The Pals General Plan, in force since 1986, is one of the most outdated in all of Catalonia.
The Plan provides for the construction of new housing developments in the forested and flood-prone areas of Pals Beach, covering a large area.
Several natural areas of interest on Pals beach are designated as developable under the 1986 General Plan. They cover a large expanse of pine forests on continental and coastal dunes known as Rodors, to the south of the town near the beach.
According to the Directive 92/43/EEC, are Habitats of Community Interest (HIC) “Priority”. In addition, the Partial territorial plan of the Girona Region approved on 14 September 2010, Very rare and scarce, of particular connector interest..
At the northernmost part of the seaside municipality, there is one of the last wetlands available for development. It is a floodplain, used for forestry and rice cultivation, with an area for development known as the Jonquers. This sector, a few years ago, was part of the old Vernegar Pond. Currently, there is the Path of the Islands, which provides access to the Basses d'en Coll Partial Natural Reserve. The Basses area is part of the Natura 2000 network, a Special Protection Area for Birds (SPA), and forms part of the Natural Park.
In 1948, Josep Pla writes in his book Guide to the Costa Brava About the landscape of wetlands and dunes at Pals beach:
«These low-lying, lacustrine, uncertain, blurred and marshy lands, separated from the sea by the pinkish jaspilated brushstroke of the sand, evoke a sense of primitive, free life. Slashed by the sea winds, its atmosphere carries the brackish marine air mingled with the sturdiness of decayed mud, the detritus of dead waters and the rotten scent of aquatic plants. It is a primeval and rugged landscape, of irreparable solitude.«.
The marshes to which the author referred have been gradually urbanised and their use altered. The marshy lands and dunes have been removed, and numerous buildings and tourist facilities have been constructed, transforming the landscape forever.
Josep Pla describes Vernegar Pond and the pools in 1948 in this way, as an area full of biodiversity and life:
«"Inland there are the Basses, large lagoons that are a good nursery for fish, sea bass, plaice and, above all, eels. This place is home to all kinds of birds and aquatic birds."»
In 2019, the Master Plan for the Revision of Unsustainable Lands on the Girona Coast (PDU) was approved. This plan reclassifies areas designated for development due to their environmental value, but does not assess the Jonquers.
This is a sector delimited by the future construction of the North Road. The area is floodplain and preferential flow habitat of natural interest. It has a diversity of amphibians, crustaceans, birds, heteropterans, coleopterans and trichopterans, small mammals, fish fauna and helophytic vegetation. Moreover, it is a necessary habitat for bird migration at both European and Iberian levels. The planning envisages constructing a high-rise building for hotel use and economic activity, with high build density, and a large car park facing the road and the Reserve.
In November 2020, Pals Town Council commissioned the drafting of the North Road project. This project aims to complete the works on this road, which began in 2003 during the term of Mayor Joan Silvestre Albertí. The work was continued in a second phase in 2012 by the same mayor.
This new road will affect a priority HIC pine forest on dunes and a rice paddy opposite the Basses. The road will delineate a new floodplain area that the General Plan has incorrectly classified as urban land for over 40 years. Furthermore, the road will cross non-urban land of agricultural interest designated as a biological connector between the PEIN Muntanyes de Begur and the Natural Reserve.
This road will be the preliminary step before the definitive elimination of the Rodors and Jonquers pine groves and their development.
In 2017, the Ombudsman issued a Resolution of case file 7667/2016 Regarding the first approval of the Pals POUM in 2015. This resolution warns of the environmental impacts on the Jonquers sector and the Jonquers:
«Environmental impacts on the Jonquers sector: Situated at the north-western end of the Platja de Pals settlement is the area known as the Jonquers. This urban development zone, unlike the others, would be primarily devoted to hotel services and other economic activities.
«As we have already analysed for the Paratge Rodors Nord sector, this sector is located right on the edge of the Montgrí, Medes Islands and Baix Ter Natural Park, specifically just to the south-west of the Basses d'en Coll natural area. In this case, the POUM incorporates some environmental conditions, such as locating the green spaces or open areas at the northern end so that they act as a buffer zone between the urban area and the boundaries of the Natural Park, but it would still represent a significant urban encroachment on natural spaces of high ecosystem value. Furthermore, we would not be talking about a residential sector that could, if the case arose, be low-impact and low-density, but rather a hotel and commercial sector that would be developed with priority over the rest.«
«The Basses d'en Coll wetland, catalogued under number 04001004 in the’Catalogue of Wetlands of Catalonia of the Generalitat, stands out for being "a system of two ponds that constitute the mouth of the Molí canal, where the water from the Pals rice fields ends up". The same descriptive sheet of the space states that "the area is an important breeding point for birds such as the little martin (Ixobrychus minutus), amphibians, invertebrates, etc. It is worth highlighting, for example, the population of turtles (Triops cancriformis)". It is also worth noting that the space is a breeding area for the otter (Lutra lutra), and is included in the Conservation Plan for this species promoted by the Generalitat of Catalonia.«
«While some of these are due to the use of fertilisers and phytosanitary products in rice paddies, others are due to human pressure and the increased impacts resulting from urban development. Putting forward a plan for urban development with hotels, commercial areas and housing right on the edge of an area with this ecological fragility, home to threatened and protected flora and fauna, and in an ecosystem that is already suffering certain impacts, is not the best option. Therefore, for all the above reasons,The development of this sector is strongly discouraged..«
The Master Plan provides for the declassification of forest areas of environmental value at Pals Beach. These areas are priority HICs such as Rodors South. It also declassifies the Rodors North sector, where the Neptuno campsite currently stands. It further declassifies areas with slopes exceeding 20°3′, such as Puig Padrós and Roca Blanca, which feature a continental dune and are used for forestry.
The Master Plan also provides for the “Declassification and grading with possible recovery”to other sectors. This should be done through a new POUM, reducing buildable area and converting some uses to economic activity.
This is the case of five sectors. The Rodors 3 site., and the Rodors 1, 2 and 3 sectors, with a forest area of 24 hectares. Further to the east, the same applies to Saguer's pine grove, designated in the planning scheme as the Palsmar North (Interpals) sub-sector.
Estates at Pals Beach
It is difficult to know with exactitude the potential for growth and the number of dwellings in terms of the town planning of Pals Beach.
It is a municipality that, with only 2,461 inhabitants, tea 12 sectors of unprogrammed urbanisable land, 7 of scheduled urbanisable land. It also has a variety of urban improvement plans and action units partly focused on second homes, campsites and future hotels. It is the Girona municipality that sees the greatest increase in population during the summer, more than quadrupling its numbers.
According to the Land Observatory (2019), there are 57 plots awaiting the construction of multi-family housing. There are also 181 plots awaiting single-family housing in consolidated urban land, with a potential of 379 new homes. These occupy a total of 21 hectares.
There is a potential for 244 new homes in development areas awaiting development. They are unconsolidated urban plots, comprising second homes on the beach and farmhouses.
There is a potential for 2,350 homes on developable land. The majority (2,204) are second homes, 1,592 in multi-family buildings in the Rodors area and the future Rodors 1, 2 and 3 developments on the beach. Of these, 612 are in Masos and only 146 dwellings in two sectors close to the village.
Pals has no Catalogue of farmhouses, rural houses and other buildings on non-urbanisable land. This catalogue should identify buildings of architectural, historical or cultural interest that meet certain requirements making their preservation necessary. There is a large number of farmhouses and historic buildings awaiting rehabilitation or in a state of ruin, approximately. 120 homes potentials.
According to Idescat, there are 383 homes Vacancies in the municipality from 2011 to the present, which represent 101% of the total.
Furthermore, there is a large number of plots and homes for sale within beachside developments. These are not recorded as vacant by IDESCAT. We do not have any estimate for this figure.
According to the summary table (Image 2), the Master Plan requires a reduction of at least 1,392 dwellings on the beach's urbanisable land. This means that in a future POUM Paratge Rodors could be developed for hotel use, economic activity and second homes. The same can be done in the dune forest sector north of the Interpals campsite, with hotel use and parking areas.
In the Rodors 1, 2 and 3 area, the Master Plan reclassifies them as land that may be developed in a future POUM. These are forest plots where the Master Plan allows hotel use and economic activity. It also permits car parks and a second-home zone.
Nevertheless, there is still potential for growth of at least 1,800 new homes Under the current planning regulations, after this reduction. Moreover, some of these developments are still geared towards second homes and hotel uses in the forested areas by the beach.
If the housing units that the PDU It is therefore foreseeable that second homes will come to exceed the 80% in the municipality. Let us remember that Pals is The municipality with the highest proportion of second homes relative to main residences in all of Catalonia..
If the housing that the Power Distribution Unit It is therefore foreseeable that second homes will come to exceed the 80% in the municipality.
The areas marked on the map in yellow (Image 4) consist of sectors that the Master Plan marks as "Extinction" in red (Image 3). But the reality is that these sectors foresee a possible recovery, reducing the buildability. These are:
Paratge Rodors
The Master Plan envisages the declassification of this sector, with possible redevelopment through a new POUM. This Plan provides for hotel use and economic activity, with an area equivalent to 79 new homes.
In one part of this area there is dune habitat with pine and holm oak, and it is bounded by the Ral path, dating from the 12th to the 18th centuries and built of dry stone. This path should form part of the public inventory of municipal roads, but at present the municipality has no such inventory. The path and its dry-stone construction should also be protected and classified as a Cultural Asset of Interest, and may not be privatised.
The upper part of the woodland has holm oak groves, bordering the PEIN. This area was partially within the PEIN and was surprisingly downgraded, removing its protection. Location on Google Maps., here. (Image 4).
North Sector Palsmar – Interpals
the PDU provides for this exceptional forest area, called Saguer's Pine Grove. Priority HIC, priority HIC of pine forests on dunes, 66 new homes in high-rise multi-family buildings and a buildable roof area of 9,161 m²2. The sector is very close to Radio Liberty and the archaeological remains of the Torre Mora, next to a giant dune. (Image 4).
The areas on the plan coloured green (figure 4) are sectors. that the PDU has not considered. Although they are currently rural land with HIC, the General Plan defined them as unconsolidated urban land. This classification is surprising because they still do not qualify as building plots. Of these areas, those with the greatest environmental value are:
North Road and the Jonquers
The 1986 General Plan provides for a road that crosses a rice paddy. This paddy is flood-prone and subject to preferential flow, and it borders the Partial Natural Reserve of the Basses d'en Coll. This environment has great ecological importance. Here you will find the Reserve's information centre and the start of the Camí de les Illes, which is the entrance to the Natural Park for pedestrians and cyclists. Els Jonquers covers an area of 10,184 m²2 and, surprisingly, the City Council plans to build a roof covering 5,603 square metres.2. This represents a buildability index of 0.55 m.2 standard time/minute2. This is high if we consider that it is the end of the urban area opposite the Park.
In the POUM initially approved in 2015, the area increases to 11,819 m².2, with a buildability of 0.80 m2 standard time/minute2. This is a buildable ceiling at 9,402 m2. Of these, 4,701 metres2 for hotel use, 3,761 m2 for residential use with 32 new homes, 940 m2 for commercial use and a large car park of 2,417 m²2.
The failure to declassify this sector runs counter to the Resolution of Ombudsman case file 7667/2016 As of 17 February 2017, we can view in 3D the information centre and entrance to the Natural Park that the Town Council wants to remove. Location on Google Maps. here. (Image 4 and 7).
Giant Dune Sector
It was a riparian woodland with a pond and a giant continental dune with priority HIC pine forest, perhaps the most exceptional example of a dune. Unfortunately, in 2019 the Town Council allowed a pine forest and part of the giant dune to be removed in a green area. A multi-family building with second homes has been constructed. It is planned to build another multi-family building of one storey plus three storeys with 25 new homes and a building for hotel use (key 13b). (Images 5, 7 and 8).
Pineda de Pals
It is currently a pine forest area on dunes of great environmental and scenic importance. The Town Council is planning a development comprising four multi-family high-rise buildings. These buildings have a buildable area of more than 7,000 m2 where between are expected 65 to 70 new homes. This forest sector has a large building, only the skeleton of which remains, that people know as the ghost building. Construction has been halted for over 35 years, putting pedestrians' safety at risk. The council has allowed it to be converted from a hotel into second homes.. (Images 6 to 9).
Arenals Mar Area
As of today, it is a pine forest on dunes at the entrance to the Gulf of Pals, covering approximately 9,000 square metres.2. The General Plan allows the construction of detached or semi-detached houses on plots of 400 m².2. This transformation will have an environmental impact on Rodors, due to the steep slope and forested nature of the land, with the potential to 22 new homes. (Image 4).
The areas shaded green in image 4 are housing developments with undeveloped plots (multi-family and single-family). They have the option to subdivide plots and build, or to increase their building capacity. This applies to developments such as Duna Gegant, Pineda de Pals, Puig Vermell and Arenals Mar.
The Master Plan declassifies, with the possibility of reclassification, the Rodors 1, 2 and 3 sub-sectors, along with other economic activities and hotel use. On the other hand, it declassifies the Roca Blanca forest sub-sector, which has steep slopes partially covered by the PEIN Mountains of Begur, XN 2000 and a ZEPA.
The possibility of urbanising these areas in a new POUM goes against the Resolution 332/XI of the Parliament of Catalonia, on Pals Beach 250-00424/11. This resolution requires the Government to“To protect the Rodors – Roca Blanca sectors in Pals by expanding the PEIN area.”
This is the Expert opinion, Issued by the environmental scientist Josep Ramon Aragó. It forms part of appeal 217/2008, with a 2011 ruling by the Superior Court of Justice against the urbanisation of the beach's forest areas.
There is an extraordinary diversity of species. in the pine forests on dunes within the Rodors sub-area and the Interpals sector. They are protected by Decree 172/2022 on threatened native wild fauna and on measures for the protection and conservation of protected native wild fauna. They would constitute an environmental assault, leading to the disappearance of numerous protected or endangered species in these areas, if urban development at Pals Beach continues:
“Among the fauna, we note the common lizard. ─Lacerta lepida*─, and a few small mammals: hedgehogs ─Erinaceus sp.*─, hedgehogs ─Talpa europaea─, rabbits ─Oryctolagus cuniculus─, mice ─Apodemus sylvaticus─, mostoles ─Mustela nivalis─ and certain species of bats such as the lesser mouse-eared bat ─Myotis emarginata*─. The variety of birds that can be found there is particularly noteworthy. At various times of the year we can observe the following: woodpecker —Eagle-owl*—, Turkish turtle dove —Streptopelia decaocto—, Silver gull —Larus michahellis—, tudó —Columba palumbus—, Green woodpecker Green Woodpecker*—, woodpeckers ─Parus sp..*─ small workshops —Sylvia sp.—, clasp —Serinus serinus*—, Common thistle —Certhia brachydactyla*—, gull —Pica pica—, common tern —Common murre—, sparrow-like ─Carduelis carduelis*─, House Sparrow —House sparrow—, Black-headed Gull Audouin's gull*─, kite ─Falcon tinnunculus*─, Common Kestrel ─Accipiter nisus*─, and the following in winter: owl —Uncle Tito, alba*—, cargolet —Troglodytes troglodytes—, red breasted —Redstart*—, Blackbird —Turdus merula—, mosquito nets —Phylloscopus sp.*—, long-tailed tit —Long-tailed Tit*—, and in summer: swallowtail ─Merops apiaster*─, turtle dove —Wood Pigeon—, footpaths —Charadius sp..*—, cuckoo —Cuckoo—, black swift —Apus apus*—, Pallid swallow —Pale-faced hawk*—, archer —Apus melba*—, hoopoe —Upupa epops*—, and house martin —Swallow among others. The species marked with an asterisk (*) are listed as protected species of native wildlife in the Annex to Legislative Decree 2/2008.”
The following is in force Decree 172/2022 of threatened native wildlife and of protection and conservation measures for protected native wildlife. At that time the Real Decreto 172/2008, of the creation of Catalogue of threatened flora of Catalonia. Also its modification Resolution AAM/732/2015, for the cataloguing, decataloguing and reclassification of species in the Threatened Flora Catalogue of Catalonia.
The’Catalonia Water Agency (ACA) reported unfavourably in 2016 the «Special Planning Scheme for the Water Cycle in the Pals Beach Area”. It determined that if the Pals Beach sectors are developed, the entire water resources of the Mancomunitat will be exhausted. This will worsen water quality. Furthermore, the report warns that the sewage treatment plant, the sewers and the pumping stations do not have the capacity to treat the wastewater from the new sectors:
«The capacity of the Pals sewage treatment plant is insufficient for the new sectors at Rodors, the Rodors area and Interpals; this special plan offers no solution to this serious problem, nor to the seasonality of discharges, nor does it provide for the expansion of the treatment plant, nor for the impact of the costs of such an expansion on the new urbanisable sectors at the beach. There is no construction project within the special plan, so it is impossible to know what the budget will be, how it will affect the different sectors, or the environmental consequences of the works.«
«The new sectors in Rodors 1, 2 and 3 connect to existing mains and to pumping station EBAR No. 4, which is currently overloaded. Water resources are insufficient: the drinking water supply calculation is incorrect, the infrastructure is inadequate and unviable, leaving the other municipalities of the Mancomunitat—Palafrugell, Torrent, Regencós and Begur—with no possibility of growth. The impermeable and urbanised surface area is increasing without providing rainwater drainage within each sector.«
UUNP 2 Fountains Camp
The 1986 General Plan provides for 100 new homes in this area. It currently corresponds to the grounds of Mas Corredor de Camargues, which is already documented in the 14th century but dates from much earlier. Both the farmhouse and its surroundings must be preserved, as determined by the Department of Culture for their patrimonial, architectural and historical value, as shown by various studies. The undeveloped surroundings must be preserved. The planning already provides for other urbanisable areas closer to the urban core. For example, the UUNP of Mas Bergés includes 46 new homes and undeveloped plots within the urban core.
Industrial Area of the Camp de Roures site
This site occupies a large area of land in an area with existing industrial use; it is currently derelict.
It also includes another partially floodable agricultural area, which should retain its agricultural use.
The new POUM intended to regulate the urban development of Pals Beach.
The Judgment of the High Court of Justice of Catalonia (TSJC), The ruling of 22 February 2011 in administrative appeal no. 217/2008 obliges the Town Council not to process any development or project at Pals Beach until a new POUM has been approved..
The Resolution 332/XI of the Parliament of Catalonia, on Pals Beach 250-00424/11 urges the Government to “To initiate the necessary procedures and mechanisms to protect the Rodors – Roca Blanca areas in Pals, by expanding the PEIN zone.”.
The Resolution of case file 7667/2016 relating to the General Plan, from the Ombudsman of February 2017, Demand its declassification.
A report from the Montgrí Natural Park, Medes Islands and Lower Ter of 2020, requests protection for priority Community interest habitats of dunes with pine woodland. According to the Park, it is necessary that that the ecological characteristics for which it has been included in the habitat are maintained and its transformation prevented..
For all these reasons, the General Plan is out of date and devastating, and does not comply with higher-level sectoral regulations.
The Partial Territorial Plan for the Girona Region, the Coastal System Master Plan, the declaration of the Natural Park, the Plan for Areas of Natural Interest and the Master Plan for Unsustainable Lands on the Girona Coast are regulations adopted after 1986 to be incorporated into the new POUM.
This obliges the Town Council to reclassify the developments in dune and floodplain forest environments on the beach.
Article creation date: 2/2/2021.
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