Diving Master Plan MALTA.Pdf

Report Reference: Adi Associates Environmental Consultants Ltd, 2012. Master Plan to Support a Sustainable Diving Industry for Malta. Version 3. San Gwann, May 2012; vi + 68pp + 2 Appendices.

This is a digital copy of the Report. Respect the Environment – Keep it Digital

Quality Assurance

Diving Master Plan for Malta

May 2012

Report for: Malta Tourism Authority

Revision Schedule

Report Rev Date Details Report by: Approved by: checked by:

00 Feb 2011 Submission to client Bill Richardson Kevin Morris Adrian Mallia Consultant Managing Director Managing Director

01 June 2011 Revised Plan Adrian Mallia Rachel Xuereb Rachel Xuereb Director Director Director

02 May 2012 Submission following Adrian Mallia Rachel Xuereb Rachel Xuereb public comments Director Director Director

File ref: F:\ADI\Master Plans\Malta Diving Master Plan\Master Plan\Adi Associates Diving MP for Malta_v3.doc

This document has been prepared in accordance with the scope of Adi Associates’ appointment with its client and is subject to the terms of that appointment. It is addressed to and for the sole and confidential use and reliance of Adi Associates’ client. Kappara Business Centre

Adi Associates accepts no liability for any use of this document 113 Triq Birkirkara other than by its client and only for the purposes for which it was San Gwann SGN 4197 prepared and provided. Except as provided for by legislation, no person other than the client may copy (in whole or in part) use or MALTA rely on the contents of this document, without the prior written permission of Adi Associates. Any advice, opinions, or recommendations within this document should be read and relied Tel. / Fax: 21378172 - 77 upon only in the context of the document as a whole. The contents of this document do not provide legal or tax advice or opinion. Email: [email protected] Web: www.adi-associates.com © Adi Associates Environmental Consultants Ltd 2012

iii

CONTENTS 1. Introduction ...... 1 Background ...... 1 Stakeholder involvement ...... 1 Why prepare this Diving Master Plan? ...... 2 2. Issues ...... 3 Overview of the diving industry in Malta ...... 3 A Profile of the Diving Tourist ...... 5 The product today ...... 6 Shore Diving...... 6 Boat Diving Sites ...... 8 Wreck Diving...... 9 Industry and Regulation ...... 10 Industry Gap Analysis ...... 19 Industry Issues Today ...... 19 Factors that Influence the Choice of Destination ...... 22 The Competition ...... 27 Conclusions ...... 33 A sustainable diving product ...... 34 Definition of Sustainability ...... 34 The Emerging Role and Importance of MPAs and Other Related Regulations as a Means to Promote Dive Site Stewardship ...... 35 Notice to Mariners No 5 of 2008 ...... 41 Priorities for a Sustainable Dive Tourism Segment ...... 41 3. Strategic objectives ...... 43 Short to medium-term objectives ...... 43 OBJECTIVE 1 - Upgrade shore and boat dive sites ...... 43 OBJECTIVE 2 - Encourage further marketing of the product ...... 53 OBJECTIVE 3 - Ensuring dive sites are better managed and protected...... 54 OBJECTIVE 4 – Diversify the product ...... 59 Scuttling of Wrecks ...... 60 Artificial Reefs ...... 61 MEDIUM to long TERM OBJECTIVES ...... 62 Cleaner Seas – Relate to WF Directive / Cleaning of Vessels ...... 62 4. Implementation priorities and action plan...... 65 Implementation partners ...... 68

FIGURES Figure 2.1: Malta dive sites ...... 11 Figure 2.2: Location of dive schools in Malta...... 13 Figure 2.3: Water Lighter X127, Manoel Island ...... 15 Figure 2.4: Existing infrastructure at Manoel Island ...... 17 Figure 2.5: Wreck site images from MTA website...... 23 Figure 2.6: MTA Website – dedicated section to promote dive tourism ...... 23 Figure 2.7: Special feature on diving in Malta – highlighting the diversity of dive sites & other cultural attractions ...... 25 Figure 2.8: Existing Marine Protection Areas / Marine Natura 2000 Sites – Malta ...... 39 Figure 3.1: An example of a “halo” in Posidonia meadows as a result of anchoring ...... 50 Figure 3.2: Example of mooring buoy (as used in Hurghada, Red Sea) ...... 50 Figure 3.3: Possible ways to raise the status of dive sites and simplify procedures for new infrastructure ...... 58

TABLES Table 2.1: Trends in ‘fanatic’ dive trips to Malta ...... 3 Table 2.2: Diving tourists by country of residence - 2009 ...... 5 Table 2.3: Dive industry issues in 2010 ...... 20 Table 2.4: Gap analysis of main competing destinations ...... 28 Table 3.1: Proposed interventions at Shore Dive Sites ...... 45 Table 3.2: Necessary interventions at boat dive sites as identified by the diving industry ...... 52 Table 3.3: Sites where conflicts are most likely to exist between diving and fishing ...... 56

APPENDICES

Appendix 1: Definitions of fishing activities Appendix 2: Concept drawings for diving infrastructure

1. INTRODUCTION

BACKGROUND 1.1. Adi Associates Environmental Consultants Ltd (“Adi Associates”) has been commissioned by the Malta Tourism Authority (MTA) to prepare a Master Plan for a Sustainable Diving Industry for Malta (Tender Ref: MTA/731/2008). 1.2. The objectives of the Master Plan are to provide:

· An overview of diving in Malta - facilities available, quality of dive sites, infrastructure on the coast, safety measures available for divers;

· A comparison of the local diving situation with Malta’s chief competing destinations;

· A gap analysis;

· Identification of short-, medium-, and long-term issues to ensure the sustainability of the diving sector;

· Development of a strategy for the diving sector;

· An assessment of the requirements of other competent authorities;

· Proposals for upgrading various diving sites; and

· Introduction of management measures at popular diving sites.

Stakeholder involvement 1.3. The Diving Master Plan has been prepared following comprehensive feedback from individual divers, representatives of the diving industry and an analysis of various published sources of material about the state of dive sites and the diving sector in Malta. Site inspections were also undertaken for all the shore based dive sites in order to audit existing facilities and follow up on comments raised by divers about the state of facilities in these locations. The following summarises the research methods that underpin the Strategy:

· Desk research;

· On-site inspections and surveys;

· Stakeholder consultation and interviews; and

· On-line survey / questionnaire. 1.4. This strategy document does not include individual dive site audits as these are provided through 21 separate dive site reports. Similarly, it is not necessary to

provide a comprehensive account of all issues raised by the divers and industry representatives as a full account of the stakeholder consultations and the findings are set out in a second background paper entitled “Report on Public Consultation – Master Plan to Support a Sustainable Diving Industry in Malta”. Specific reference is made to these documents where relevant throughout this Master Plan.

Why prepare this Diving Master Plan? 1.5. The Tourism Policy for the Maltese Islands1 presents the principles upon which decisions, actions and other matters relating to tourism in Malta are to be based. It proposes to increase national tourism revenues through the promotion of the principle of sustainable development (ensuring environmental and socio-cultural resources are preserved). Specific objectives that are relevant to the Diving Industry in Malta are:

· To maintain and conserve environmental and socio-cultural resources, being the key elements of the Maltese Islands’ tourism product;

· To increase our competitive advantage and deliver quality and distinct tourism products, built on our characteristics;

· To reduce seasonality; and

· To increase accessibility to and from Malta. 1.6. The Policy recognises the need to improve the broader ‘product offer’ for tourists through destination management. The need to better manage tourist zones, dive sites and other sites of environmental and cultural significance is acknowledged. The importance of the marine environment in supporting growing tourism sectors is emphasized. The Policy also confirms a commitment to examine further opportunities to scuttle wrecks and to support this industry segment through the provision of infrastructure, such as the setting up of the decompression chamber on Gozo. 1.7. A commitment to prepare this Master Plan is given in page 43 Together with the local diving community we will develop a master plan for the diving business. A master plan for diving in Gozo is already underway. The diving plan for Malta will need to take this into account to ensure complementarity rather than direct competition.

1 Tourism Policy for the Maltese Islands 2007-2011. Ministry for Tourism and Culture.

2. ISSUES

OVERVIEW OF THE DIVING INDUSTRY IN MALTA 2.1. Tourism’s contribution to GDP (Gross Domestic Product) in the Maltese Islands is estimated to be 25% and accounts for about 28% of full time equivalent employment. The contribution of the Diving Segment to the Tourism Sector has increased substantially due to the popularity of the Maltese waters with both local recreational divers as well as leisure and fanatic divers2 from overseas. Since the 1970s the number of dive schools in Malta has increased from 5 to 34 in Malta (plus 12 in Gozo). 2.2. Malta hosts a range of dive sites that benefit from fantastic underwater scenery in warm and clear waters. As a destination, Malta enjoys a good reputation for excellent shore and wreck diving. Most dive tourists originate from Europe; the largest markets being the UK, Germany, Italy, France, the Netherlands and Nordic Countries. 2.3. Table 2.1 shows that total tourist arrivals to Malta since 2005 have increased on a generally upward trajectory, assisted through the liberalisation of the airline industry, which has seen the expansion of budget operators to/from more regional airports throughout Europe. 2010 was a record year for tourist visits to Malta. During this period the proportion of ‘fanatic divers’ who visited Malta increased substantially; diver numbers in 2010 saw an increase of 49% over the figures of 2009. Table 2.1: Trends in ‘fanatic’ dive trips to Malta3

Purpose Apr-Dec Jan-Dec Jan-May of Trip 2005 2006 2007 2008 2009 2010 2011 Scuba Diving 2,177 1,990 1,902 2,901 3,468 5,171 1,331 Total Tourists 1,170,608 1,124,232 1,243,506 1,290,856 1,182,490 1,332,086 481,762

2.4. Although visits from ‘fanatic divers’ has increased significantly, it is useful to look at the broader profile of dive tourism. By far the majority of tourist-related diving is undertaken as part of a family or group holiday where diving is just one of a number of activities for which the tourist will visit Malta. It is estimated that 57,000 visitors

2 Describes a diver who travels overseas with the sole purpose to dive. MTA (2007) Marketing Plan 2008- 2010. Segment Trends…Diving. 3 ‘Fanatic’ dive trips are where the respondent has indicated that the sole purpose of his/her holiday to Malta was for diving. Data sourced through written request to NSO from Adi Associates, November 2010. Based on data from NSO ‘Tourstat Departure Questionnaire’.

(4.3% of all tourists) partook in diving activities in 2010 compared to 60,000 (5.1%) in 20094. 2.5. The proportion of dive tourist spend nights in Malta, when compared to Gozo is between 75 to 85%, suggesting that Malta remains the most popular destination. This is largely explained by the ‘double insularity’ of Gozo, which requires additional travel modes and time. 2.6. Compared to when the sector was in its infancy (the 1970s), the range of participants in diving has increased, with increased participation of women and people of mixed ages and abilities. Most participants are classed as ‘recreational’ divers whereby the dive experience is perhaps just for 1 to 3 days and part of a range of other holiday activities. 2.7. As Malta’s main source market is Europe, Malta tends to mainly compete with other European destinations, although two non-European destinations attract very significant numbers of dive tourists from Europe. These are the Red Sea / Egypt and the Maldives. The main competitor markets5 have been identified as follows6:

· Red Sea/Egypt;

· The Maldives;

· Greece;

· Balearic Islands;

· Cyprus;

· Portugal.

· Sardinia; and

· Corsica. 2.8. This list of competitor destinations is supported anecdotally through feedback from representatives of the Maltese dive industry7 and through other research8. Meetings held with industry representatives have also highlighted further potential competition

4 Research findings are based on the ‘Market Profile’ Survey carried out by MTA on a continuous basis. Main purpose of visit was not necessarily recorded as ‘Diving’; however ‘Diving’ was recorded as one of a number of activities undertaken by the tourist. 5 MTA Workshops - Marketing Plan 2008-2010, 9th – 11th July 2007. 6 Ranked according to ‘chatter’ about each dive destination as recorded on 16th November 2010 on http://www.tripadvisor.com. The following number of reviews was noted for each destination: Red Sea (9,650), The Maldives (3,406), Greece (796), Balearic Islands (391), Cyprus (324), Portugal (220), Sardinia (149) and Corsica (19). 277 reviews were recorded for Malta. 7 Report on Public Consultation, Master Plan to Support a Sustainable Diving Strategy in Malta. Adi Associates. November 2010. 8 Research findings are based on the ‘Market Profile’ Survey carried out by MTA on a continuous basis. MTA 2009.

from emerging markets including Tunisia (e.g. Tabarca) and Libya, which has a huge potential for wreck diving.

A Profile of the Diving Tourist

Economic / spending profile 2.9. Approximately 4.3% of all tourists who visit Malta partake in diving activities9. Relative to other tourists these visitors tend to have larger disposable incomes10 and are typically self-employed / office workers or managers / professionals, typically in the age range of 25 to 45 years old. Their spending impacts on the Maltese economy are further enhanced as dive tourists are more likely to hire cars and rent self catering accommodation. Tourists who come to Malta to dive typically stay for relatively long visits (average length of stay is 10 nights11).

Country of origin 2.10. In the last 5 years, the MTA has invested considerable resources into establishing a profile of dive tourists in Malta. Table 2.2 shows where most dive tourists originate from and the proportion of dive tourists from each country. 2.11. Most dive tourists to Malta (approximately 24% - 13,500) originate from the UK, followed closely b the Italians (approximately 21% - 11,900). Although a much higher proportion of the total Spanish, German, French, Nordic Countries, and Irish tourists partake in diving activities in Malta; their numbers are lower, reflecting lower overall numbers of tourists from these countries when compared to the UK. 2.12. Malta’s skew towards the UK market is further demonstrated by contrasting the figures below with the actual main markets in Europe for ‘Outbound’ divers. Of the approximately 2 million certified divers in Europe that take outbound dive holidays, 25% of these are German, 18% are French, 18% are Italian and 12% are British. These countries, therefore, account for the main outbound markets in Europe12.

Table 2.2: Diving tourists by country of residence – 200913 & 201014

9 Source: A Profile of the Diving Tourist in 2010. MTA 2010. 10 Net average monthly wage of €2,700. Source: A Profile of the Diving Tourist in 2010. MTA 2010. 11 MTA Workshops - Marketing Plan 2008-2010, 9th – 11th July 2007. 12 Mintel Diving Tourism – International, Travel & Tourism Analyst, 2007. 13 Research Unit, Malta Tourism Authority. 2009.

Share of Diving Share of Total Tourist Diving Tourists Tourists of Diving Tourists Departures Total Tourist by Market Departures 2009 2010 2009 2010 2009 2010 2009 2010 Total 1,183,016 1,332,086 60,000 57,000 5.1% 4.3% 100.0% 100.0% UK 415,234 415,121 15,000 13,500 3.6% 3.3% 25.0% 23.7% Germany 122,795 126,097 9,200 6,800 7.5% 5.4% 15.3% 11.9% France 72,630 86,475 4,500 4,100 6.2% 4.7% 7.5% 7.2% Italy 159,036 214,258 8,300 11,900 5.2% 5.6% 13.8% 20.9% Netherlands 33,641 33,425 3,700 800 11.0% 2.4% 6.2% 1.4% Nordic Countries 67,527 92,770 4,700 5,400 7.0% 5.8% 7.8% 9.5% Austria 19,978 19,899 600 700 3.0% 3.5% 1.0% 1.2% Belgium 23,024 24,297 1,100 1,000 4.8% 4.1% 1.8% 1.8% Switzerland 22,058 21,522 2,000 600 9.1% 2.8% 3.3% 1.1% Spain 44,551 67,810 3,500 4,900 7.9% 7.2% 5.8% 8.6% Republic of Ireland n/a 25,167 n/a 1,700 n/a 6.8% n/a 3.0% Other 202,542 205,245 7,400 5,600 3.7% 2.7% 12.3% 9.8%

2.13. In 2007, the MTA identified the geographic markets with the most potential as the UK, Germany, France, Italy, the Netherlands/Belgium and the Nordic Countries. At 8.6%, the Spanish market is also growing. This is partly explained by the rapid growth in new routes to Spain provided by the budget airlines and the increase in Spanish students visiting Malta to learn English in 2010 following the provision of grants by the Spanish government15.

THE PRODUCT TODAY 2.14. The compact size of Malta means that a range of potential dive sites are accessible in any one day. More than one attraction can be visited within the same day with relatively few logistical problems16. 2.15. Figure 2.1 identifies some of the most popular shore and boat dives in Malta, as recognised by the Malta Tourism Authority. Figure 2.2 shows the location of the 34 dive schools in Malta that are currently registered with the MTA.

Shore Diving

Location of shore dive sites 2.16. Figure 2.1 shows 29 popular shore dives that are spread throughout the island. Many are clustered around popular urban tourist areas (St Julian’s, Sliema, Marsaskala and Marsaxlokk), whilst others are at relatively remote coastal locations such as

14 Research Unit, Malta Tourism Authority. 2010. 15 These grants were withdrawn in 2011, which may result in fewer Spanish students visiting Malta this year. 16 Subject to ‘bottom time’ and the need for safe surface intervals between dives.

Cirkewwa in the North West, and Ghar Lapsi and Wied iz-Zurrieq on the south coast. These shore dives are served by 21 access points. Most of these access points have basic formal or informal infrastructure to allow divers to park vehicles, kit up and access the water. These shore dives offer opportunities for divers of all skills to gain access to a site of interest without having to get involved with an organised boat trip (which normally entails an additional cost). Shore dive attractions vary from wrecks (e.g. the X127 Water Lighter, Manoel Island and the P29 Patrol Boat at Cirkewwa) to unusual and spectacular features of the marine topography (for example, the Mini Blue Hole at Marsaskala and the Cirkewwa Arch). Many shore dives also provide divers with an opportunity to explore a variety of reef wild life (for example, the ‘Coral Gardens’ St Julian’s and the Cirkewwa Reef).

Condition and management of shore dive sites 2.17. The land infrastructure and the characteristics of shore dive sites vary. Some are accessed only by rough and restricted tracks. Some are set at a distance from vehicle parking areas and may require passage over steep gradients to access the water, while others are located close to scheduled historic structures or areas that are designated for their geological or habitat interest. 2.18. Feedback from the diving industry, followed up with full site inspections provided a picture of the overall condition of these sites. Despite the popularity of some sites, the provision of basic infrastructure (for example steps) is often missing or badly in need of replacement. At other locations issues such as vandalism, theft, littering, pressures for other coastal development or overcrowding of the site / car park can create problems for site users.

Usage and other threats 2.19. Feedback from individual divers and the diving industry has provided an indication of the shore dive sites that are most popular:

Top 10: Most popular shore dives (Overall)

Um el Faroud - Wied iz-Zurrieq

Tug Boat Rozi - Cirkewwa

Sugar Loaf & Madonna - Cirkewwa

P29 Patrol Boat - Cirkewwa

Cirkewwa Arch - Cirkewwa

West Reef & Caves - Wied iz-Zurrieq

East Reef - Wied iz-Zurrieq

HMS Maori - St Elmo Bay, Valletta

Middle Reef - Ghar Lapsi

Tug boats - Zonqor point

2.20. Feedback from divers and dive schools showed that although the shore access sites are dispersed across the island, pressures for parking and access at more sheltered harbour locations can be experienced when prevailing winds make diving conditions difficult at more exposed sites. 2.21. Visits to the sites suggest that there is no overall coordination, and the upkeep and management of sites varies considerably. The following issues need to be addressed through the Master Plan:

· Upkeep & management;

· Managing possible cultural heritage and other environmental pressures; and

· Potential overcrowding. 2.22. As an example, Figures 2.3 & 2.4 show the current state of the Manoel Island shore dive site to provide an example of a site that would benefit from short-term interventions and that is under threat in the long-term. This dive site is the second most popular shore dive in the central region (see Figure 2.1); it provides access to the wreck of the X127 Water Lighter that was sunk in situ in 1942. 2.23. Access to the dive site is currently controlled by security guards who manage the site on behalf of the Manoel Island developers. The Manoel Island Project proposes restoration and rehabilitation of Fort Manoel and the surrounding historic structures. A marina is proposed above the site of the wreck (PA 03254/03), which could significantly limit access to this popular dive site in the future (on grounds of maritime safety and further degradation of water quality). This example demonstrates some of the short-term and long-term threats that some dive sites face, highlighting the need to give dive sites more status and improve public accessibility.

Boat Diving Sites

Location of popular boat dive sites 2.24. Figure 2.1 shows 15 popular boat dives. These are concentrated on the north western, northern and south eastern coasts. Few are located off the south coast due to the deeper waters.

Type and variety of boat dives 2.25. Malta contains a variety of boat dives close to shore. These vary from sites with specific morphological features (overhangs, swim throughs, and arches) and reefs, to boat wrecks that have either been purposefully scuttled for diving purposes or historic wrecks (typically WW2 period).

Usage and other threats 2.26. Feedback from individual divers and the diving industry provided an indication of the boat dive sites that are most popular:

Top 10: Most popular boat dives (Overall)

Imperial Eagle

HMS Stubborn

Bristol Blenheim

Beaufighter

Qammieh Point

Le Polynesien

Devil's Reef

HMS Hellespont

Southwold

Migra Ferha

2.27. Divers and representatives from the industry identified over-fishing and spear fishing as a particular problem at wreck dive sites. The impact of fish farming (food debris) on boat dive sites in the vicinity of St Paul’s Bay was also identified as an issue. Additionally, the consultees indicated a general lack of both mooring buoys and recognition of the significance of off shore dive sites from the point of view of safety and wildlife conservation. Fishing with nets and anchoring activity was also noted as causing risks to divers and being detrimental to the boat dive site and its surrounding infrastructure. 2.28. In terms of the existing dive product (for boat dives), the following issues need to be addressed through the Master Plan:

· The need for safety infrastructure – in particular mooring buoys; and

· Managing possible cultural heritage and other environmental pressures.

Wreck Diving 2.29. There are currently 6 wrecks close to the coast of Malta that have been purposely scuttled for diving: the MV Rozi and the P29 in Cirkewwa, the Um El Faroud in Zurrieq, the Imperial Eagle off Qawra Point, and the tug boats number Ten and the St Michael at Zonqor Point, Marsaskala. Other vessels that sunk during the World Wars that are used as diving wrecks include the HMS Stubborn off Is-Sikka l-Bajda, the HMS Maori in the Grand Harbour, the SS Margit in Kalkara Bay, le Polynesien, the St Angelo minesweeper, the HMS Hellespont, and the Schnelle Boote (E-boat) outside the Grand Harbour, the HMS Southwold off Zonqor Point, Marsaskala, the Blenheim Bomber off Il-Hofriet in Marsaxlokk, the Bristol Beaufighter off Merkanti Reef, the Scot Craig off Anchor Bay, the X127 Water Lighter at Manoel Island, and a British aircraft (Mosquito) off Delimara (see Figure 2.1).

Industry and Regulation 2.30. There are 34 licensed dive schools in Malta. These are mainly clustered within the urban areas of Sliema / St Julian’s and Qawra / Bugibba / St Paul’s Bay (See Figure 2.2). 2.31. Diving Regulations17 in Malta were updated in 2010 to partly ensure Malta’s compliance with the Services Directive18. The Regulations also provided an opportunity to ensure the highest possible safety standards are maintained by service providers. The aim of these Regulations (named: Recreational Diving Services Regulations, 2010) is to establish the license and other requirements for service providers in the field of recreational scuba diving. The Regulations fall under article 47 of the Malta Travel and Tourism Services Act and are implemented by the Malta Tourism Authority. The Regulations require that persons wishing to offer recreational diving services hold a valid license, issued by the MTA under the terms of the Regulations. The primary purpose of the Regulations is to ensure:

· That the applicant and his staff are sufficiently qualified and competent to provide diving services;

· The infrastructure, equipment, and operations of the dive centre meet required standards; and

· The applicant has sufficient third party liability insurance. 2.32. Once granted, licenses are renewed annually and each license requires an appointed ‘director of diving’ who is ultimately responsible for compliance with the Regulations. The Regulations are focused primarily on safety and cover operational issues such as requirements to undertake risk assessments and safety drills, prepare dive logs and ensure medical checks are undertaken for clients. 2.33. The Regulations are currently subject to a review process to ensure clarity with regard to interpretation and certain definitions. The revised Regulations are likely to be issued in 2011, although the basic mechanisms and aims are unlikely to change significantly.

17 Legal Notice 357 of 2010. 18 Directive 2006/123/EC of the European Parliament and of the Council of 12 December 2006 on services in the internal market.

Figure 2.1: Malta dive sites

Figure 2.2: Location of dive schools in Malta

Figure 2.3: X127 Water Lighter, Manoel Island

Location of dive site in relation to Fort Manoel. Rock cut gully provides some support for divers, but hand rails No formalised car parking for divers. Parking is restricted to a relatively small area against could assist further. Entry point E2. the fortifications.

Proposed construction of breakwater to enclose marina (extract from PA 03254/03). Long informal paths provide access between vehicles and the Jump point (Entry point E1). Proposed at the site of the wreck of the X127 Water Lighter. shore. Limited sense of security.

Figure 2.4: Existing infrastructure at Manoel Island

INDUSTRY GAP ANALYSIS 2.34. The following section considers the main issues that influence Malta’s dive tourism product. It considers how well Malta competes on price and quality, and considers the socio-demographic profile of dive tourists. It reviews how Malta compares to competing destinations and identifies any action required.

Industry Issues Today 2.35. Feedback from diving industry representatives describes an industry that has experienced expansion in recent years. Malta now offers a wide choice of schools and experiences. Representatives have highlighted the following as key issues facing the industry:

Environmental stewardship · Fishing and threats to marine life;

· Enforcement and awareness; and

· Management and state of individual site sites.

Management of the industry · Government support; and

· Coordination between dive school operators and perceived discrepancies in standards. 2.36. Table 2.3 provides a detailed analysis of the above issues.

Table 2.3: Dive industry issues in 2010 Issue Issue Summary Possible actions to help address the issue

Environmental Stewardship Fishing and Fishing and the lack of marine life is a serious concern for the diving industry. There is a Promote understanding between each industry and threats to conflict for the same resource between divers and certain fishermen. Respondents safeguard dive sites from fishing activity – particularly marine life mentioned overfishing in general, spear fishing (in particular with scuba gear), and fishing those sites that are cherished most for their marine life. at dive sites and on wrecks, which is illegal and detrimental to the industry. Fish farms More effective monitoring / intervention at dive sites to located close to dive sites may also create problems for divers. Sea pollution is a further enforce existing legislation and future management threat to marine life. plans. Enforcement Survey respondents agree that although there are many environment protection Identify legally defined and protected dive sites. and regulations, enforcement is lacking. There is a need to protect dive sites (and the whole Additional status will help to focus the efforts of awareness aquatic environment) and to enforce the fishing regulations for such sites. A greater environmental enforcement agencies with regards to the effort is required from the Administrative Law Enforcement (ALE) and other prevention of: administrative bodies. Although reports of fishing on wrecks have been made to the · Illegal dumping / damage of dive sites; police, nobody has been caught; this situation still exists despite the Notice to Mariners · Illegal fishing; which identifies 7 wrecks as no stopping areas and bans such activities. · Land based theft from vehicles and vandalism; and · Acts of polluting. The industry considers that there is also is a general lack of awareness of marine laws together with a lack of understanding that pollution and illegal fishing activities harm the Tangible boundaries will provide divers and clubs with marine environment and, therefore, dive tourism. more confidence to report environmentally damaging activities (self-policing by industry). Management Numerous issues were identified at dive sites including: The online dive survey provided information about the and state of · Poor road access to some; popularity of various shore and boat dive sites. It individual dive · Lack of facilities for the disabled; provides an audit of frequency of use and the state of sites · Lack of mooring buoys required for wreck dives; infrastructure (this was followed up through site visits). · Illegal anchoring on dive sites; · Lack of available vehicle parking for divers and dive parties; This information will help to prioritise investment · Lack of public awareness of the use of some areas as dive sites; opportunities in dive site infrastructure.

· Lack of changing facilities and toilets; The Master Plan considers how better management of · Lack of facilities for night dives; dive sites and land facilities can be achieved between the · Lack of sheltered facilities for kitting up. Most are not maintained – e.g. the facilities diving industry and other public agencies. It considers at Anchor Bay; current potential barriers and whether legislative or · Cleanliness of seabed and shoreline;

Issue Issue Summary Possible actions to help address the issue · Vehicle security; procedural burdens can be eased to ensure · Lack of solid ladders and hand rails at entry / exit points; improvements are implemented at dive sites. · Removal of ladders during the winter leaving dive sites without a proper access point; and · Irresponsible use of pleasure craft such as jet skis and speed boats close to dive sites. Management of the Industry Government Industry representatives generally acknowledged specific Government actions in recent The Diving Master Plan for Malta recommends where support years, including the scuttling of boats. However, there was a general feeling that public future market resources would be best directed to agencies were not actively managing dive sites or coordinating to ensure action against ensure the long-term growth and sustainability of this illegal fishing or other activities that can be harmful to dive sites such as illegal anchoring. growing segment of the tourism sector. Industry representatives were concerned that diving was viewed as ‘just a tourist pass- time’ by Government, without realising the important economic role played by this Stakeholder consultation and MTA figures suggest stiff market segment. competition from other European destinations and emerging dive destinations. The Master Plan considers In particular, industry representatives wish to see Government take a firmer lead in Malta’s strengths and weaknesses and how actions can promoting Malta as a year round tourist diving destination, genuine enforcement of illegal be taken to improve and diversify the product, including fishing activity, and better coordination between MTA and Transport Malta to maintain reducing seasonality. and manage sites is required. The Master Plan recommends Action is taken to ensure Respondents also request subsidies on boat fuel and boat purchases. better coordination in the management of sites. Coordination Certain issues highlighted by survey respondents are related to the dive school Many of these issues relate to matters of regulation and between clubs operators. Some respondents think that there is no consistency between school competition. The Master Plan suggests actions that may in the face of standards. Others feel that some operators act as if they own the dive sites. One assist clubs to co-manage sites and better coordinate mounting respondent argues that certain regulations and procedures are unnecessary. the use of sites during bad weather or in peak season competition when parking may be at a premium. and perceived Independent divers have problems accessing boat dives and oxygen cylinders. Some discrepancies operators only hire tanks to individuals that take part in a course or a guided dive. There in standards seems to be little or no coordination between operators to co-organise boat dives. Considering the increasing costs of such dives, this needs to be considered.

One diving instructor argued that it is not possible to work for a profit in the local diving industry without being affiliated to a school. Individuals should be allowed to provide courses under some form of regulation.

Factors that Influence the Choice of Destination 2.37. It is important to understand the motivational factors that guide the dive tourist in making a decision about which destination to choose. These factors are a combination of practical and subtle considerations. Some of the more practical considerations include:

· Value for money;

· Time spent getting to the destination;

· Water temperature / length of season; and

· Distance between accommodation and potential dive sites. 2.38. Other considerations are more qualitative and relate to perceptions of the likely quality of the overall experience. Important questions that a potential dive tourist might ask (or seek reassurance for) are:

· Is the water clear and is there good visibility?

· What is the quality of the marine environment? Will I be able to see a range of sea life?

· Is there plenty to do and see underwater? Will there be a good range, quality and variety of dive sites (particularly for technical divers and more experienced leisure divers)?

· Are there good facilities for divers (close to dive sites and lodging)?

· Will the dive centre staff speak my language?

· Will there be other activities that my partner / family can do while I am diving?

· Are there other cultural, sports, leisure attractions that I can get involved in on the days I am not diving (applies less to the ‘fanatic’ diver who is likely to engage in diving activities for the entire stay)? 2.39. Most of the practical and subjective considerations identified above will be used to compare potential destinations. In terms of marketing, most studies have concluded that the decision to travel to Malta to dive is based mainly on:

· Word of mouth (recommendations by friends or relatives) – 35.7%;

· Internet searches – 33.1%; and

· Previous visits – 24.6%. 2.40. Investment in more focused tourist media will also remain important. Feedback from dive tourists, therefore, suggests focussing market efforts on internet-based solutions

is probably most effective. In addition, specific articles and promotions in industry- specific publications (such as dive magazines) can also be beneficial. Figure 2.5: Wreck site images from MTA website

Figure 2.6: MTA Website – dedicated section to promote dive tourism

Figure 2.7: Special feature on diving in Malta – highlighting the diversity of dive sites & other cultural attractions

The Competition 2.41. Table 2.4 identifies some of the strengths and weaknesses associated with three of the top diving destinations that compete with Malta as likely to be viewed by potential dive customers. It then considers how Malta’s current product offer could improve to better compete with these destinations.

Table 2.4: Gap analysis of main competing destinations19 Competitor Considerations Strengths and Weaknesses Summary of advantages / disadvantages of Destination competing destinations. What actions can the Diving Master Plan promote in order that Malta continues to develop the diving segment of its tourist market to ensure that it compares favourably with other destinations? Egypt / Red Seasonality Strengths: All year destination. Water 15 oC in Jan to Egypt and the Red Sea offer a relatively inexpensive medium- Sea 29oC in September. haul location from the main European dive markets. Their Weaknesses: None. main strengths include the unique variety of Red Sea wildlife Quality of dive sites Strengths: Excellent variety – includes Thistlegorm and an impressive array of ship wrecks. This destination is Wreck (sunk 1941) and ranked 4th most popular dive site home to 3 of the top ten dive sites in the world. in the world. Weaknesses: Anecdotal web-based diver reviews suggest Disadvantages include the additional time and costs of travel wreck sites are particularly prone to archaeological theft – when compared to European destinations and relatively destroying the integrity of some sites. expensive costs for equipment hire. Aquatic life and variety Strengths: Large variety of fish and plant species - just under 20% are endemic to the Red Sea, providing a A review of reviews (http://www.tripadvisor.com) highlights relatively unique marine life compared to Mediterranean some negative feedback about the lack of a ‘personal’ destinations that host more generic species. approach from some of the dive schools. Divers have Weaknesses: None. suggested that the focus of some schools is to fill boats and Typical dive costs Strengths: There are numerous hotels in the Red Sea find sites that are suitable for all levels of divers and that specialise in dive tourism and which provide snorkelers, possibly limiting opportunities for more competitive package prices that include flights/hotel and experienced divers to try more challenging dives. diving tuition/equipment. Given the range of aquatic life and quality of many of the Distance to destination Weakness: 4-6 hrs by plane from 4 main European dive sites, the Red Sea is likely to remain a popular outbound markets. Approx 1 to 2 additional hour’s flight competing destination in the long-term. time. More expensive destination to which to travel.

Distance between sites Weakness: Malta and Maltese dive schools may be able to once at destination Linear coastline – tourist could be isolated when there – better compete on the basis of quality as they seem country large distances between dive sites.

19 Dive site rankings based on scubatravel.co.uk ranks of Global and European dive sites. Web site accessed November 2010.

Competitor Considerations Strengths and Weaknesses Summary of advantages / disadvantages of Destination competing destinations. What actions can the Diving Master Plan promote in order that Malta continues to develop the diving segment of its tourist market to ensure that it compares favourably with other destinations? Popularity with main Strength: Identified as number one destination of choice more able to provide a personalised service that is European Outbound for French and British divers. Second destination of choice more tailored to meeting the expectations of Markets for German and Italian divers (after the Maldives). individual divers and less focused on ‘throughput’ of Quality of non-diving Strength: Unique natural and cultural landscapes. numbers and inflexible itineraries. tourist offer Weakness: Dive sites isolated from heritage features requiring significant excursions. Opportunities for new / improved dive sites or new wrecks will help to provide a competitive dive tourism product. The Seasonality Strength: All year, although visibility is generally not good Most of the tourists to the Maldives travel to the Maldives Maldives in July & August. Water temperature is consistent to dive (approx 60%). throughout the year (between 27 and 30oC). Total tourist visits to the Maldives declined by 5% between Quality of dive sites Strength: Excellent, especially for corals and reefs. Over 2008 and 2009 (Source: Maldives Ministry of Tourism, 2009). 200 sites throughout the islands. This is largely attributed to reductions in the numbers of Aquatic life and variety Strength: Excellent variety – includes Angel Fish, European visitors. The overall decline in tourist numbers Barracuda, Blue Lined Snapper, Butterfly fish, Clownfish, was partly off-set by significant increases in visitors from Eagle Ray, Grey Reef Shark, Manta Ray, Parrotfish, Stingray, Asia and the Middle East. Whale Shark, Zebra Shark and many other species. Typical dive costs Strength: Comparable with Malta, although transport Although this may only be a medium-term consequence of costs to destination make total holiday costs more the Global Economic Slowdown, it could trigger an expensive. increased focus towards attracting Asian divers to the Maldives. Distance to destination Weakness: Long haul destination taking approximately 10

hrs from 4 main European outbound dive markets. Contraction of numbers of European Divers to long haul Distance between sites Strength: The Maldives include over 2,000 islands. Not destinations such as the Maldives could prove an advantage once at destination all resorts cater for diving and many Europeans opt for an for Malta. country all-in package living on a ‘liveaboard’ boat. Weakness: Distance between dive sites and the use of The main ‘pull factor’ associated with the Maldives is the ‘liveaboard’ boats results in mainly ‘drift’ diving where the diversity of wildlife, unique variety of reefs and corals, and current takes you. Confinement on a ‘liveaboard’ may

Competitor Considerations Strengths and Weaknesses Summary of advantages / disadvantages of Destination competing destinations. What actions can the Diving Master Plan promote in order that Malta continues to develop the diving segment of its tourist market to ensure that it compares favourably with other destinations? appeal to ‘fanatic’ divers but may not appeal to young almost constant water temperature. families or non-diving partners. Popularity with main Strength: Very popular with main outbound European The main weaknesses of the Maldives are the cost of travel European Outbound dive markets. Germans and Italians ranked the Maldives as (for European divers) and the distances between dive sites. Markets their 1st choice dive location and the French as their 2nd The location is not ideal for younger families. choice (MTA, 2008). 70% of tourist arrivals to the Maldives originate from As the main European markets emerge from Europe (most of these originate from UK (17%), Italy recession, long haul diving destinations will become (15%), Germany (10%) and France (7%). increasingly attractive to the main outbound Interestingly the gender split of all tourists is 50/50, European Markets. Malta will benefit from suggesting that a higher proportion of female divers travel improving the management and condition of dive to the Maldives when compared to Malta (33/67). sites, improving the range of wrecks and other Quality of non-diving Weakness: More limited by geography when compared attractions, and promoting itself better in the tourist offer to most other locations. It is estimated that most tourists European winter months. who travel to the Maldives are there for diving (and snorkelling) – about 60% of all visitors, compared to approx 5% in Malta. Cyprus Seasonality Strength: All year. Water 16oC in Jan to 32oC in As a Mediterranean diving destination, Cyprus competes for September. the same outbound dive tourist markets. Its proximity to Quality of dive sites Strength: Excellent variety – includes The Zenobia the Red and Black Seas provide a diverse marine life and Wreck (a RO RO boat that sunk in 1980) and ranked the provides a comparable array of ‘non-diving’ family attractions best dive site in Europe. including beaches and urban cultural tourism. Aquatic life and variety Strength: Diverse. Currents flowing from the Red and Black Seas bring a large diversity of differing marine life Cyprus provides comparable water temperatures and including Grouper, shoals of Double Banded Bream, experiences, although boasts wreck dive of international Stingrays, Scorpionfish, Amberjacks and Wrasse. significance – the Zenobia. Value for money Strength: Comparable dive prices – for example a ‘Try Dive’ with equipment is circa €38 – comparable with Cyprus is similar to Malta and can probably have a Malta. greater edge due to its small size and close

Labour costs & emerging Markets 2.42. Representatives from the diving industry in Malta have highlighted some of the competitive advantages that other diving destinations enjoy. The cost of labour at some destinations (particularly Tunisia, (e.g. Tabarca); Croatia; Libya; Greece; Egypt; Turkey; and Cyprus) allows for extra staff to be employed specifically to assist tourists with kitting up. 2.43. Prior to the unrest that has swept across North Africa and is currently still raging in Libya, industry representatives had cited Libya as an example of an ‘emerging market’, since, at the time the Libyan Government had been actively pursuing tourism-led growth. The situation today is obviously different in view of the recent Libyan conflict; however, now that the civil war is over and the political situation is slowly returning to normality, Libya’s position coupled with an excellent variety of wrecks (mainly WWII era) and relatively low labour costs, will be important catalysts for the dive tourism markets in the country (and neighbouring Tunisia), which are likely to grow rapidly. 2.44. In 2010 (i.e. prior to the conflict), the British Sub Aqua Club recognised Libya as an emerging market and summarised it as ‘a destination to watch for the future’… Libya is probably not at the top of most divers' holiday list but there are some attractions that make the country a destination to watch for the future. For the last few years, Libya has been officially promoting tourism in an effort to start diversifying an economy primarily based on oil. However, tourist facilities are currently said to be pretty limited compared to its neighbours although, on the plus side, visitors will benefit from relatively cheap prices. A nascent diving industry is developing as the country is increasingly opened-up for tourism. Dive sites include a large number of wrecks as well as archaeological sites and there is always the lure of the supposed Second World War gold sunk offshore.20

20 http://www.bsac.com Web site of the British Sub Aqua Club. Accessed November 2010.

Conclusions 2.45. Malta presents an increasingly attractive dive destination for the main outbound markets. Its main attributes are its warm waters, good visibility and the spectacular underwater scenery. Although numerous vessels have been scuttled since the MV Rozi in 1991, the international recognition of Malta’s wreck dive offer is relatively low compared to other destinations such as the Red Sea and Cyprus. There are few wreck dive sites that portray a ‘wow’ factor with the international diving community. There may be scope to complement existing wreck sites further, especially with a “special” wreck. 2.46. Malta generally appeals particularly well to divers from a range of English speaking countries. The destination is perceived as safe; with specific benefits resulting from the close proximity of sites in relation to each other and the availability of other activities for ‘non divers’ is seen as beneficial. 2.47. A diving holiday may also become increasingly attractive to the main outbound markets as long haul destinations become less affordable in the short to medium term (as a consequence of the current global economic slowdown). 2.48. Malta enjoys a good reputation for the individual attention that many dive schools offer. The willingness to tailor dive schedules to meet the requests of divers places Malta at a specific advantage over some of the larger and more commercially run operations at Red Sea diving schools. 2.49. On the negative side, the lack of fish, especially when compared to competing destinations, acts as a detractor. This highlights the better environmental stewardship of the most cherished dive sites. The Master Plan needs to promote further measures to protect sites from illegal fishing, marine damage through anchoring, archaeological theft and other human activities. 2.50. There is a general consensus from within the industry that the benefits of diving in the shoulder months are not effectively communicated or marketed to the main outbound dive markets. Furthermore, the quality of the facilities at popular dive sites is considered poor or inadequate. These include inadequate or nonexistent parking areas, litter, access problems and lack of suitable toilet / changing facilities. Recommended actions to overcome some of these problems are provided in Chapter 3 and individual Dive Site Reports that have been prepared for the 21 shore access points. 2.51. On this basis the Diving Master Plan needs to:

· Promote the physical upgrading of sites;

· Look at the ‘wider’ offer and ensure that this is promoted; including measures to further diversify the type of attractions – for example, new Wreck Dives; and

· Review main source markets21 and undertake further web promotion targeted at potential dive tourists from these countries. Marketing efforts should continue to focus on Malta’s appeal as a safe all year round dive destination with dive sites in close proximity and alternative pursuits for ‘non-diving’ partners or family members.

A SUSTAINABLE DIVING PRODUCT

Definition of Sustainability 2.52. The World Tourism Organisation (WTO) considers sustainable tourism principles should be embedded into all areas of tourism management and public tourism policy. The WTO acknowledges22: Sustainable tourism development guidelines and management practices are applicable to all forms of tourism in all types of destinations, including mass tourism and the various niche tourism segments. Sustainability principles refer to the environmental, economic and socio- cultural aspects of tourism development, and a suitable balance must be established between these three dimensions to guarantee its long- term sustainability. Thus, sustainable tourism should: 1) Make optimal use of environmental resources that constitute a key element in tourism development, maintaining essential ecological processes and helping to conserve natural heritage and biodiversity. 2) Respect the socio-cultural authenticity of host communities, conserve their built and living cultural heritage and traditional values, and contribute to inter-cultural understanding and tolerance. 3) Ensure viable, long-term economic operations, providing socio- economic benefits to all stakeholders that are fairly distributed, including stable employment and income-earning opportunities and social services to host communities, and contributing to poverty alleviation. Sustainable tourism development requires the informed participation of all relevant stakeholders, as well as strong political leadership to ensure wide participation and consensus building. Achieving sustainable tourism is a continuous process and it requires constant monitoring of impacts, introducing the necessary preventive and/or corrective measures whenever necessary.

21 Whilst acknowledging that main source markets may change over time. For example, the addition of new routes to Spain appears to be increasing the numbers of dive tourists from this source market. 22 World Tourism Organisation Website: http://www.unwto.org/frameset/frame_sustainable.html accessed on 18th November 2010.

Sustainable tourism should also maintain a high level of tourist satisfaction and ensure a meaningful experience to the tourists, raising their awareness about sustainability issues and promoting sustainable tourism practices amongst them. 2.53. Divers and representatives of the diving industry in Malta have highlighted an acute awareness of these principles. Through feedback from industry representatives provided in meetings and a stakeholder questionnaire there is clearly a recognition that the segment will not continue to flourish without:

· Better management of dive sites (on shore and off shore);

· Increasing awareness of the ecological consequences of certain activities such as anchoring;

· Better facilities to attract divers;

· Better management and cooperation between dive schools to avoid overcrowding of sites (which has land and marine impacts); and

· The need for better enforcement and awareness of the harmful impacts of fishing on wrecks and other structures that act as havens for marine life.

The Emerging Role and Importance of MPAs and Other Related Regulations as a Means to Promote Dive Site Stewardship

Marine Protected Areas 2.54. Marine Protected Areas (MPAs) are adopted across the world, among other reasons, as a mechanism to control fish stock depletion and address problems of marine habitat degradation. MPAs use various regulations or legislation to achieve such aims. In Malta, designation of areas under the EU Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora (the Habitats Directive) (1992) provides a basis for designation of MPAs.

The Habitats Directive 2.55. The EU Council Directive 92/43/EEC23 on the Conservation of Natural Habitats and of Wild Fauna and Flora (the Habitats Directive) (1992) provides a basis for the protection of land and marine habitats that are recognised as being of Community Importance. The Habitats Directive requires the establishment of Special Areas of Conservation (SACs). These SACs are also known as Natura 2000 sites, for which management plans may be devised as a means of establishing the required conservation measures.

23 This Directive was transposed into local legislation by LN 311 of 2006.

2.56. Many of the shore dive access points are located within or close to Natura 2000 sites, meaning, in most cases, that any proposed new infrastructure will require a Development Permit Application and, potentially, an Appropriate Assessment to determine the impacts of the development on the Special Area of Conservation (SAC). 2.57. In addition to the terrestrial Natura 2000 sites, there are a number of protected marine habitats. The first marine candidate Special Area of Conservation (SAC) in Malta was designated in 2008 when MEPA granted protection status to the coastline along the area off the northwest coast of Malta, between Rdum Majjiesa and Ras ir- Raħeb, known as site MT0000101. 2.58. A further 4 marine sites were designated as Marine protected areas on 17th August 201024. Two of these are located off the coastline of Malta:

· MT0000102 - Marine Area in the limits of Ghar Lapsi and Filfla; and

· MT0000105 - Marine Area in the Northeast of Malta. 2.59. The two sites off the coast of Gozo are MT0000103 (Limits of Dwejra) and MT0000104 (Limits of Mġarr ix-Xini). MEPA has indicated that, to date, designation criteria for Marine MPAs has been based on the presence of Posidonia oceanica. Posidonia beds commonly referred to in Maltese as mergħat tal-alka provide both food and shelter for a number of marine species, act as a carbon sink, and protect beaches from sand depletion. Posidonia is a sea grass and can be damaged through marine activities such as anchoring. MEPA is currently reviewing whether further MPAs should be designated based on the presence of reefs, sand banks, caves or other features. MEPA is considering a search area of approximately 25 nautical miles from the coast25. The MPAs shown in Figure 2.8 extend to include the majority of the Posidonia meadows that surround Malta.

Natura 2000 Site Management Plans 2.60. Malta has a legal obligation under Article 4 of the EU Habitats Directive to manage Natura 2000 sites as soon as they are placed on the Community List and within six years at most, which for Malta would be 2014, for currently designated sites. MEPA has secured funding under measure 323 of the Rural Development Programme for Malta 2007-2013 for the establishment of a management planning framework for all the terrestrial Natura 2000 sites. This will be implemented through two service contracts. The first will concentrate on the development of the management plans, and the second service contract will complement these efforts by increasing awareness of Natura 2000 sites in the Maltese Islands amongst the public at large and amongst specific target groups, such as farmers and land managers. The contract will

24 Government Notice 851 of 2010. 17th August 2010. 25 Meeting held between officials from MEPA’s Environmental Protection Directive and Adi Associates on 29th November 2010.

also deliver training for these groups on Natura 2000 issues that are relevant to them. 2.61. MEPA is currently seeking funding to resource the preparation of management plans for Malta’s and Gozo’s marine Natura 2000 sites and also for the designation of new Natura 2000 sites. 2.62. Article 14(4) of LN 311 of 2006 requires that management plans are prepared to set out appropriate actions for conservation. The Article stresses that MEPA should consult widely during the preparation of such plans. 2.63. It is intended that the MTA will seek official recognition of the dive sites identified in this Master Plan. Future management plans for terrestrial and marine Natura 2000 sites are seen as important delivery tools for various aspects of the Diving Master Plan for Malta. The MTA will work with MEPA and other competent authorities to ensure issues identified as relevant to these sites are addressed through these management plans. These issues include:

· Clarity on the type of improvements to shore based infrastructure (within or near to Natura 2000 sites) that are endorsed by the management plan and, therefore, not expected to be subject to Appropriate Assessment through the Habitats Directive; and

· Enforcement of anchoring and fishing restrictions at dive sites.

European Marine Strategy Framework Directive 2.64. The Marine Strategy Framework Directive26 has been transposed into Maltese Legislation through LN 73 of 2011. This Legal Notice establishes the OPM as the Competent Authority for the implementation of the Directive, with MEPA entrusted with its technical implementation. The requirements of the Directive with regards to Malta are:

· An assessment of the current state of Maltese seas by July 2012;

· A detailed description of what Good Environmental Status (GES) means for Maltese waters, and associated targets and indicators by July 2012;

· Establishment of a monitoring programme to measure progress towards GES by July 2014; and

· Establishment of a programme of measures for achieving GES by 2016. 2.65. The overall goal of the Directive is to achieve Good Environmental Status (GES) as defined by eleven descriptors in Annex I of the Directive. In turn, GES should be

26 Directive 2008/56/EC of the European Parliament and of the Council of 17 June 2008 establishing a framework for community action in the field of marine environmental policy (Marine Strategy Framework Directive) (Text with EEA relevance).

achieved through the implementation of a marine strategy that should be developed in respect of each marine region or sub-region concerned (in Malta’s case the Ionian Sea and the Central Mediterranean Sea). The marine strategy has to be in place by 2016 and shall include spatial protection measures." 2.66. It aims to protect the resource base upon which marine-related economic and social activities depend. Diving is a growing economic resource generator and an important social / sports activity. This Master Plan (and subsequent further official recognition of dive sites) is intended to inform the assessments that are currently being undertaken by MEPA in preparation for implementation of this Directive.

Figure 2.8: Existing Marine Protected Areas – Malta

Notice to Mariners No 5 of 2008 2.67. In January 2008, the Malta Maritime Authority (now Transport Malta) issued Notice to Mariners No 5 of 2008 entitled Conservation Areas around Wrecks. The Notice was prepared in the context of the Fisheries Act27 which promotes the stewardship of fish stocks and regulates commercial fishing practices. The Notice was supported by certain dive clubs in Malta who saw it as a mechanism to maintain the abundance and diversity of fish species at certain wreck sites. The Notice prohibits boats from anchoring in the vicinity of wrecks unless for the purpose of diving. Although the Notice is issued by Transport Malta, it does not bring additional enforcement resources. By publishing such notices, Transport Malta is acting more as a ‘Conduit’ for information to Mariners rather than taking on the enforcement responsibilities that are implied by the Notice. The Notice also expressly prohibits spear fishing and the use of fishing gear such as set bottom lines, trammel nets, gill nets and entangling nets, encircling nets, demersal pots, and traps are prohibited in these areas. Appendix 1 provides definitions of the typical fishing activities that occur around the Maltese coastline. Only surface fishing is allowed aroudn wrecks, including trolling lines (rixa) and angling for pelagic fish. The wreck sites identified off the coast of Malta are listed below:

Site name Location Site name (as set out in Notice to (as set out in Master Plan – Mariners No 5 of 2008) See Figure 2.1) Um el Faroud Wied iz-Zurrieq Shore Dive Site No 11 Um el Faroud Tug St. Michael Marsaskala Shore Dive Site No 6 Tug 10 Tug Boats, Zonqor Point Imperial Eagle Off Qawra point Boat Dive Site No 15 Imperial Eagle Rozi Off Cirkewwa Shore Dive Site No 20 P29 Tug Boat Rozi, Cirkewwa

Shore Dive Site No 18 P29 Patrol Boat, Cirkewwa

Blenheim bomber Off Xrobb l-Ghagin Boat Dive Site No 9 Bristol Blenheim Bristol Beaufighter Off Exiles point Boat Dive Site 1 Beaufighter

Priorities for a Sustainable Dive Tourism Segment 2.68. The following Chapter provides a number of strategic priorities to help overcome these concerns and to ensure that the diving segment continues to develop in a sustainable way.

27 The Fisheries, Conservation and Management Act. Act II of 2001.

2.69. The Strategy sets out a number of short, medium, and long-term objectives for the industry. An action plan is provided in Chapter 4 which identifies implementation priorities and recommends regulatory changes or specific working arrangements that may be necessary.

3. STRATEGIC OBJECTIVES

3.1. Discussions and meetings with diving industry representatives have proved invaluable in identifying the main economic and environmental challenges facing the dive segment. This section sets out a number of short to medium and long-term priorities for the industry.

SHORT TO MEDIUM-TERM OBJECTIVES 3.2. The dive segment in Malta has experienced growth in recent years, partly benefiting from the expansion of the budget airline sector and possibly benefiting from a reluctance of some divers to commit to relatively expensive long-haul dive trips during the current global economic climate. 3.3. Although the segment is expanding, analysis undertaken for this Master Plan shows that the local dive industry cannot afford to be complacent. Competition is fierce, not only between dive schools in Malta but also between dive schools within Europe, and particularly in the Mediterranean. This means that even in the short-term, the industry cannot assume that divers will continue to visit Malta in preference to other destinations. Some immediate improvements are needed, including continued efforts to ensure environmental stewardship of dive sites. Priorities can be broadly summarised as follows:

· The need to physically upgrade shore dive sites to improve access;

· The need to better manage boat dive sites, formally identify these sites and, in some cases, to provide moorings to limit the impacts of anchoring;

· To continue to market the diving niche sector; and

· To improve the range and diversity of the product. 3.4. Immediate short to medium-term priorities (within the next 5 years) are identified below:

OBJECTIVE 1 - Upgrade shore and boat dive sites 3.5. Industry feedback provided a comprehensive picture of the popularity of various shore and boat dive sites. It also highlighted concerns about the state of facilities at some sites. Adequate and safe parking, lack of suitable kitting up areas and access infrastructure such as ladders were identified as inadequate at some shore sites. The need for suitable moorings and better demarcation of sites was mentioned with regard to the boat dive sites.

Shore dive sites 3.6. Following this feedback a comprehensive survey of the state of various infrastructure was undertaken. Twenty one Dive Site Reports have been produced to identify

priority interventions at shore based Dive Sites. Most of these interventions relate to access (roads, ramps, steps, and ladders), although other areas of intervention include security improvements (lights and CCTV) and management interventions (for example, bins and dedicated parking areas). Each of these interventions are characterised as of high, medium, or low priority in the individual dive site reports. High priority interventions should be addressed as early as possible. Priorities have been given (in preference to a fixed calendar of works) as it is recognised that funding opportunities change over time and assigning broad priorities highlights which interventions will provide maximum benefit. 3.7. Table 3.1 indicates the various infrastructure that is recommended at each of the shore dive sites. Each individual Dive Site Report identifies the locations of existing infrastructure and recommends the locations where new (or replacement) infrastructure should be situated. 3.8. The rows highlighted in grey show those locations where this basic infrastructure will significantly increase the usage of the site28. These could arguably be targeted early on in order to ‘open out’ access of some of these less-used sites to a wider diving audience, and thus help diversify the range of diving experiences that Malta can offer. 3.9. It should also be noted that a number of priority interventions are still considered necessary at some of the most popular shore dive site locations. For example, the P29 Patrol Boat, Sugar Loaf & Madonna, Tug Boat Rozi and Cirkewwa Arch all share the same facilities at Cirkewwa. These represent the 2nd, 3rd, 4th and 5th most popular sites. It is, therefore, logical to target resources at Cirkewwa. Similar arguments also apply to the three popular dive sites (Um el Faroud, and the West and East Reef caves) at Wied iz-Zurrieq.

28 Based on questionnaire feedback from individual divers and representatives from the diving industry. Denotes all sites where ‘site usage index’ improves by >1 following implementation. For example, Slugs Bay has a usage index of 1 (it is used rarely) and with improvements, its index increases to 2.73 (occasionally to frequently). See Figures 1-8 of Diving Master Plan for Malta: Report on Public Consultation. Adi Associates, December 2010.

Table 3.1: Proposed interventions at Shore Dive Sites O ve r a ll R n k i g ( i n c bo a t d v e s i t e s) S ho r e D i ve R a n k i ng M a p ID S i te R e p l a c h n d r ils I n s t a ll e w h a n d r i ls R e p l a c x i s t n g l a d e r /s I n s t a ll e w l a dd e r /s I m p r o v e s t ps N e w s t ps P r o v i d e k t ng up f a c il i t es P r o v i d e l f s a n g e qu i pm nt S i g n a e d i n t e r p a on P r o v i d e b ns P r o v i d e c a t p a r k i ng I n s t a l e c u r i y c a m e r as P r o v i d e l g h t n f o r n i gh t d v es I m p r o v e nt s to a c e ss r o ad I m p r o v e n t s to f o ot p a t h /s R e m o v r d ud a nt / d a n g e r o u s f e a t u r es G e n r a l c i g a nd l n d s c p i ng S e D i v t R e p o r t N o… 1 111Um el Faroud - Wied iz-ZurrieqLLHMMHH8 22 20 Tug Boat Rozi - Cirkewwa H M/H M H H H M 14 3 3 19 Sugar Loaf & Madonna - Cirkewwa H M/H M H H H M 14 4 4 18 P29 Patrol Boat - Cirkewwa H M/H M H H H M 14 5 5 21 Cirkewwa Arch - Cirkewwa H M/H M H H H M 14 6 6 10 West Reef & Caves - Wied iz-Zurrieq L L H M M H H 8 7 7 9 East Reef - Wied iz-Zurrieq L L H M M H H 8 8 8 1 HMS Maori - St Elmo Bay, Valletta H M H M M H H H 1 9 912Middle Reef - Ghar LapsiMHHMMHH9 11 10 6 Tug boats - Zonqor point M M 6 121113Finger Reef & Crib - Ghar LapsiMHHMMHH9 131216Anchor BayLLLMHHH12 141329Lighter X127 - Manoel IslandMM21 141317South Quay - CirkewwaHHHLMHH13 161522Tunnel & Reef - L-Ahrax15 191614Black John - Ghar LapsiHMMHH10 211724Qawra Point NorthM17 22185Zonqor Point North - MarsacalaMH5 25192Fort St Elmo - VallettaHHMHHMH2 272026Exiles - SliemaMLM19 29218South Reef - Delimara PointHL7 302225Mercanti Reef - PacevilleLML18 30223SS Margit - Kalkara CreekMMMH3 32247East Reef - Delimara PointHL7 352515Migra FerhaL11 362623Slugs BayMMLH16 412727Fortizza - SliemaM20 42284Mini Blue Hole - MarsascalaMLM4 442928Coral Gardens - Sliema20

H Denotes a 'High Priority' Intervention M Denotes a 'Medium Priority' Intervention L Denotes a 'Low Priority' Intervention

Top ten most popular dive sites

Feedback from divers at these sites suggests that, if implemented, the proposed interventions will substantially increase the usage of the site

3.10. Table 3.1 identifies the need for numerous small scale interventions. Many of these require Development Notification Orders and/or Development Planning Applications. Dive sites should be formally designated in order to recognise their importance to diving and to ensure that potentially ecologically damaging activities are controlled at these locations. The benefits of formal designation are that their status can be acknowledged in the context of:

· Local Plans / Subject Plans;

· Environmental Monitoring Plans for Marine Protected Areas (as required through the Habitats Directive);

· The Marine Strategy Framework Directive; and

· The Water Framework Directive. 3.11. The Master Plan recommends that the MTA seek amendments to the DNO to allow for a simplification of procedures for genuine diving related infrastructure, once dive sites are designated. The designation of dive sites is likely to be most effective through the production of a Subject Plan that highlights the location of boat and shore dive sites and identifies the most appropriate infrastructure at each location. This is a subsidiary plan – as allowed through Article 57 of the Environment and Development Planning Act 2010 (see Objective 3 below).

Better on-line management of shore dives 3.12. Web-based technology could be utilised to better manage sites and encourage a feedback culture from visiting divers. 3.13. The need for CCTV was highlighted at various boat dive sites, particularly those sites close to urban areas where vehicle theft and/or vandalism have occurred on various occasions. The MTA is keen to explore how a web-linked system of CCTV cameras could assist the dive industry to better monitor popular dive sites. Such a system could relay images in real time and be web-based. This could also be extended to provide a system similar to the ‘BayWatch’ concept adopted overseas whereby local authorities offer on-line streaming of wave / weather conditions to surfers and others who are considering a trip to the beach. An ability to check conditions via a streamed web-camera can save the need for unnecessary journeys. 3.14. Feedback from the diving industry has suggested that there is an appetite for better coordination of activities between the dive schools29. Although better coordination per se is not something the MTA or public authorities can force the industry to

29 While this has occasionally been highlighted, in practice not a lot of coordination takes place. There is definitely scope for more coordination, better planning, and possibly pooling of resources among dive centres in order to cut down on some of the costs and reducing impacts on the environment (through for example less fuel consumption, less anchoring if boat trips are shared, etc). Dive centres actions need to reflect sustainable tourism principles.

engage in, the installation of certain web-based real time ICT/communications equipment could assist. If a network of cameras could cover the most popular and remote dive sites and streaming of information and images could be provided to divers / dive schools, the following benefits could emerge:

· Electronic spy glass – allowing for a real time assessment of conditions, waves / swell / currents;

· An indication of car park usage / likelihood that the site will be overcrowded;

· On-line interactive assistance – Details of dive sites, features, depths of features, available amenities, posting of weather forecasts by dive sites (sun index, water quality, visibility etc.);

· Site security – acting as a deterrent against vandalism and theft especially in certain notorious hotspots and “out of the way” locations;

· Better enforcement – the use of an on-line system for reporting of illegal activities at dive sites in real time, offering an increased reaction time from authorities;

· Online facilities to be synced for compatibility with 3G / Smart phones to allow for streaming of weather conditions to phones, geo-caching of underwater trails / features…etc; and

· Site feedback – to allow for on-line feedback on the various sites. 3.15. The benefits are numerous, but clearly such a system will require very significant capital investment. The MTA is keen to explore this concept further as well as potential funding sources. It is likely that a pilot project could be initiated to gauge likely usage and fully explore all potential benefits. The maximum benefit is likely to accrue from an early pilot programme at Cirkewwa because:

· The site is extremely well used and remote from the majority of diving schools;

· The site is relatively exposed and therefore very weather dependent; and

· There is the need for CCTV (for security reasons).

Boat dive sites 3.16. The boat dive sites that surround Malta are identified in Chapter 2. Boat dive sites are generally those sites that offer a specific feature for recreational diving. By nature, they are off shore and hence require a boat to reach them. These sites add further diversity to the dive product and mainly offer access to wrecks. Six of these sites are at depths exceeding 50 metres and, therefore, offer technical diving opportunities.

3.17. Feedback from the industry highlights that despite no stopping designations and fishing restrictions (Notice to Mariners No. 5 of 2008 – See Chapter 2) these sites are not as actively managed as they could be. They are not generally identified with buoys or offer mooring opportunities. This can lead to damage to the sea floor or even damage to wrecks (see Figure 3.1). The diving industry has highlighted the need for buoys and moorings at these locations.

The case for permanent mooring buoys 3.18. The provision of tie-up mooring buoys for use by dive boats (and other vessels), especially in sensitive areas, is common practice and could provide a solution to the industry’s concerns. Permanent mooring buoys as a means of protecting important sea bed environments from anchor damage were first developed at the Key Largo National Marine Sanctuary in Florida. Following this initial programme, similar measures were taken throughout the Florida Keys, the Caribbean, and worldwide. One example, taken from a competing destination, is the mooring system installed in the Red Sea by the Hurghada Environmental Protection and Conservation Association (HEPCA), in a number of dive sites to prevent boats from anchoring on the coral reefs. Since 1997, the HEPCA has installed over 1,000 mooring buoys throughout the whole Red Sea, making it the largest mooring system in the world. In addition to installing the mooring buoys, HEPCA also provides training to boat captains and crew on the correct use of these buoys. 3.19. With the increase in the number of boats in the Maltese Islands, the need to protect the benthic environment against anchor damage is urgent. Evidence of damage to Posidonia oceanica meadows from anchors has been well documented, with each anchor dropped on these seagrass meadows ripping off parts of the matte, the growth of which is very slow. Such anchor damage results in the death of the matte and the formation of “halos” within the meadow (see Figure 3.1). The effective protection of these meadows30 should be placed on the same footing as the protection afforded by Malta’s diving destination competitors to their coral reefs and other marine assets. Protection from anchoring is likely to be an important consideration for future management plans for the MPA established for the North East of Malta. 3.20. All mooring buoy systems consist of three elements: a permanent fixture on the sea bed, a floating buoy at the surface and something in between to link the two. The type of system employed is largely dependent on the characteristics of the sea bed. Different systems could be employed, such as a large sinker, helical pins, or three anchors in radial plan form. The Manta Ray system could also be used in areas of sand (see Figure 3.2 for an example of the mooring buoy systems employed at Hurghada, Egypt).

30 Not solely through legislative measures affording protection to this species and marine areas, but more importantly through practical measures and site management.

Figure 3.1: An example of a “halo” in Posidonia meadows as a result of anchoring

Figure 3.2: Example of mooring buoy (as used in Hurghada, Red Sea)

3.21. Table 3.2 provides a list of the types of intervention the diving industry would like to see at the 15 boat dive sites surrounding the coast of Malta. These are generally limited to the provision of mooring facilities or the introduction of specific site management measures. The installation of such equipment is not always feasible in view of the costs involved; however, where the sites are regularly used, or where anchoring needs to be prohibited to protect the seabed or for safety reasons, the provision of alternative means of mooring is required. 3.22. The MTA will examine possible implementation programmes for the installation of marker buoys and moorings together with competent authorities such as Transport Malta (the Ports & Yachting Directorate). Resources should initially be prioritised at the locations where anchoring activities have been identified as particularly harmful. These locations are:

· Boat dive site 7 – Southwold;

· Boat dive site 8 – Le Polynesien; and

· Boat dive site 14 – HMS Stubborn. 3.23. The Chief Officer of the Ports & Yachting Directorate has indicated that buoys may require self-illumination, especially when close to busy transit lanes. Buoys and moorings may not be well-suited to shore dive locations, in particular, those located at busy transit routes (entrance and exit to the Grand Harbour and Freeport). Early consultation on the detailed management, location, and long term maintenance of such infrastructure will, therefore, be sought. This is a concern that has been identified by both the Chief Officer of the Ports & Yachting Directorate and the Amateur Fishermen Association.

Table 3.2: Necessary interventions at boat dive sites as identified by the diving industry

Map IDSite M a r ke b u o ys M o r i ng s f d v e b o a ts F i s hi n g r es t i c io ns D es ig n a t i o f s e as a M PA R e m o v a l / r e l o c a t i n f n ea r b y f i s h a ms B e tt r c oo r di n a t i on w h p o r t a u h i es A d r e s i n g se w a g e p r ob l em A n c h o r a g e p r e ve n t ion St r u c t a l a pp r i s l o f t h e w r e ck 1Beaufighter •••• 2HMS Hellespont •••• 3HMS Eddy •• 4St Angelo •• 5Schnellboot ••• 6Italian E-Boat • 7Southwold •• 8Le Polynesien •• 9Bristol Blenheim ••••• 10Migra Ferha • 11Scot Craig ••• 12Devil's Reef •• 13Qammieh Point •• 14HMS Stubborn ••• 15Imperial Eagle ••••

OBJECTIVE 2 - Encourage further marketing of the product 3.24. Generally, feedback about the Malta diving experience is good and Malta attracts significant repeat business from the main European source markets. The MTA has seized opportunities to promote the dive product through direct foreign marketing campaigns and more recently implemented Regulations to ensure industry wide adherence to safety standards (providing a level of quality assurance that is not matched at many competing destinations). 3.25. The proximity of Malta to these markets is good, and increased numbers of routes to regional airports throughout Europe has helped to ensure growth in the Diving Segment. Malta compares favourably with competing destinations in terms of the cost of travel and seasonality (with warm water temperatures throughout the year). Malta also offers some more specific benefits for dive tourists that could be emphasised further through future marketing efforts. These benefits include the short land distances between shore dives and the attention to detail and ‘personal’ attention offered by service providers. The alternative entertainment / leisure / cultural pursuits on offer for non-diving members of families or groups are also a recognised benefit. 3.26. It is, therefore, recommended that the MTA and recreational diving service providers should continue to promote Malta as:

· An all year round destination for diving with a diverse range of diving experiences;

· A destination where the dive industry is regulated to ensure rigorous safety standards are met;

· A destination where ‘non-divers’ have plenty of alternative attractions; and

· A destination with short distances between numerous and varied sites with a diverse range of wrecks, caves, reefs and other formations. 3.27. The means of communication is likely to vary, although it is noted that the majority of decisions about where to dive are made on-line. It is envisaged that the MTA will use a mix of web and magazine formats to further promote the dive segment in Malta. 3.28. There is a general concern from the industry that Malta needs to diversify the range of diving experiences. The MTA and the service providers should ensure maximum publicity is made following any future scuttling or creation of new dive attractions.

OBJECTIVE 3 - Ensuring dive sites are better managed and protected

Dive site management 3.29. The need for more effective recognition of the importance of dive sites was stressed by numerous stakeholders throughout the master planning process. A well-managed dive site can attract and safeguard demersal ground species rather than just pelagic or predator species and help to improve safety for divers, particularly at sites that are some distance from the shore. Measures that have assisted to date include “No Stopping Areas” designated in Notice to Mariners No 5 of 2008. Unfortunately, however, this Notice does not cover all boat dive sites and the current resources available to the AFM and the Administrative Law Enforcement section of the Malta Police Force are focused on the prevention of illegal hunting at sea and the control immigration.

Diving and fishing – finding a happy medium 3.30. Water quality and the presence of fish and other marine life are crucial components of the dive experience. The chronic lack of fish at all sites around Malta is worrying and a major detractor especially when comparing local sites with those of competing destinations (see also Chapter 2). One of the main issues of concern that impacts fish numbers is over-fishing. 3.31. The diving industry is aware that fishing is socio-economically important for the islands; however, it is also aware that excessive fishing pressures are depleting fish numbers and are a threat to biodiversity and therefore to the diving industry. In order for both activities to co-exist, their separation in time and space must be addressed. The designation of “no fishing zones” around certain dive sites, or the establishment of fishing seasons should be actively considered. Such measures should not be applied indiscriminately but rather they should target the more important dive sites (e.g. wrecks and their environs) and important natural sites. Establishing no fishing zones (or “no-take” zones) would allow the fish populations to grow again in these areas, eventually spilling over into adjacent locations from where they can be freely fished. Such actions are very important and can be easily achieved. The first step was the publication of Notice to Mariners No. 5 of 2008, which established a no stopping area around a number of wrecks (see below). 3.32. Once no fishing zones are established, the possibility of creating synergies between the dive centres and fishermen through, for example, instituting a closed season for fishing in certain areas while providing incentives to fishermen to ferry divers to dive sites during these periods, could provide an interesting joint effort by both stakeholders.

Review of Notice to Mariners No 5 of 2008 3.33. As an immediate action, the MTA will work with the diving industry to review and update the Notice to Mariners No 5 of 2008. This notice designates no stopping areas around 7 dive sites that are off the shoreline of Malta (Nos 11, 6, 15, 20, 18, 9

and 1). These should be reviewed to consider the benefits of further No Stopping areas around the remaining wreck dive sites. Sites that are not currently identified in the Notice and have been identified by the diving industry as in need of better management (with regard to fishing activities) are:

Boat dive sites · No 2 – HMS Hellespont;

· No 4 – St Angelo; and

· No 11 – Scot Craig;

Shore dive sites · No 9 – East Reef – Wied iz-Zurrieq;

· No 10 – West Reef & Caves – Wied iz-Zurrieq;

· No 12 – Middle Reef – Ghar Lapsi; and

· No 13 – Finger Reef & Crib – Ghar Lapsi. 3.34. Any such review should be undertaken in consultation with the MRRA and fishing industry representatives. Table 3.3 sets out the types of fishing activities that are most common at the various dive sites. It also provides an indication of the locations where the diving industry think there is the most need for a managed approach between fishing and diving activities. These sites are highlighted in grey. In working with MEPA (in the context of MPA management plans and the recommended Diving Subject Plan), the MTA identifies these sites as sensitive in terms of the interaction of fishing and diving activities and will promote measures / policies that seek to minimise potential conflicts.

Table 3.3: Sites where conflicts are most likely to exist between diving activities and fishing31

t i ng

Site n e t s)

T y pe 2008? s h o r e) F i s h ng M a p ID b o tt m) g ill a c t ivi ies L o ng i n e s L o ng i n e s S qu i d J gg ng R e c r a t io n l D ivi n g I d u s tr y h a ve s p e c i f lly s u r f a c e o m t h ( D e p l o ye d a t h t o c n tr ol f i s h g d e s i gn a t M P A? W i t h n a e xis i d e n t f h R e c r a t io n l S h o I d e n t i f ie N o c F i s h ng f r o m V e el t o M ar i n e r s N 5 f (d e p loy d a lo n g t h N e tt i ng ( tr a mm el & 1 Beaufighter Boat dive • • • • YES 2 HMS Hellespont Boat dive • • • • 3 HMS Eddy Boat dive • • • 4 St Angelo Boat dive • • • • 5 Schnellboot Boat dive • • 6 Italian E-Boat Boat dive • • 7 Southwold Boat dive • • 8 Le Polynesien Boat dive • • 9 Bristol Blenheim Boat dive • • • YES 10 Migra Ferha Boat dive • • 11 Scot Craig Boat dive • • • • 12 Devil's Reef Boat dive • • • 13 Qammieh Point Boat dive • • • 14 HMS Stubborn Boat dive • • • YES 15 Imperial Eagle Boat dive • • YES YES 1 HMS Maori - St Elmo Bay, Valletta Shore dive • • 2 Fort St Elmo - Valletta Shore dive • • • 3 SS Margit - Kalkara Creek Shore dive • • • 4 Mini Blue Hole - Marsaskala Shore dive • • • • 5 Zonqor Point North - Marsaskala Shore dive • • • • 6 Tug boats - Zonqor point Shore dive • • • • YES 7 East Reef - Delimara Point Shore dive • • • 8 South Reef - Delimara Point Shore dive • • • 9 East Reef - Wied iz-Zurrieq Shore dive • • • • • YES 10 West Reef & Caves - Wied iz-Zurrieq Shore dive • • • • • YES 11 Um el Faroud - Wied iz-Zurrieq Shore dive • • • • • YES YES 12 Middle Reef - Ghar Lapsi Shore dive • • • • • YES 13 Finger Reef & Crib - Ghar Lapsi Shore dive • • • • • YES 14 Black John - Ghar Lapsi Shore dive • • • • • 15 Migra Ferha Shore dive • • • • 16 Anchor Bay Shore dive • • • YES 17 Cirkewwa - South Point Shore dive • • • YES 18 P29 Patrol Boat - Cirkewwa Shore dive • • • • YES YES 19 Sugar Loaf & Madonna - Cirkewwa Shore dive • • • • YES 20 Tug Boat Rozi - Cirkewwa Shore dive • • • • YES YES 21 Cirkewwa Arch - Cirkewwa Shore dive • • • • YES 22 Tunnel & Reef - L-Ahrax Shore dive • • • YES 23 Slugs Bay Shore dive • • • YES 24 Qawra Point North Shore dive • • • YES 25 Merkanti Reef - Paceville Shore dive • • • • 26 Exiles - Sliema Shore dive • • • 27 Fortizza - Sliema Shore dive • • • 28 Coral Gardens - Sliema Shore dive • • • 29 X127 Water Lighter - Manoel Island Shore dive • •

31 Popular fishing activities at (or near) each site as noted by the Ministry for Resources and Rural Affairs. Letter to Adi Associates dated 17/01/2011.

Natura 2000 management plans – an opportunity better resourced, enforced and managed dive sites 3.35. Management Plans for terrestrial Natura 2000 sites will be introduced by 2014. It is imperative that these terrestrial management plans take account of the infrastructure and recommendations of this Diving Master Plan proposed at the relevant shore dive sites. Proposed interventions at sensitive SAC/SPA sites have been kept to a minimum. For example, only signage is proposed at Migra Ferha and it is considered appropriate to re-designate this site as a boat dive site – to discourage shore-based assess through a designated SAC/SPA, AEI and Area of High Landscape Value. Where possible / relevant these emerging management plans should endeavour to assess the significance of the impact of interventions at dive sites that are within SACs/SPAs in the context of the Habitats Directive. This will help to ensure minor interventions at dive sites within Natura 2000 sites are not subject to Appropriate Assessment procedures. The MTA will, therefore, work with MEPA to ensure that land-based site improvements at shore dive sites complement any Natura 2000 Site management objectives. 3.36. Not all Natura 2000 sites are terrestrial. The management plans for the recently designated MPAs will eventually provide an excellent opportunity for further management of these important marine habitats. These management plans should be seen as a way to prioritise resources. The MTA will work with MEPA to ensure that these management plans set out how enforcement resources will be deployed for the protection of dive sites, particularly from illegal fishing activities and indiscriminate anchoring. Other priorities will include the control of marine activities and the improvement of standards, particularly in relation to fish farm feeding / debris and location of farms relative to dive sites.

Diving Subject Plan 3.37. Figure 2.8 shows that not all dive sites are included within the designated Marine Protected Areas. It is, therefore, recommended that official recognition and charting of all dive sites is pursued as a priority. The benefits of official recognition are that complementary policies can be introduced to set out site-specific policies for all dive sites (land access points and shore/boat sites). This could be achieved through the adoption of a Subsidiary Plan as part of the Environment and Development Planning Act 2010. Article 57 of the Act states Subsidiary Plans may be prepared… Where the Authority considers that for the proper and effective management and protection of the environment and of development or the proper protection and development of land and sea, it is necessary to prepare more detailed policies or plans and guidance other than those already contained in a plan or policy, the authority may prepare and adopt such policies or plans as it considers appropriate subject to the provisions of this article. 3.38. It is, therefore, recommended that the MTA seeks the following approach:

Figure 3.3: Possible ways to raise the status of dive sites and simplify procedures for new infrastructure

OBJECTIVE 4 – Diversify the product 3.39. The Gap analysis of the dive industry in Malta showed that Malta competes very well with other destinations. Malta is known for the range of alternative activities it offers for accompanying non-divers, making it an attractive destination for families and groups where not everyone wishes to engage in diving. 3.40. The dive industry has highlighted the lack of a diverse range of quality dive sites and a lack of marine life at sites as a potential disincentive for divers to travel to Malta. Another concern is that the class and type of wreck dives are very similar. Divers have suggested there is a need for:

· More scuttling of wrecks, particularly in shallow waters; and

· The introduction of ‘reef balls’ or other artificial reef technology to help promote fish stocks and marine life generally. 3.41. Although all structures placed on the sea bed have the potential to attract fish and other marine life, this Master Plan distinguishes between wrecks and artificial reefs. International demand for new wreck attractions is growing with the growth of diving as a leisure pursuit. In many countries this demand is also coming from the fisheries sector in order to boost fish stocks. Recent consultation with the Amateur Fishermen Association in Malta has also shown there is a keen interest in the creation of artificial reefs as a way of sustaining fish stocks. The Fisheries Division of the Ministry for Resources and Rural Affairs is not currently actively pursuing the use of FAD (Fish Aggregating Devices). However the Division is aware of the potential benefits of artificial reefs as a means to provide alternatives to fishing at wreck and other sites. Provision of such alternatives could be useful in areas where new fishing restrictions could be introduced in the future32. 3.42. Respondents to the dive industry questionnaire (Summer 2010) were asked to identify potential locations for wrecks and other underwater attractions. The following were mentioned:

· Balluta Bay;

· Cirkewwa;

· Exiles (Sliema);

· Outer Mellieha Bay;

· Outer Mistra Bay;

· Qammieh;

32 Views expressed by the Director of Fisheries at meeting held on 15th December with Adi Associates.

· Qawra;

· Qui-si-sana (Sliema);

· St Paul’s Islands;

· Wied iz-Zurrieq; and

· Zonqor Point. 3.43. Suggested attractions included reef balls, old buses, statues, another large ship and an aeroplane.

Scuttling of Wrecks 3.44. The introduction of new wrecks can help maintain variety and interest in Malta’s dive tourism product. It is clear that, in recent years, Malta has benefited from an increased number of purposefully scuttled wrecks. While many of these would have been made available for scuttling more out of the original ship’s owner need to dispose of the vessel, once purchased by, or transferred to, the diving industry, the vessels were properly cleaned and their scuttling subjected to rigorous environmental assessment and development permit application procedures. In this way, the vessels were given a second life as an artificial reef benefitting the diving industry. Whilst it is envisaged that more vessels will be scuttled, a less ‘indiscriminate’ approach to the siting of wrecks may be necessary in the future. This is in part because:

· MEPA has indicated that while it will pursue the formulation and implementation of management plans for existing MPAs and marine Natura 2000 sites, it does not rule out new designations in the future;

· The industry has indicated that the deployment of wrecks in shallower waters would benefit the industry; and

· The deployment of fewer but larger or more unique wrecks would create more attractions with an international appeal. 3.45. The MTA should work with the PDSA and other industry stakeholders to identify the types of ‘set piece’ wrecks that could have maximum impact on raising Malta’s profile as a diving destination. The preferred types, sizes and ideal depths for new wrecks could be identified in the proposed Diving Subject Plan together with broad areas for deployment. As part of the Subject Plan, the sites suggested by the industry (above) should be reviewed and considered. 3.46. The exact siting can only be decided following detailed technical studies such as Environmental Impact Assessment. The Subject Plan should provide a clear remit for future scuttling projects to look at the benefits and practicalities of setting up new artificial reefs close to future scuttled vessels. These reefs may allow for alternative fishing opportunities to compensate for the implementation of No Fishing Zones.

Artificial Reefs 3.47. The exact location for the deployment of artificial reefs should be considered carefully. The development of further dive sites through the construction of artificial reefs is likely to improve the diving product, offering a greater choice and allowing Malta to better compete against other diving destinations. The MTA is committed to further explore the possibility of new artificial reefs in consultation with the dive industry and other stakeholders. Important issues to address will include:

· The siting of new artificial reef structures as a means to relief pressure for fishing on wrecks or natural reefs;

· The siting of new artificial reef structures as a means to relief pressure for diving inside caves; and

· The siting of new artificial reef structures (with non-fishing zones) to act as purpose build diving structures. 3.48. The MTA intends to wait for further baseline work for the MPA management plans to be undertaken by MEPA. As further information about the state of the marine environment is made available, the MTA wishes to identify ‘broad locations’ where new artificial reef structures would have maximum benefit. These broad locations will be identified in the Diving Subject Plan. As part of the Subject Plan, the sites suggested by the industry (above) should be reviewed and considered. Sites that already support wrecks should also be actively considered for the deployment of (smaller) artifical reefs that would help to consolidate the dive site. 3.49. It is important that the final design and siting of reefs allow for maximum environmental benefits (particularly in MPAs). Issues such as the best design for maintaining fish stocks, materials (that minimise leaching / environmental damage), and siting to minimise potential to damage pipelines, cables, and fishing gear are all considered. These principles also apply to the scuttling of wrecks and it is, therefore, important that these issues are addressed in any wreck / artificial reef development application and the necessary precautions and mitigation measures are put in place to mitigate such possibilities. These issues are normally dealt with through the Environmental Impact Assessment process. 3.50. Product diversification, however, should not stop with scuttling of wrecks or deployment of artificial reefs. The diving industry needs to innovate and create new services through a creative approach to diving. Ideas could include the promotion of specific themed diving packages linked to, for example, history, culture and folklore (e.g. historic wrecks, Migra Ferha, San Dimitri, etc), religious themes (e.g. St Paul’s Islands, San Dimitri, etc), geology (e.g. Delimara, Migra Ferha, caves, reefs, etc). Also the promotion of eco-dives, with the help of specialised tour guides and provision of detailed information on the subject. 3.51. The diving industry should also attempt o link up with other service providers as has happened with the EFL schools. Other links could include CIT, culture, and sports. Innovation should link to the past and the contemporary and take up novel ideas and

current affairs matters, such as environment friendly approaches, ecological thinking, initiatives, etc. Ideas from foreign centres could also be adopted here, for example, in some places, dive centres organise an annual seabed clean–up that they also market among their foreign customers.

MEDIUM TO LONG TERM OBJECTIVES

Cleaner Seas – Relate to WF Directive / Cleaning of Vessels 3.52. Many respondents felt that the diving community should regularly participate in seabed cleanups. It is recognised that the dive community could do more to assist with seabed clean ups. Public agencies and competent authorities should also continue to coordinate to ensure water quality improvements continue. 3.53. The commissioning of the new sewage treatment plant at Ta’ Barkat, l/o Xghajra will result in significant water quality improvements in the vicinity of Wied Ghammieq on the limits of Kalkara. This will be complemented further through other measures related to the Water Framework Directive and the Marine Strategy Framework Directive. 3.54. The MTA will continue to lobby MEPA to ensure that due regard be given to the environmental and socio-economic significance of the dive sites identified in this Master Plan, and eventually designated through the Diving Subject Plan, when compiling baseline studies for implementation of the Marine Strategy Framework Directive.

Environmental awareness and training 3.55. The diving industry in general needs to become more geared towards conservation of the marine environment on which it depends. In order to do this, it is important that the various service providers (dive centres, instructors, boat crew, etc) are trained to provide a better service that respects the environment. To this end, environmental awareness programmes for diving instructors / dive masters, for boat handlers / crew, and also for the boating community in general should be organised. Training would cover environmental issues, safety at sea, tourism and marine ecology, correct diving procedures to minimise environmental damage, and similar topics aimed at increasing the awareness of the participants. 3.56. All service providers should also be provided with training on how to deal with tourists. 3.57. Foreign instructors who visit the island to work with dive centres for a few months should also be required to attend such environmental courses prior to taking up the job. This would provide them with enough information on the marine environment of the Maltese Islands, provide some induction on the aims of the industry and also provide an opportunity for liaison with such entities as Transport Malta, and the Civil Protection Department on such issues as safety at sea and accident management procedures.

Improving Safety 3.58. Training in safety awareness and rescue procedures will help reduce accidents. Boat handlers and crew would require training in first aid, CPR, and oxygen administration, since they could be the first to provide assistance on the scene of an accident. 3.59. The installation of physical safety measures, such as polypropylene safety lines / guidelines in caves, shot lines on the deeper wrecks, and warning signs informing boat users as to the possible presence of divers should be installed in appropriate locations. 3.60. Management of boat traffic at sites that are heavily used by both divers and recreational craft, is a must. Simple and clear guidelines on approaching such areas should be issued and provided to boat owners and visible warning signs erected on quays and jetties or slipways, as appropriate. The MTA will liaise with Transport Malta for the latter to install such signage and provide information as appropriate.

Maintaining and improving standards of Diving 3.61. The diving industry must itself maintain and continually improve its standards of service through a system of self-regulation and continual professional development. Measures such as the formulation and adoption of a Code of Responsible Diving, a Code of Practice on Wreck Diving, Dive Permit Systems for certain areas, a Code of Conduct for diving in Marine Protected Areas, etc., should be considered. Such measures should not unnecessarily hamper the industry, rather they will serve to uphold standards and weed out the cowboys. Adoptions of such standards and self- regulatory measures and adherance to Codes of Practice will send a positive message to the international diving community.

Environmental Protection 3.62. The diving industry is intimately tied with environmental protection. Examples of environmental protection initiatives initiated by diving associations around the world abound. This role of the diving community must be acknowledged by the environmental authorities and associations supported to further this role. Authorities should encourage the industry to organise itself in a way that it could provide input to environmental protection and conservation of the marine environment at the dive sites. 3.63. Initially, dive centres should commit to adopting a strict “hands-off” policy, whereby their instructors and dive leaders are trained on the importance of the marine environment and to ensure that nothing is touched or removed from the seabed. An environmental code for responsible diving could be drawn up and adopted by dive centres. The dive centres would actively promote this code / policy by also transmitting it to their clients and alerting each dive group to the aims and objectives of the Code. Dive centres should also commit not to take on divers who do not abide by, or who infringe, these rules. The motto should be “to respect and protect Malta’s sea and its inhabitants”. Such a policy can also be used as a marketing tool as done so effectively by other diving destinations (e.g. Belize, Red Sea, Thailand, etc).

An effective marketing tool as part of such a hands-off programe would be for the dive centres to issue an exclusive certificate or other memento to divers who support this programme by abiding by these rules. This would also serve as a small memento of their trip to Malta. Such certificates / mementoes could also be sponsored by the MTA / Ministry for Tourism or other agency.

4. IMPLEMENTATION PRIORITIES AND ACTION PLAN

4.1. The following action plan summarises the findings of the Master Plan. These are the main actions that can assist to bring forward a more sustainable diving segment for Malta.

Action Time Comments Action by Frame Review of Notice to Immediate This notice should be reviewed to Transport Malta, MRRA Mariners No 5 of 2008 determine whether further boat dive (Fisheries) & MTA sites should be included as ‘no stopping’ zones.

Consider establishing no-fishing zones and closed seasons for fishing in certain areas Official Designation of Within 2 To prepare a Diving Subject Plan to: MTA, MEPA, Dive Dive Sites years • Formally identify all shore Industry and other and boat dive sites; stakeholders. • Identify broad areas best suited for future wrecks / artificial reef structures; and • Identify proposed physical infrastructure at shore and boat dive sites. To include the designation of Migra Ferha as a boat dive site and not a shore dive site. Amendments to Within 2 Table 3.1 identifies approximately MEPA & MTA Development years 150 interventions at the 21 shore dive Notification Order sites. Approximately 100 of these interventions are likely to require a Development Planning Permit. Pursuit of permits for such small scale infrastructure will significantly delay implementation. Amendments to the DNO will assist in simplifying the implementation of infrastructure identified through this Master Plan and the proposed Diving Subject Plan (see above). Carry out interventions 2-5 years Interventions should be prioritised at MTA, Dive Industry, at shore dive sites as the popular dive sites and will be MEPA proposed through the 21 dependent on availability of funding. Dive Site Reports prepared for this Master Official designation of all dive sites Plan. through a Diving Subject Plan and amendments to the Development Notification Order (See below) will help to simplify the permitting process and could speed up the time frame for

Action Time Comments Action by Frame implementation.

MTA will seek all opportunities to fund a pilot project to examine the potential to link CCTV cameras at Cirkewwa with an online dive site ‘spy camera’ and associated information / feedback web site.

Carry out interventions 2-5 years Interventions should be prioritised at: MTA, Transport Malta, at boat dive sites – • Boat dive site 7 – Southwold; Dive Industry, MEPA marker buoys and • Boat dive site 8 – Le mooring buoys. Polynesian; and • Boat dive site 14 – HMS Stubborn. But should then be rolled out to other sites in consultation with TM and MEPA. Natura 2000 terrestrial By 2014 MTA will work with MEPA to ensure MEPA and other management plans the speedy introduction of stakeholders / land management plans at terrestrial SPAs owners. / SACs that overlap with shore dive MTA (re: diving sites. infrastructure needs and access to dive sites) Marine Protected Areas Ongoing MTA will work with MEPA to ensure MEPA, MTA, MRRA management plans the speedy introduction of (Department of management plans for MPAs that will Fisheries), and take into account the specific issues stakeholders from the that have arisen for existing and fishing industry. future boat dive sites. MTA will lobby MEPA to ensure MPA management plans are resourced to ensure better enforcement of no stopping areas and fishing controls at dive sites. Continue to promote Ongoing MTA will continue to seek MTA and dive industry Malta as a Dive Tourism opportunities to promote Malta as a Destination, particularly Dive Tourism Destination, building on in main target markets its strengths…

• An all year round destination for diving with a diverse range of diving experiences; • A destination where the dive industry is regulated to ensure rigorous safety standards are met; • A destination where ‘non- divers’ have plenty of alternative attractions; and • A destination with short distances between numerous and varied sites with a diverse range of wrecks,

Action Time Comments Action by Frame caves, reefs and other formations.

Further diversification of 2-10 years MTA to work with the dive industry MTA and MEPA the product to actively seek opportunities for the scuttling of new wreck attractions and the creation of artificial reefs. Priority will be given to new wrecks/attractions in shallow waters (to a new ‘set piece’ attraction that provides a distinct attraction – for example an aeroplane or submarine. The MTA will work with MEPA to identify broad areas for future scuttling opportunities and locations for new artificial reefs. These broad areas will be identified through a Diving Subject Plan. Adoption of Codes of Ongoing Dive centres to work together to Diving Industry Practice and formulate and adopt codes of practice Environmental Protection to help improve their standards of measures by the Industry service and generate environmental marketing tools.

IMPLEMENTATION PARTNERS 4.2. Implementation partners will vary depending on the aspect being addressed. The Malta Tourism Authority will seek to coordinate implementation where possible and will actively seek to assist the industry in gaining access to funding where projects can assist in meeting the objectives of the Master Plan. Other important roles for the MTA will remain through its marketing efforts and responsibilities for Malta’s Diving Regulations (LN 357 of 2010). 4.3. The implementation of the Master Plan remains the sole responsibility of the MTA. It is envisaged that other authorities, individuals, companies, and organisations will assist. These include:

· MEPA;

· The Ministry for Resources and Rural Affairs (MRRA) – mainly through the Fisheries Directorate;

· Diving Industry – Including diving NGOs (PDSA and Malta Marine Foundation), dive clubs / schools and the Government of Malta (through the MTA);

· The fishing industry including the Amateur Fishermen Association and professional cooperatives; and

· Transport Malta (particularly in connection with its maritime regulatory responsibilities). 4.4. I order for this Master Plan to be effective, there is a need for financial and other resources to be made available specifically for the implementation of the Plan in line with a detailed timetable to be agreed with relevant stakeholders.

APPENDIX 1 – DEFINITIONS OF FISHING ACTIVITIES

Drifting Vessel: means a craft not using engine power relying on the combination of wind and current to determine its course. Squid fishing: Vessel having a single or multiple lines suspended directly below it, at varying depths, several artificial lures being attached to each line and terminating with a weight. Fishing with this setup involves this rig being jigged gently up and down from time to time. Gill net: consists of a single panel of net. Trammel nets: consists of three panels of nets, one middle panel of small mesh and two side panels of larger mesh.

Long lines: consists of a main line carrying numerous hooks suspended off branches, (snoods) of variable length and spacing, normally deployed horizontally at varying dept, drifting long line would be deployed off shore. Traps octopus: consists of a main line having a number of metal cages attached to it. Traps Bogue: consists of basket pots deployed off a vertical main line, from vessels and off cliffs Pole and line: consists of pole of varying length having an equivalent length of line attached to it. Rod and Reel: consists of a rod of varying length having a reel or spool of line capable of holding lengths of line, enabling the angler to cast out a length of line or fish from a height.

Trawling lines: consists of a length of line with one or more lures or baited hooks pulled behind a vessel in motion.

APPENDIX 2 – CONCEPT DRAWINGS FOR DIVING INFRASTRUCTURE

Kitting up bench and parking arrangement (e.g. Cirkewwa, Ghar Lapsi, Qaliet)

Handrail

Stairway