Article on Dwejra Development Permit published in Times of Malta

joseph/ July 8, 2019/ Uncategorised/ 0 comments

We live in a small country which is heavily light polluted. Measurements by the Institute of Space Sciences and Astronomy (ISSA) suggest that the Milky Way is observable from less than two per cent of the area of mainland Malta. 

The situation in Gozo is better, undoubtedly aided by the fact that a number of coastal areas had been designated as Dark Sky Heritage Areas (DSHAs). 

One of these sites – the best one of them all – is Dwejra.

However, Dwejra’s night sky has been threatened for a long time. Woes with light pollution there started way back in 2007, when approval was issued for an “interpretation centre” (PA/06447/06) which, of course, had to be accompanied by a catering facility. 

For how could one possibly focus on learning about Dwejra if they were about to faint from hunger? And so it was that an interpretation centre was buried underneath a restaurant. And once the interpretation centre would close for the night, the restaurant would remain open, as is only logical!

The same restaurant had previously been refused a permit three times within the space of two years, but it was approved in 2007 (and, following revisions, in 2010; PA/02418/09) when it was bundled up along with an interpretation centre as part of the Dwejra Heritage Park. That is all it took to sanction a restaurant in a sensitive site: dubbing the site a ‘Heritage Park’. What twists of logic!

Assurances were made that the site’s sensitivity would be respected. And yet, problems kept cropping up. Over the years, this place has seen it all, from rope lighting to a blindingly bright vending machine (in breach of Condition 8 of the 2010 permit), with the authorities stepping in to tackle the various infringements following our outcries (as was reported by this newspaper at the time).

Then, in 2017 a development application came along (PA/05372/17) that read:

“Proposed development within existing site; installation of canopy to match existing canopy in order to provide shade and protection from adverse weather, installation of lights, to place tables and chairs within existing site and installation of sign.”

A lot could be said about all this, but let us stick to the lighting here. It is there for all to see: “Installation of lights”.

ISSA was one of the objectors among many. The Environment and Resources Authority (ERA) did not recommend in favour. The Planning Authority refused to issue a permit. The case then went on to be heard by the Environment and Review Tribunal (EPRT).

ISSA’s arguments were refused on the grounds that an engineer’s report stated that the lighting is in conformity with ‘Condition 7’ of the permit (which condition is quoted in the EPRT report). And yet, ISSA’s night sky measurements (as part of an archipelago-wide study) showed that even with the existing lighting, night sky brightness had more than doubled.

But what would astronomers know about measuring light in the sky? This result was presented to the EPRT. It was ignored, because all was deemed to be fine according to ‘Condition 7’.

So let me talk about this ‘Condition 7’ from the 2010 permit document. It reads as follows: “External lighting of the structure should be kept to a minimum, and should consist exclusively of low-key intruder-triggered downlighters of low wattage. Globes, uplighters, etc. shall not be installed. Lighting under the canopy should be kept to the bare minimum and lighting of surrounding areas is strictly prohibited.”

First of all, when one downloads the relevant document, they can see that this quote is actually found under ‘Condition 6’ (‘Lighting Installations’) not ‘Condition 7’, suggesting that the EPRT board members did not even open the original Planning Authority permit document but merely copied the quotation from the reply provided to them by the PA, where this mistake was also made.

Originally, the mistake was in the applicant’s document itself, specifically in Plan 67b, and it was carried over.  The level of scrutiny exhibited by the EPRT is truly stunning, albeit for all the wrong reasons.

Secondly – and crucially – if the lighting was truly conformant with this condition, it would be intruder-triggered. And yet, the lighting is always switched on. It is not a security light. It turns on at sundown and stays on. It is continuous lighting intended to illuminate the space for the restaurant’s patrons. One could say that it is in a state of perpetual intrusion. 

To add insult to injury, despite the title of the 2017 application explicitly saying “installation of lights”, in Plan 67b a note says that the “Proposed changes being pro-posed to the existing approved lighting (PA/02418/09 condition 7) consist of just the elimination of the intruder trigger.” Was there ever an intruder trigger to begin with, given that the lights are always on?

Thirdly, it boggles the mind how it can be agreed that the lighting is being “kept to the bare minimum” if it is brightening the night sky to the extent measured by ISSA.

And lest you forget, as I have pointed out before, the site in question is designated a Dark Sky Heritage Area under Policy GZ-DARK-1 of the (MEPA) 2006 Gozo and Comino Local Plan. This policy states that in such areas, “reflective signs shall be employed to guide driving at night, while the installation of lighting which is not related to aerial or maritime navigation, shall be strongly discouraged”.

Consequently, one simply has to ask: How, exactly, do these lights serve the purpose of “aerial or maritime navigation”?

Needless to say, the site in question is also an Outside Development Zone (ODZ).

In case it was not clear where this was going, let me spell it out: following a number of appeal sittings spread over a year and three months, the EPRT has ordered that the PA’s decision for refusal be overturned.  

Now, you see, when others witness blatant disregard for our natural heritage, can you blame them when they begin to ask themselves: if others got away with it, why can’t I also?  

And so it has begun. Nowadays the Inland Sea is oftentimes lit up. The beauty of a star-peppered night sky is slowly but steadily fading from Dwejra. And soon enough, if all this persists, children will learn about the stars from books, but will have to imagine what they might look like. Nevertheless, I shall try not to end this on a negative note.

The EPRT decision document says that there will be no additional lighting beyond that which is already conformant with the conditions of the 2010 permit, which they quote. This means that:

The lighting has to be kept to a bare minimum

It should consist exclusively of low-key intruder-triggered downlighters of low wattage

The lighting, as it is, is:

  • Measurably brightening the night sky, and
  • Not intruder-triggered

So it breaches both of these points. The EPRT urges the relevant authorities to continue their scrutiny to ensure that the conditions of the 2010 permit are adhered to. So the authorities, at this point, should indeed take note of the above two points and take appropriate action.

Needless to say, the above exceptions should not even have been allowed in the first place in 2010, since this lighting is not “related to aerial or maritime navigation” as specified in policy GZ-DARK-1.

Dwejra’s environment remains under numerous threats. If we give up, all will be lost. When authorities fail, we have to collectively maintain our efforts to continue protecting this site as best as we can.

Joseph Caruana is an astrophysicist at the Department of Physics and the Institute of Space Sciences and Astronomy. For years he has tried to preserve the dark skies of Dwejra, and maintains an educational website about the site:

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