri,
12.12.01
RES
policies are considered too
committing when applied to a quarry that is
still in an early stage of development.
Whilst it is appreciated that thought must be
spared for the eventual re-use of the site, it
would be rather premature for any quarry
owner to commit himself to what might he
develop the site into after the exhaustion of
the resource.

specific land-use (area effected by quarrying)
and not to the said entity/ entities. A permit
for a new or an extension to an existing quarry
is normally issued pending satisfactory
mitigation of identified cumulative impacts;
especially if such an application also includes
the requirement for an EIA. A permit may not
be issued in such cases where significant
adverse impacts are envisaged. The Plan will
include a recommendation for the drawing up
of action plans by local Plans, especially
where it can be identified that mineral
workings are conducive to significant
cumulative impacts on the landscape character
of areas and/or the amenity of residents.
GF/170/01/25
Good quarry practice require that Restoration/

rehabilitation of a quarry site progressively
follow in immediately after land forming part
of a quarry permit can no longer be exploited
or has alternatively become exhausted. For
this reason it is advisable, in the early stages
of the development of a quarry, to
simultaneously plan ahead both the way in.
which a particular site will be quarried and the
45
Policy
(Ref. Page)
Respondent/
Date
Ref.

methodology that will be adopted to restore
the commercial and esthetic value of the land
(Part C; Chap. 10,

RES1, p 93)
Mr. Paul Vella

04.12.01
It is very difficult for one to anticipate what GF/170/01/24

is going to happen after the quarry is
exhausted. (Say 20 years from today)
Granted. None the less the Plan requires that

operational quarries be covered by approved
restoration schemes and that such schemes
within reason should be implemented in
phases throughout the lifetime of a quarry.
Such schemes should conform with Local
Plan recommendations.
Part C; Chap. 10,

RES2, p 93)
Softstone
quarry owners
31.10.01
In view of the fact that permitted quarrying GF/170/01/21A/

is normally over a period of between 7 to T
10 years, and given the relatively limited
size of quarries, it is not possible to carry
out phased restoration of quarries; also in
view of the fact that disused parts of
quarries are normally used in conjunction
with ancillary quarry uses.
Good management practice requires that

quarry
restoration
be
planned
and
implemented as early as possible, well in
advance during the lifespan of a quarry. This
is necessary in order to restore precious land
to useful application and limit the visual
impact
and
other
resulting
social/
environmental impacts. Whenever possible
(available space and access), phased
restoration of an operational quarry, is the
preferred option. On the other hand, given the
limited size of local quarries, it is understood
that phased restoration is not always an
option. Installation of ancillary plant in a
quarry is not necessarily the recommended
46
Policy
(Ref. Page)
Respondent/
Date
Ref.

after-use
planning
option.
Any
auxiliary/ancillary development should as a
general rule be dismantled as soon as
quarrying has ceased.
(Part C; Chap. 10,

RES4, p 94)
Mr. P. Zammit
Briffa 19.10.01
The implication of land filling of quarries

with waste are not well defined in the plan.
The plan does not give clear definitions of
waste and seems to poorly comprehend the
implications of the landfill directive of the
EU.
(Part C; Chap. 10,

RES6, p 94)
Mr. Paul Vella

04.12.01
We agree that agricultural land should be GF/170/01/24

reinstated. However, it does not make much
sense to store the soil until the quarry is
exhausted. The soil can be utilised while the
quarry is operating.
Comment noted. Soil that is required in

conjunction with approved restoration
schemes should whenever possible retain the
same properties (clay content, PH value,
organic and mineral content) as that originally
occupying site.
Part C; Chap. 10,

RES 7, p 95,
RES8, p 95,
RES9, p 97)
BICC
15.01.02
Currently there exists a high demand for GF/170/01/27

warehousing
which could ideally be
accommodated as part of the rehabilitation
of disused quarries. It goes to reason that
Comment noted. Quarry restoration schemes

whenever possible conform with approved
land uses as specified within the framework of
approved Local Plans. While at present a
GF/170/01/16
The Plan only recommends inert waste for

reclamation purposes in disused quarries.
However in applying Minerals polices for
quarry reclamation purposes extensive use is
made of the Waste Management Subject
Plan which clearly defines the different types
of waste and methods of waste disposal in
conformity with the landfill directive of the
EU.
47
Policy
(Ref. Page)
Respondent/
Date
Ref.
not all quarries are suited for such purposes

and that certain conditions would need to be
imposed so as to safeguard aspects such as
the surrounding environment or the ground
water table. The Plan in coordination with
Local Plans could play a more proactive
role in promoting disused quarries for
special types of development.
very limited number of quarries is covered by

approved restoration schemes, the Plan
requires that all quarries be covered by such
schemes shortly after the publication of the
Plan. Although as rightly pointed out,
different types of schemes will apply to
different quarries depending on a number of
criteria that must be met, the Plan does not
exclude that such forms of restoration
solutions will also include warehousing or
other special types of development.
(Part C; Chap. 10,

RES 7, p 95,
RES8, p 95,
RES9, p 97)
Hardstone
quarry owners
13.11.01
It is not possible for quarry owners to GF/170/01/22A/

indicate what restoration plans exist for T
their sites at the Local Plan formulation
stage. It is difficult to make predictions for
quarries that will take some time to exhaust
their resources.
While acknowledging that it is often not clear

what restoration scheme best to adopt for a
given quarry site, it is none the less important
that individual quarry owners provide Local
plans with at least indicative restoration plans
so that the Planning Authority can come up
with a reclamation strategy on an area based
approach.
art C; Chap. 10,

RES8, p 95)
Mr. A.N.
Welsh
14.10.01
The plans for infill of worked-out quarries GF/170/01/13

should be given more teeth; clean stone
waste or builders rubble should not be
tipped at Maghtab etc. but put straight down
these unsightly and dangerous holes.
Tipping of inert waste at Maghtab or any

other form of engineered/sanitary landfill is
not an option. The recommended way forward
envisages the reduction of inert waste through
better management/ planning of our mineral
48
Policy
(Ref. Page)
Respondent/
Date
Ref.

resources and successively maximizing on
other options whereby a substantial proportion
of inert waste construction materials are
reutilised/recycled.
(Part C; Chap. 10,

RES 9, p 97)
Hardstone
quarry owners
12.11.01
Is it envisaged in the Plan that a number of GF/170/01/22A/

quarries within a specific area could be T
covered by a single restoration scheme for
the whole area. Such a scheme would be
desirable in areas already committed to
activities related to quarrying/building
materials.
Policy RES9 provides guidelines under which

such a form of restoration can be considered.
The needs of existing activities related to
quarrying/building materials must to be
accommodated in one way or other within the
context of such a scheme.
(Part C; Chap. 10,

RES10, p 98)
Hardstone
quarry owners
12.11.01
Larger and groups of quarries that are GF/170/01/22A/

suitably located on urban/urban fringe areas T
should be utilized to create recreation
amenities or for small light industrial
development.
Such schemes are normally envisaged within

the framework of land uses allocated by Local
Plans. However the Plan provides the
guidelines under which such land uses may be
considered in conjunction with the restoration
of spent mineral workings.
(Part C; Chap. 10,

RES10 / RES11, p
98)
Mr. Victor Hili

28.08.01
Is it contemplated that a disused quarry may GF/170/01/3

be rehabilitated to other uses besides
agriculture.
Yes the Plan offers clear guidelines with

regards to the issue of quarry afteruse, and in
particular for such cases where quarries are
located in urban/urban fringe areas or in rural
locations.
49
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Coastal Areas, p
99)
BICC
06.02.02
It is recognised that the amount of re-cycled GF/170/01/29

or re-used C & D Waste will never reach a
high percentage and there are not enough
used quarries to take all the quantity of C &
D Waste. The bulk of the C & D Waste
results from rock excavation which is clean
and inert. It is therefore advisable to
dispose the excess clean excavated rock in
Governmentdesignated dumping grounds
at sea. This will create more areas for
marine habitat. It is not advisable to
dispose this C & D Waste close to the
shores for land reclamation on large scale.
This is said for various reasons.
1. The depth of the sea would be around
40 metres and the cost for the
construction of sea-walls would be
prohibitive.
2. There would be the danger that a seawall gives way during a storm while
being constructed and the material
would spread all along the shores,
resulting into a disaster for the flora
and fauna and the Tourism Industry.
3. The reclaimed land could only be
possible within bays or areas close to
the shore. This land would only take a

Comment noted. The effect of construction
waste on marine habitats has yet to be
investigated; the effect left by the dumping of
wastes in the approved spoil grounds off the
coasts of Malta is yet unknown.
Effects/impacts are likely to be site-specific:
the impact caused by the material on existing
habitats may well be deleterious, and may
upset habitats of significant environmental
/economic importance. The transboundary
effects, particularly where migratory species
are involved (whose breeding/feeding grounds
are frequently unknown), will probably be
severe.
The use of hard materials to create solid
substrates for marine biota has been
investigated elsewhere. However, should a
suitable location be identified where such
development may be beneficial (i.e. the site is
not
significant
in
terms
of
biodiversity/productivity), the dumping of
materials must first be processed to eliminate
environmental hazards (e.g. fines), and
deposited in the appropriate manner.
Furthermore, the geochemical/ geophysical
behaviour of the material must be evaluated
scientifically, to verify that the material is
50
Policy
(Ref. Page)
Respondent/
Date
Ref.
few years to be reclaimed. Furthermore, the

utilisation of the reclaimed land is very
doubtful since any buildings would spoil the
view of the inner buildings.
indeed suitable for habitat creation projects.

Dumping of inert waste at sea is covered in
detail in the Minerals Subject Plan: Space For
Waste.
(Part C; Chap. 11,

pp 101-102)
Dr. Godwin
Debono
23.01.02
The section on Oil and Gas is somewhat GF/170/01/28

poorly covered. Reference to the Petroleum
(Production) Regulations 2001 would be
useful.
Comment noted. The main objective of the

Plan at this stage is to set in practice the
planning process as it applies to oil and gas
exploration and production. The Petroleum
(Production) Regulations, 2001, although a
formidable bureaucratic and management tool
are beyond the scope of planning law.
However the section of oil and gas may
necessarily need to be revised and treated in
more detail in the process of future updates to
the Plan should Oil and Gas exploration and
exploitation activity be intensified.
(Part C; Chap. 11,

p 101 11.1 last
line)
Dr. Godwin
Debono
23.01.02
Text relating to drilling of wells has been GF/170/01/28

overcome by recent events. A well is
envisaged in the immediate future.
Comment noted. Text will be modified to

account of updated information provided.
(Part C; Chap. 11,

p 101 11.2 last
sentence)
Dr. Godwin
Debono
23.01.02
This is not correct. Exploration is an GF/170/01/28

ongoing activity.
Comment noted. Corrections to text will be

made accordingly.
51
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Part C; Chap. 11,

p 101 11.3)
Dr. Godwin
Debono
23.01.02
Exploration contracts have a term of 1 to

1.5 years.
Commented noted. Adjustments will be made
(Part B; Chap. 4,
pp 13-21)
Mr. P. Zammit
Briffa 19.10.01
The Plan is not exhaustive of national GF/170/01/16

mineral resources. Resources such as
phosphorous and chalk are not even
mentioned. A number of banal erroneous
descriptions of local limestone reflects a
poor understanding of the nature of the
mineral resources of Malta.
The Plan is mainly intended as a land use

planning tool. Under no circumstance should
it be intended as a text of local Geology.
Exploitation of other mineral resources
besides limestone, phosphate in particular has
been proved in the past not to be
economically feasible. It is now felt that
attempts to exploit local phosphate reserves
would also have serious impacts on the rural
environment. As to the reference made to
chalk deposits, it should be noted that such
sedimentary rocks are absent from the
stratigraphy of the Maltese Islands. A
reference to the presence of phosphate
mineral resource
(nodules) deposits will
included in the final approved draft.
Part C; Chap. 11,

pp 101-102)
BICC (GRTU)
15.01.02
In Chapter 11 no reference is made to other GF/170/01/27

minerals that are to be found in the Maltese
islands albeit in small quantities. In
particular chalk deposits are present along
parts of the coastline in the South of Malta
In the absence of reliable documented proof

of the presence and extent of chalk or other
mineral deposits within the Maltese islands
the Minerals, mere reference to such minerals
is of no concern to Minerals Planning. Given
52
Policy
(Ref. Page)
(Part C; Chap. 11,

pp 101-102)
Respondent/
Date
Dr. Godwin
Debono
23.01.02
Ref.
and silicates. It is felt that this section is

technically deficient and was not given
serious consideration.
the limited quantities and extent, if any , of

such deposits, they are not considered of any
strategic importance from a land use point of
view. In this respect while mention may be
made of other minerals such as phosphate
which although more abundant cannot be
feasibly exploited, reference to other minerals
of a relatively more limited extent such as
chert and glauconite is more appropriate
within the context of a geology text book.
It may be useful to include in the document GF/170/01/28

a brief account of all the minerals found in
the Maltese Islands and identify
the
economic ones.
The Plan concentrates on limestone

(hardstone and softstone) as the only mineral
resources bearing an economic importance,
since exploitation of these resources is known
to fall within the remits of land use planning.
All other known minerals have so far not
been considered
feasible to exploit
commercially and hence from a land use
perspective are not subject to Planning
control. On the contrary, attempts to exploit a
number of known minerals are expected to
have
serious
environmental/ecological
impacts. Oil and Gas, although as yet
undiscovered
in
economic
quantities,
especially if onshore deposits are discovered,
53
Policy
(Ref. Page)
Respondent/
Date
Ref.

would constitute a significant land use
planning constraint that would definitely fall
within the remits of planning legislation.
However, adjustments will be made in the
Plan to include a reference to phosphate
which is mainly available in relatively thin
layers marking the three main subdivisions of
the Globigerina Limestone Formation.
(Part C; Chap. 11,

pp 101-102)
Dr.Godwin
Debono
23.01.02
As natural salt is an economic mineral salt, GF/170/01/28

do you think it should be treated in the
document? I think it should.
Comment Noted. A section on salt extraction

will be included in the Plan. However no ad
hoc policies will be included at this stage,
considering that the current Plan Policies
adequately address related forms of
development arising.
(Part D; Chap. 12,

pp 107-111)
Hardstone
quarry owners
12.11.01
The issue of quarry permits subject to GF/170/01/22A/

renewal on a yearly basis is not practical. T
The period is too short considering that
quarry permits are normally issued on the
basis of exploitable mineral resources
which according to existing structure Plan
policy MIN10 should in any case be in
excess of 10 years.
Presently the requirement for annual renewals

of minerals planning permits is necessary in
abeyance of settlement of the pending dispute
with the quarry owners representatives over
the restoration bonds. The Subject plan
recognizes the need to issue longer term
permits and proposes that restoration bonds
should be pooled in order to iron out the
burden of single quarry owners having to
sustain the full weight of bank guarantees.
Once such a scheme would be in place then
54
Policy
(Ref. Page)
Respondent/
Date
Ref.

quarry permits may be issued for 5 years,
renewable.
Part D; Chap. 12,

pp 107-111)
BICC (GRTU)
15.01.02
Imposition of restoration bonds on quarry GF/170/01/27

operators, often at the sole discretion of the
Planning Authority, has proved to be a very
contentious issue. While the need to impose
safeguards in order to ensure compliance
with permit conditions is understood, none
the less imposition of substantial bond taxes
even further the finances of the quarry
operator.
Comment noted. The Development Planning

Act 1992, requires that permit conditions are
duly complied with, if necessary through
imposition of bonds. While it is understood
that such guarantees do not impose excessive
burdens on quarry operators, it would be futile
to expect quarry owners to fulfill the
requirements of approved restoration schemes
unless such schemes are adequately covered
by guarantees in one form or other. Such
guarantees may however be collective and
governed by a single collective fund to which
the Planning Authority will retain the right of
forfeit (access and appropriation of monies)
in case any of the quarries covered by the
bond fails to satisfy in full the requirements of
an approved restoration scheme. Although it
is highly unlikely that such a situation will
arise it is none the less up to the Planning
Authority to physically be able to execute the
required restoration works at the expense of
the defaulting party/s.
55
Policy
(Ref. Page)
Respondent/
Date
(Appendix A; pp
1-6; Appendix B;
pp 1-9)
Dr.Godwin
Debono
23.01.02
Ref.
The reference to the future issuing of some

form of Quarry Regulations by PA (or GF/170/01/28
MRA) is probably needed. The policies
listed in appendix A and B do not
adequately cover this requirement. For
instance Health and safety management and
operations management requirements need
to be specified in detail.
(Appendix B; pp
1-9
upplimentary Doc.
Annex 1,
Hardstone Quarry
boundaries
N/C
Dr.Godwin
Debono
23.01.02
N/C
The policies produced in appendices A and B

are intended for use in conjunction with the
issue of development permits regulating land
use with respect to mineral workings and
other ancillary development. Management
plans conforming to set national and/or
international standards although highly
desirable, fall outside the terms of reference
of the Plan. The drafting of management plans
for mineral workings and ancillary operations
in Malta falls within the remits of other
entities directly or indirectly responsible for
the management of mineral workings.
Management plans must necessarily conform
and tie up and conform with land use policies
and in particular with the Code of Practice
For Quarry Working and Restoration .
N/C
Plan HM19 in the Supplementary GF/170/01/28

Documentation
should
read
Lower
Coralline Limestone not UC
N/C
Comment noted. Wording will be modified

accordingly
56
Policy
(Ref. Page)
Respondent/
Date
Ref.
Supplimentary
Doc. Annex 1,
Hardstone Quarry
boundaries
Dr.Godwin
Debono
23.01.02
Plan 13A should read Upper Coralline

Limestone not LC
GF/170/01/28
Comment noted. Wording will be modified

accordingly
(Supplimentary
Doc.; Annex 2, pp
1-6)
Mr. Twanny
Baldacchino
29/08/01
If the survey was carried out calculating

only the quarries operating with a permit,
then it was definitely not correct. How long
did it take to complete the report.
GF/170/01/4/M
It took three years to finalise the plan with the

help of foreign consultants. It would have
been much better had the quarry operators
cooperated co operated, but since they did not
provide the requested information the
Planning Authority had to come up with
estimates.
(Supplimentary
Doc., Annex 2, pp
4-6
Mr. A. Fenech
Vella 29/08/01
How was the quarry depth measured. The

average output from a quarry over a given
time span will be different from that
measured at a different point in time.
GF/170/01/4/M
Quarry depths were measured from aerial

photographs and differences in levels were
picked up from photographs taken at two
distinct points in time; namely 1994 and 1998.
Although the Plan does not make a
contingency in view of a possible increase in
the production rate between 2002 and 2010,
proved permitted stocks are well in excess of
the estimated production rate. However
through regular monitoring of the production
it shall be possible to keep track of any
changes in the demand for the resource over
time. Such changes will be taken into account
57
Policy
(Ref. Page)
Respondent/
Date
Ref.

in the forthcoming Plan review five years
from now.
Supplimentary
Doc., Annex 2, pp
4-6)
Mr. A. Zammit
17.10.01
(Supplimentary
Doc.; Annex 2, pp
1-6)
BICC (GRTU)
(Supplimentary
Doc., Annex 2,
Mr. P. Zammit
Briffa,
15.01.02
The PA is stating that there is sufficient

hardstone material of suitable quality for a GF/170/01/15
number of years, and in this respect, we beg
to differ since the PA did not distinguish
between prima and sekconda material.
The average consumption as calculated by
the PA was based on a relatively short time
span and is for this reason not indicative of
the actual consumption. The analysis by the
PA is as such considered as being over
simplified.
Comment noted. Please refer to earlier reply

to comments under same heading.
The methodology adopted in establishing GF/170/01/27

the figures relating to both the current levels
of extraction from softstone and hardstone
quarries are seriously flawed and hence the
estimated projections relating to the
available supply for the next thirty years are
overly optimistic.

The plan gives estimates of good quality GF/170/01/16

rock reserves available in terms of years of
Estimates that were carried out for the

purpose of assessment of existing permitted
58
Policy
(Ref. Page)
Respondent/
Date
Ref.
pp 5-6)
19.10.01
hardstone and softstone production. The

calculations of these estimates are unclear
since they do not include quality of stone or
a scientific description of the stone.
reserves was based on overall production

figures. Since it would be almost impossible
(at least in the short term) to stratigraphically /
geotechnically assess the mineralogical
properties of every permitted quarry site, the
figures reproduced are based on the overall
production requirements (involving different
grades/quality of minerals) over the period
1994/98 and an assessment of the total
quantities of minerals remaining unexploited
within the permitted quarry boundaries.
(Supplimentary
Doc., Annex 2, pp
5-6)
BICC (GRTU)
15.01.02
It is a fact that even what is theoretically GF/170/01/27

considered to form part of the available
supply could in practice prove to be
unavailable for extraction.

(Supplimentary
Doc., Annex 2, pp
5-6)
Mr. A. Zammit
28.09.01
One has to remember that not all hardstone GF/170/01/11

material is made from the same quality. The
best quality prima is utilized for
prestressed concrete units as well as for
road blacktop construction , whilst the
second quality is utilized for general
concrete production. The production of
these materials will obviously depend upon
the existing projects.
Comment noted. Review of production and

permitted reserves data derived from annual
surveys of operational quarries will reflect
any resulting increase in demand. Such
information will be taken into consideration in
applying policy HS12.
59
Policy
(Ref. Page)
Respondent/
Date
Ref.
(Supplimentary
Doc., Annex 2, p
6)
Mr. A. Zammit
28.09.01
Adopting a hard-line approach by saying GF/170/01/11

that we have sufficient good quality for a
number of years is obviously an
overconfident approach, as the PA has no
information as to the actual reserves of the
two types of hardstone. From feedback
arising from the industry, we can point out
that the actual prima material is running
out and there are very few reserves
available.
Comment noted. Please note ref. 16 under

same heading in view of rock quality. The
Plan promotes the need to efficiently manage
our mineral resources. Recycled softstone and
concrete products could partly replace
precious first quality (prima) hardstone, thus
making reserves last longer. However other
options identified in the Plan include proved
resources in the so called Minerals
Safeguarding areas and the need for further
investigation with respect to additional
surface reserves and underground mining.
(Supplimentary
Doc., Annex 3,
point 3.4, p 17)
Mr. V. Gauci
22.10.01
On p.17 of Annex 3 (Supplementary GF/170/01/18

Documentation) makes reference to EU
Directive 91/692/EEC when the reference
should point to EU Directive 1999/31/EC
Agreed and amendment incorporated.
(Supplimentary
Doc., Annex 3,
chap. 3, point 3.4,
p 17)
Mr. Peter Gatt

4.12.01
According to this section of the Plan GF/170/01/26

restoration of spent quarries involving
infilling will need to conform to EU
directive 91/692/EEC). Since only inert
waste will be used compliance with such a
directive is considered onerous on quarry
operators.
Reference to this directive shall be replaced

by EU Directive 1999/31/EC. It should be
noted the burden of complying with this
directive will depend on the required
operational standards
and mitigation
measures that are demanded in relation to the
type of land filling that is undertaken. Since
only inert waste is acceptable for the purpose
60
Policy
(Ref. Page)
Respondent/
Date
Ref.

of quarry restoration, the onus of complying
with this directive will be of a limited nature.
Supplimentary
Doc., Annex 3,
App. 1, Para. 12 &
Para. 15
p 22)
(Supplimentary
Doc., Annex 3,
App. 1, Para. 13 &
14 p 22)
Note:
Softstone
quarry owners
31.10.01
Softstone
quarry owners
31.10.01
Although quarrying is an ODZ activity the GF/170/01/21A/

boundary wall should be more than 4 crs in T
height; possibly 8 crs in order that no illegal
ODZ rural policies require that boundary

walls be no more than 4 courses in height and
that they consist of rubble walls. Good quarry
tipping by third parties will take place.
practice normally envisages adequate

screening and landscaping of a quarries in
addition to a 4 course boundary wall.
However the Planning Authority takes a
pragmatic view in such cases where there
exists a requirement for safety and other
justifiable reasons dictated by higher
priorities.
With respect to ongoing rumours that quarry GF/170/01/21A/

operations are responsible for damage to T
road surfacing it was pointed out that such
damage is also due to other form of heavy
plant/traffic that is not associated with
quarrying.
Comment noted.
G under reference (Ref.) refers to Public consultation meeting held in Gozo
T under reference (Ref.) refers to Technical meetings with quarry operators
M under reference (Ref.) refers to Public consultation meeting held in Malta
N/C stands for no comments received
61
62
APPENDIX 1
MINERALS SUBJECT PLAN CONSULTATION LIST
1. GOVERNMENT DEPARTMENTS AND LIAISON OFFICERS
Office of the Prime Minister
Ministry for the Environment
Mr. Vince. Gauci, Director Environment Protection Department.
Mr. Mario. Farrugia, Environment Protection Department.
Mr. Andrew Vella, Environment Protection Department.
Mr. Joe Sammut; Director, Waste Mgmt., Works Division.
Mr. Peter Gatt Geologist, Building & Engineering department, Works Division.
Mr. Annetto Portelli, Explosives section, Works Division
Ministry of Agriculture and Fisheries
Mr. Franco Serracino Inglott, Director
Mr. Anthony Mifsud, Department of Agriculture
Mr. Anthony Borg, Department of Agriculture
Ministry for Gozo

Mr. Frank Psaila, Permanent Secretary; Ministry For Gozo, Victoria, Gozo
Mr. Joe Portelli, Director, Ministry For Gozo, Victoria, Gozo
Ministry of Health
Mr. Clifford Cauchi, Department of Health
Ministry of Foreign Affairs
Ministry Of Justice and Local Government

Local Councils
Mr. Anthony Bonello, Executive Secretary, obo Mqabba Local Council
Ms. Antonia Farrugia, Mayor, Zurrieq Local Council
63
Water Services Corporation

Dr. John Mangion
Eng. Paul Micallef
2. PARASTATAL ORGANISATIONS
3. POLITICAL PARTIES AND AFFILIATES
4. UNIONS, EMPLOYERS AND PROFESSIONAL ORGANISATIONS

Unions and Employers
Mr. Vincent Farrugia, Director General, General Retailers and Traders Union,
Professional Organisations
5. NATURAL AND LOCAL AMENITY GROUPS

A.N. Welsh, Chairman The Malta Geographical Society
6. Mr. Philip Zammit Briffa, Hon. Sec. General, Din L-Art Helwa,
7. INDIVIDUALS/ Organisations (Identified for Consultation)

Mr. Vincent Gauci, Director; Environmental Protection Department, Ministry
for the Environment, Floriana
MB
Mr. Joe Sammut; Director Waste Management, Works Division, Ministry for
the Environment, Floriana
MB
Dr. Godwin Debono, Director ; Oil Exploration Division, Office 0f the Prime
Minister, Valletta
OPM
Dr. Saviour Xerri, Petroleum Geologist; Oil Exploration Division, Office 0f

the Prime Minister, Valletta
OPM
Mr. Vincent Cassar A & CE, Director General, Works Division, Ministry for
the Environment, Floriana
MB
Mr. Franco Seracino Inglott, Director;
MB
Mr. Tony Mifsud, Ministry of Agriculture and Fisheries, Valletta
MB
64
Mr. A. Borg , Dept. of Agriculture, Ghammieri Experimental Farm, Luqa
MB
Mr. Victor Rizzo, Director, Local Councils Department, Valletta

Mr. Stefan Scotto, A & CE, Local Councils Department, Valletta
Mr. Vincent Farrugia, Director General; General Retailers & Traders Union,
Valletta
MB
Mr. E. Aquilina, General Retailers & Traders Union, Valletta
MB
Mr. Robert Musumeci, A & CE; Building Industry Consultative Committee,

Naxxar
BICC
Mr. A. Fenech Vella, A & CE: Building Industry Consultative Committee,

Naxxar
BICC
Mr. Conrad Thake, A & CE; Building Industry Consultative Committee,

Naxxar
BICC
Mr. Peter Gatt; Building Industry Consultative Committee, Naxxar
MB
Hon. Edwin Vassallo, Parliamentary Secretary, Min. For Economic Services,

Auberge DAragon, Valletta
Mr. Frank Psaila, Permanent Secretary; Ministry For Gozo, Victoria, Gozo
Mr. Joe Portelli, Director, Ministry For Gozo, Victoria, Gozo
Dr. J. Mangion, Hydrogeologist; Water Services Corporation, Luqa
MB
Mr. Andrew Seychell, A.C., Weapons Office, Security Branch, Police Head
quarters, Floriana
Mr. Vincent Grech P.C.Weapons Office, Trade Licensing Department, Police
Head quarters, Floriana
MB
Hon. George Pullicino, A & CE, Parliamentary Secretary, Ministry for Home
Affairs, S. Venera.
Dr. Ray Busuttil, Director, Ministry for Health, Palazzo Castellania ,
Valletta
MB
Mr. Edwin Calleja, General secretary, Federation of Industry, Floriana

Mr. Kevin Borg, Chamber of Commerce, Valletta
Ms. Catherine Galea, A & CE, Chamber of Architects, Paceville
65
8. PRIVATE ARCHITECTS
Mr. A Fenech Vella A & CE, BKara BKR 10
Mr. A. Zammit A & CE, Emm. Zammit & Associates, Zurrieq
9. PRIVATE INDIVIDUALS
Mr. Carmel Grima, Kercem, Gozo. (Tel. 554811)
Mr. Victor Galea, Coralline Stone Malta Ltd., Attard
Mr. Saviour Mallia, Ta l-Ibragg, St. Julians
10. PUBLIC CONSULTATION MEETING, S. LAWRENZ HOTEL, S.

LAWRENZ, GOZO
Mr. Michael Curmi, Sannat quarry and lime kiln, Sannat, Gozo
Mr. Mario Gatt, Hardstone Quarry HG 10, l/o Qala, Gozo
Mr. Victor Hili, Hardstone Quarry HG 12, l/o Qala, Gozo
Mr. Ferdinand Zammit, Softstone quarry, Gharb, Gozo
Mr. Noel Formosa, San Lawrenz Local Council, San Lawrenz, Gozo
Mr. Paul Zahra, San Lawrenz Local Council, San Lawrenz, Gozo
Ms. Gillan Martin, Public
Mr. John Saliba, A & C.E., Xlendi, l/o Munxar, Gozo
Mr. Andrew Vella, Environment Protection Department, Ministry for the
Environment, Malta
11. PUBLIC CONSULTATION MEETING, MEDITERRANEAN

CONFERENCE CENTRE, MALTA
Hardstone Quarry Owners
Mr. Joe Abdilla, Ramel u Zrar Ltd., HM 1, Dingli, HM 4 (part of)
Mr. Gaetano Abdilla, Ramel u Zrar Ltd.,Gaetano Abdilla & Sons, HM 4A & Hm 30,
Dingli
Mr. Carmel Abdilla, Ramel u Zrar Ltd.,Gaetano Abdilla & Sons, HM 1 & Hm 30,
Dingli
Mr. Paul Polidano, Polidano Bros., HM33 & HM7, l/o Siggiewi
Mr. Emanuel Aquilina, Sand & Gravel Ltd. HM 3 & HM 12, Attard
66
Mr. Ruben Aquilina, Zrar Ltd., HM 35, Ta Zuta l/o Siggiewi

Mr. Emanuel Bonnici, Zrar Ltd., HM 35, Ta Zuta l/o Siggiewi
Mr. Joe Camilleri, obo J. Camilleri Ltd., HM26, Zurrieq
Mr. Gaetano Ciantar, Hal Far Quarries, HM 19, Zurrieq
Mr. Paul Debono, Debono Enterprises, HM 19, Zurrieq
Mr. J. Galea obo Wied Ghomor Quarries Ltd, HM 11, S. Gwann
Mr. Jimmy Gatt obo Gatt Bros. Ltd. HM 28, Naxxar
Mr. Joseph Gatt obo Gatt Bros. Ltd. HM 28, Naxxar
Mr. Joseph Mercieca, Hal Far Quarries, HM 19, Zurrieq
Mr. Emanuel Mifsud, SM 52, Tal-Hagra, Mqabba
Mr. Joe Vella, Carmel Vella ltd., HM 37, Ta Kaduma l/o Mgarr
Mr. Joe Vella Borg, A. Vella Borg, Tat-Tomna, l/o Mellieha
Mr. Zaren Vella, Vella Bros. HM 31, Dingli
Softstone Quarry Owners

Mr. Albert Agius with Mr. L. Micallef A & CE, SM 55,Qrendi & SM 78, Qrendi
Mr. Anthony Bondin, Bondin Quarry Ltd., SM27, Ta L-Isqof, Mqabba
Mr. Angelo Bonello, SM 8, Siggiewi & SM 59, Mqabba
Mr. Gorg Bonello, HM 15, Siggiewi
Mr. Emanuel Camilleri, HM 28, Tal-Mentna, Mqabba
Mr. Joe Cauchi Carmel Vella Ltd., HM 21 & HM 9C, Naxxar
Mr. Paul Cilia, SM 18, Misrah Sinjura, Qrendi
Mr. Alex Ghigo, SM 19, Ta L-Isqof, Imqabba
Mr. Joseph Mangion, SM 7, Tas-Sejba, Mqabba
Mr. Emanuel Psila, SM 79, Wied ta Kandja, Mqabba
Mr. Twanny Theuma, SM 39, Tas- Sienja, Kirkop
Mr. Carmel Vella, SM 37, Tat-Tabib, Iklin
Ancillary Services
Mr. Anthony Cini, Blast Monitoring Consultant, EMS
Mr. J. Abela, Blasting contractor
Mr. Paul Bonavia, J.Bonavia Excavations Ltd., Contractor
Mr. Victor Galea, Coralline Stone Malta, Recycling and stone processing facilities
Public
Mr. Ray Bondin A. & C.E.
67
Dr. Conrad Thake, A. & C.E.

Mr. Lino Bianco, EIA Consultant
Mr. Peter Gatt, EIA Consultant
Mr. Clifford Cauchi, Health Department
Dr. Vince Buhagiar, A. & C.E.
Dr. Godwin Debono,Director, OPM, Oil Exploration Department
Dr. Saviour Xerri, OPM, Oil Exploration Department
Mr. Anthony Fenech Vella, A. & C.E.
12. QUARRY OWNERS TECHNICAL MEETINGS

Softstone
Mr. Albert Agius with Mr. L. Micallef A & CE, SM 55,Qrendi & SM 78, Qrendi
Mr. Paul Cilia, SM 18, Qrendi
Mr. Paul Falzon with Mr. Hector Zammit A & CE, SM 76, Mqabba
Mr. Joseph Mangion, SM 7, Mqabba
Mr. Emmanuel Mifsud SM 52, Mqabba & SM 66, Mqabba
Mr. Nicholas Farrugia SM 23, Mqabba & SM 50, Mqabba
Mr. Angelo Bonello, SM 8, Siggiewi & SM 59, Mqabba
Mr. Angelo Cassar SM 54, Mqabba & SM 69, Mqabba
Mr. Michael Cauchi, SG 1, Kercem, Gozo
Mr. Francis Bugejja, SG 2, S. Lawrenz, Gozo
Mr. Teddy Grima with Mr. Dione Galea A & CE, SG 3, S. Lawrenz, Gozo
Mr. Joseph Attard, SG 4, S. Lawrenz, Gozo
Mr. Ray Cefai, SG 6, S. Lawrenz, Gozo
Mr. Joseph Zammit, SG 7, Kercem
Mr. Carmel Azzopardi, SG 8, S. Lawrenz, Gozo
Mr. Domenic Mercieca, SG 9, S. Lawrenz, Gozo
Hardstone
Mr. Joe Abdilla, Ramel u Zrar Ltd., HM 1, Dingli, HM 4 (part of)
Mr. Gaetano Abdilla, Ramel u Zrar Ltd.,Gaetano Abdilla & Sons, HM 4A & Hm 30,
Dingli
Mr. Emanuel Vella, Mr. Zaren Vella, Vella Bros. HM 31, Dingli
Mr. Anthony Feneck Vella A & CE, obo Vella Bros.
Salvu Bonnici obo Zrar Ltd, HM 35
68
Mr. Ray Sammut A & CE, obo Zrar Ltd.

Mr. Emanuel Aquilina, Sand & Gravel Ltd. HM 3 & HM 12, Attard
Mr. Lorry / Mr. Antoine Saliba obo Saliba Bros. Ltd, HM 8 Zejtun
Mr. Etienne Magri A & CE, Sant & Mugliette obo Saliba Bros. Ltd.
Mr. Pierre Zammit A & CE
Mr. Joe Cauchi Carmel Vella Ltd., HM 21 & HM 9C, Naxxar
Mr. J. Galea obo Wied Ghomor Quarries Ltd, HM 11, S. Gwann
Mr. Paul Vella (Ballut Blocks) & Mr. Joseph Vella (Hallmann), HM15 & HM 22,
Mosta
Mr. Gaetano Ciantar, Hal Far Quarries, HM 19, Zurrieq
Mr. A. Vella Borg, Tat-Tomna Quarry, HM 13, Mellieha
Mr. Paul Xuereb, Hardrocks Ltd., HM 29, Mgarr
Mr. Edgar Attard Montaldo A & CE obo Blokrete Ltd. HM 23, Mosta
Mr. Jimmy Gatt obo Gatt Bros. Ltd. HM 28, Naxxar (Excused)
Mr. Joe Camilleri, obo J. Camilleri Ltd., HM26, Zurrieq (Excused)
13. MINERALS ADVISORY BOARD
Abbreviations
used:
MB = Minerals Board; OPM = Office of the Prime Minister; BICC = Building Industry Consultative
Committee
69
APPENDIX 2
Reference (File ref. GF/170/01)
List to Summary of Response - Public Consultation Draft (August 2001)
Consultee
File entries
Mr. Carmel Grima, Kercem Gozo.
Dr. Ian Micallef L.L.D. obo Local Councils Association, Quarries Subcommitee, Balzan
Public Consultation Meeting, San Lawrenz Leisure Resort, San Lawrenz,

Gozo
Public Consultation Meeting, Mediterranean Conference Centre, Valletta,
ANON
Mr. Victor Galea, Industrial Estate, Attard
Mr. Saviour Mallia, Ta l-Ibragg, St. Julians
Mr. Anthony Bonello, Exec. Sec., obo Mqabba Local Council, Mqabba
Presentation of Minerals Subject Plan at BICC office, Naxxar
Mr. Vincent Farrugia, Director General, General Retailers and Traders

Union, Valletta
10
Mr. A. Zammit BE & A (Hons) A&CE, Emm. Zammit & Associates,

Zurrieq
11
A.N. Welsh, Chairman, The Malta Geographical Society, Qrendi
13
Mr. Philip Zammit Briffa, Hon. Sec. General, Din L-Art Helwa, Valletta
16
Mr. A Fenech Vella A & CE, BKara
17
Mr. V. Gauci, Director, Environment Protection Department, Min. For

the Environment
18
Mr. Robert Musumeci, A & CE , Building Industry Consultative

Committee, Naxxar
12
15
23
19
27
29
Mr. Robert Musumeci, A & CE Mayor Siggiewi Local Council, Sigiewi
19
27
Ms. Antonia Farrugia, Major, Zurrieq Local Council, Zurrieq
28
Consultation meetings with softstone quarry owners
21
21A
Consultation meetings with Hardstone quarry owners
22
22A
Mr. Paul Vella, Ballut Blocks Ltd., Wied Filep L/o Naxxar
24
Mr. E. Magri, A&CE, Sant & Mugliette, obo Salibs Bros. Ltd., BKara
25
Minerals Advisory Board No. 30, Minutes of meeting 4.12.01
26
Dr. Godwin Debono, Oil Exploration Department, O.P.M.
28
70
71
APPENDIX 3
PUBLICITY / MEDIA COVERAGE
72
73
Journal of the Royal Town Planning Institute
3 July 1998
The Malta Independent
3 rd June 1999
74
The Times
NEWS
3 rd June 1999
Ahbarijiet Lokali
L-Orizont
4 ta Gunju 1999
75
76
LAUNCHING OF THE PUBLIC CONSULTATION DRAFT
77
78
THE TIMES MONDAY AUGUST 27, 2001
L-Orizont Il-Hamis, 23 ta Awissu, 2001
OPINION
79
THE TIMES, THURSDAY, AUGUST 23, 2001
80
The Malta Independent
Wednesday 29 August 2001
THE TIMES, MONDAY, SEPTEMBER 3, 2001
81
82
KUNSILL LOKALI MQABBA
DICEMBRU 2001
83

Minerals Summary of Public Consultation

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MINERALS SUBJECT PLAN

PUBLIC CONSULTATION AND PUBLICITY

SUMMARY APPRAISAL OF MAIN COMMENTS

Summary of Response on:

Conclusions, Recommendations and Implementation

REVIEW OF THE STRUCTURE PLAN POLICIES

MINERALS SUBJECT PLAN POLICIES

Minerals Subject Plan Consultation List

Reference List To Summary Of Response

A three pronged approach was adopted, consisting of consultation prior to

The three main stages of publicity were:

Inception Meetings (May August 1999)

Public consultation Draft

Consultation involved Government Departments; Parastatal organizations;

An appropriate evaluation of the submissions required that the presentation

Major Changes to the Minerals Subject Plan Public Consultation Draft

As a result of this consultation process a number of amendments were made

Executive Summary para.

Included reference to other minerals, in particular phosphate

Executive Summary para.

Replaced lines 2 to 6 with new text conforming to the Solid

Part A; Chap 1, para. 1.2,

Included reference to other minerals

Part A; Chap 1, para. 1.7,

Included new para. 1.7 on salt production in Malta

Part A; Chap 1, para. 1.8

Para 1.7 replaced by para. 1.8 with minor amendments to text

Part A; Chap 1, under

Added text re actions required to implement the Plan

Part B; Chap. 4, point 4.4,

The term non-porous was replaced by scarcely porous

Part B; Chap. 4, pp 16 -19

Updated statistics in tables 4.1 through 4.4

Part B; Chap. 5, p 33 para.

Now on p 34 and included information from the Solid Waste

Part B; Chap. 5, para. 5.48

Omitted and replaced by 5.48, p35, including revised figures for

Part B; Chap. 5, para. 5.48

Omitted and replaced by 5.48, p35, including revised figures for

= changes derived from internal consultation

Part B; Chap. 5, p 34,

Table Deleted from Plan

Part B; Chap. 6, para. 6.49,

Content in point 6.49 includes a brief explanation of

Included additional para. 7.20, reference Malta Resources

Part B; Chap. 7, para 7.21,

Now on p 57. Added reference to amendments in 2001 to the

Part B; Chap 7, para. 7.26,

Added new para. with reference to Section 55 of amendments to

Part B; Chap 7, para. 7.34,

Modified text of original para. 7.34 (now 7.36, p 59) with

Part B; Chap 7, para. 7.35,

Deleted text from original para. 7.35 (now 7.37, p 59)

Part B; Chap 7, para. 7.39,

Replaced by para. 7.41, p 60 and includes a reference to the

Part B; Chap 7, para. 7.40,

Replaced by para. 7.42, p 60 and includes changes to the

Part B; Chap 7, para. 7.60,

Replaced by para. 7.62, p 64 and includes a reference to sec. 55

Part B; Chap 7, para. 7.63,

Replaced by para 7.65, p 65 and includes a reference to the

Part C; Chap. 8, HS6, p 7

The word permitted in line 2 of policy HS6 has been replaced