Fast food, slow death

Planning application with reference number PA 11067/17 for the development of a new McDonalds outlet on the outskirts of Żabbar is one of the latest attempts to nibble at our ODZ land. As readers are aware, the letters “ODZ” stand for Outside the Development Zone, meaning that the land in question should ideally not be developed at all.

However, the site selected for the possible development of the McDonalds fast food chain outlet lies in an area that has been slowly developed over the years. When the Local Plans were finalised 12 years ago, the site at Salvu Pulis Street in Żabbar and the surrounding development were defined as an ODZ (rural) settlement: meaning that it was an existing residential development outside the development zone that was to be contained and not allowed to spread any further.

Beyond the technical jargon, ODZ land should remain outside the development zone. The Local Plans have been supplemented by a myriad of additional policies and guidelines which unfortunately, but clearly intentionally, create so many policy contrasts and conflicts that it would not be amiss to conclude that practically anything can be justified on the basis of existing policy.

Having a McDonalds outlet in the chosen site at Żabbar is not compatible with the residential nature of the area, but I would not be surprised at all if another planning somersault of Olympic proportions leads to the approval of this application. The problem with most of the decision-takers at the Planning Authority is that they have little, if any, planning or environmental sense. This insensitivity is contributing to the slow and painful death of our countryside as well as that of our small settlements.

Just go slowly through the list of cases which have made it to the front pages of our newspapers and you will get a good idea of what has slowly but surely led to the current state of affairs. The basic problem is the men and women selected to be the decision-makers. The present ones are not much different from the previous ones: (although with some exceptions) generally they are useless. Some of them occasionally try to be reasonable.

Very rarely, a reasonable decision threatens the current order of things and looks likely to slip out: as the recent case on the Magħtab fuel station. The decision-taking rules are designed to trigger an automatic self-defence mechanism against those who dare overstep their brief: the definite decision is postponed to the next sitting. It is then possible to call in the reserves to vote and the habitual absentees turn up, thereby ensuring a full house at the next Board meeting. There is also sufficient time to convince those who may have “misunderstood” matters and dared speak their mind. It is then possible to ensure that the majority falls in line.

This has created an institutional double hurdle against the environment and its protection. It is specifically designed to be so by the author of the 2016 Development Planning Act, clearly intended to introduce an institutional check on those who dare sing from a different hymn sheet from the one available. It is the slow death of our countryside and our environmental heritage – not just at Ħaż-Żabbar, but all over the islands.

Some of those who grumble and fill the comments sections of our newspapers with their views need to consider whether they have contributed to all this by repeatedly electing those who have designed this mess.

Published on The Malta Independent on Sunday – 25 February 2018


Making hay …….. in St George’s Bay

The 23-storey Pender Gardens high-rise is nearly completed, after nearly 10 years of continuous construction activity. The application for the 31-storey Mercury House was approved last month and next Thursday, the Planning Authority Board will consider planning application PA2478/16 submitted by Garnet Investments Limited in respect of a substantial stretch of land along St George’s Bay on the outskirts of Paceville St Julian’s.

The applicant has requested the following: “Demolition of all existing buildings forming part of St. George’s Bay Hotel and ancillary facilities, Dolphin House, Moynihan House and Cresta Quay. Construction of Parking facilities, Hotels and ancillary facilities, Commercial Area, Multi Ownership holiday accommodation, Bungalows, Language school with accommodation. Restoration of the Villa Rosa and upgrading of the facilities including parking facility, kitchen and toilets all below existing site levels within the Villa Rosa Area to address catering facilities/wedding hall.”

The project includes mixed-uses covering a total site area of 48,723 square metres, a building footprint of 18,345 square metres and a total gross floor area of 82,917 square meters.

It is a small part of the area that was tentatively tackled by a draft Masterplan for Paceville which, after being rejected by public opinion was sent back to the drawing board. I consider it highly unethical for the Planning Authority to proceed with considering this application after the clear and resounding verdict of public opinion. As a minimum, the consideration of this application should have been postponed until a new, reasonable and acceptable Masterplan has received the go-ahead. A minimum effort at achieving consensus as to what development is acceptable is essential.

The Planning Authority is unfortunately insensitive to public opinion. It is amply clear that it, and those who appoint most of its Board members, are on the same wavelength as the development lobby, which is hell-bent on making hay while the sun shines. At this point in time, it is the turn of the St George’s Bay area.

The project is obviously recommended for approval in the 43-page report from the Planning Directorate.

The basic point of contention with such large-scale projects is that they are considered in isolation. Most of them would never get off the drawing board (real or virtual) if the consolidated impact of all neighbouring projects (existing or in the pipeline) are taken into account. Earlier this week, I had the opportunity to address similar concerns to the EIA public consultation on the db Group ITS site project.

Five large-scale projects are earmarked for St George’s Bay. Each will generate considerable havoc from excavation throughout construction and right through operation in the whole St George’s Bay area. Cumulatively it will be hell. Who cares?

Way back in 2006, when the Strategic Environmental Assessment Directive of the EU was about to be implemented in Malta, the Lawrence Gonzi – George Pullicino tandem rushed through the approval of the Local Plans in such a manner as to ensure that the accumulated environmental impact resulting from their implementation was not scrutinised and acted upon. The present state of affairs is the direct result of that irresponsible Gonzi-Pullicino action 12 years ago.

The Environment and Resources Authority (ERA) occasionally tries to patch things up. For example, within the framework of the ITS EIA exercise ERA suggested that the traffic assessment of the ITS and the Villa Rosa projects be consolidated. This has, however, been avoided: a case of too little, too late.

So where do we go from here?

The development lobby is maximising its efforts to make hay while the sun shines. In reality, a consolidated mess is taking shape with massively built-up areas in a relatively restricted space punctured by high rises mimicking phallic symbols of all shapes and sizes spread all over the place. Pender Place has 23 floors. Mercury House will have 31. The ITS phallus will have a 37-floor residential tower. The Villa Rosa/Cresta Quay project will have more modest heights.

Next Thursday, the Planning Authority has the opportunity to scrutinise the proposal for this Villa Rosa-Cresta Quay project. We will see once more the extent to which the concrete lobby still holds the Authority by its balls – obviously where this is applicable.


published in The Malta Independent on Sunday – 18 February 2018

Is-sit tal-ITS f’Pembroke : l-art pubblika, profitti tal-privat

L-iżvilupp tas-sit preżentement okkupat mill-Istitut tal-Istudji Turistiċi f’Pembroke reġa’ fl-aħbarijiet. Is-settur pubbliku jipprovdi l-art filwaqt li l-Grupp dB jimpala l-euro, bil-miljuni.

Matul din il-ġimgħa l-media tkellmet dwar il-miljuni li qed jiġi miftieħem li jitħallsu għall-bejgħ eventwali ta’ sulari sħaħ fit-torrijiet tal-Grupp dB. Dawn m’humiex flejjes li ser jitħallsu għal xiri ta’ propjetà fuq il-pjanta, għax s’issa la hemm permessi u l-anqas għad m’hemm l-ebda pjanta ffinalizzata. L-awtoritajiet tal-ippjanar għadhom fl-istadji inizzjali fl-eżami tagħhom tal-proġett propost: l-Awtorità għall-Ambjent u r-Riżorsi (ERA) għadha kif bdiet il-proċess ta’ konsultazzjoni statutorja dwar l-Istudju tal-Impatt Ambjentali (EIA) li għandu għaddej sat-12 ta’ Frar. Minkejja li l-ERA għad tista’ tirrakkomanda tibdil, żgħir jew kbir, fil-proġett wara li tkun ikkunsidrat bir-reqqa l-EIA, qiesu li l-iżviluppaturi huma ċerti li mhu ser ikun hemm l-ebda konsiderazzjoni ta’ ippjanar jew ambjent li ser ixxekkel dak li bosta jqiesu li hu proġett żejjed u mhux meħtieġ.

Id-dokumenti ppreżentati għall-iskrutinju pubbliku huma sostanzjali u voluminużi. Imma possibilment fihom in-nieqes u għaldaqstant diġa ktibt lill-Awtorità tal-Ambjent u r-Riżorsi biex tirrimedja u tippubblika dak li ġie identifikat bħala nieqes s’issa.

Dokument ta’ interess li insibuh fuq is-sit elettroniku tal-ERA huwa l-Project Description Statement (PDS) li tħejja minn ditta (partnership) ta’ periti li ftit kienet magħrufa s’issa. Din id-ditta iġġib l-isem ta’ Landmark Architects u jirriżulta li titmexxa mill-ekx-Ministru tat-Trasport il-Perit Jesmond Mugliett.

Fil-paġna 5 ta’ dan id-dokument, il-Perit Mugliett jikteb hekk “Nhar it-2 ta’ Frar 2017, il-Gvern u s-soċjetà dB San Gorg Property Limited iffirmaw il-kuntratt għat-trasferiment tal-art li dwarha ħarġet sejħa pubblika għall-proposti. Kemm il-Gvern ta’ Malta kif ukoll is-soċjetà dB San Gorg Property Limited jaqblu li l-evalwazzjoni tal-proġett ta’ żvilupp m’għandhiex iddum iktar mill-perjodu minimu stabilit mill-leġislazzjoni tal-ippjanar. (On the 2nd of February 2017, the Government of Malta and dB San Gorg Property Limited signed the contract for the granting of the RFP site. Both the Government of Malta and dB San Gorg Property Ltd. agree that evaluation of the project development should not extend beyond the minimum time frames established by Planning Law.) Fil-fehma tiegħi dan ifisser li l-Gvern diġa rabat idejn l-Awtorità tal-Ippjanar dwar kif din għandha topera f’dan il-kaz.

L-iżviluppatur donnu mhux inkwetat li l-Masterplan imfassal għal Paceville ġie skartat u beda l-proċess biex dan jitfassal mill-ġdid u dan wara l-konsultazzjoni pubblika mqanqla li kellna lejn tmiem l-2016. L-awtur tal-PDS fil-fatt jinfurmana li “L-Gvern ta’ Malta u s-soċjetà dB San Gorg Property Limited komplew bin-negozjati, u eventwalment qablu li ma kienx fl-interess tal-proġett, tal-industrija Maltija tat-Turiżmu u tal-ekonomija Maltija li joqgħdu jistennew li jkun konkluż dan il-Masterplan.” (The Government of Malta and dB San Gorg Property Limited continued with negotiations, eventually coming to an agreement that it was not in the interest of the project, the Maltese Tourism Industry and the Maltese economy to wait for the conclusion of this masterplan.)

Dan, fil-fehma tiegħi jimmina l-proċess ta’ konsultazzjoni pubblika. Għax liema huma r-regoli u policies tal-ippjanar li l-Awtorità tal-Ippjanar ser isegwi fuq is-sit illum okkupat mill-Istitut tal-Istudji Turistiċi? Il-proposta diġa tidher ċar li tmur kontra dak li jipprovdi l-pjan lokali tal-2006 li hu applikabbli. Allura fuq liema kriterji ser tkun ivvalutata l-proposta ta’ żvilupp?

Xi żmien ilu konna infurmati li l-ebda żvilupp fl-inħawi m’hu ser jitħalla jibda sakemm ikun konkluż Masterplan ġdid għal Paceville. Dakinnhar kien emfasizzat li l-proposti dwar is-sit tal-ITS f’Pembroke seta jkun evalwat biss wara l-approvazzjoni tal-Masterplan ġdid għal Paceville.

Din hi wegħda li kienet skartata kompletament!

Kien ukoll ġie mwiegħed li l-Masterplan il-ġdid ma kienx ser ikun imniġġes minn kunflitti ta’ interess. Tgħid din il-wegħda ser tkun injorata ukoll?


ippubblikat fuq Illum : Il-Ħadd : 21 ta’ Jannar 2018

Pembroke ITS site : public land – private profits


The redevelopment of the site currently occupied by the Institute for Tourism Studies (ITS) in Pembroke is again in the news: the public sector is providing the land while the dB Group will rake in the profits – amounting to millions of euro.

During the week various media outlets focused on the millions being forked out for the eventual purchase of entire floors in the dB Group towers. These are not the price for purchase of property still on plan, because no permits have yet been issued, nor have the plans as yet been finalised. The examination of the proposed development by the planning authorities is still in its initial stages: the Environment and Resources Authority (ERA) has just kicked off the Environment Impact Assessment (EIA) statutory consultation period, which is scheduled to run until 12 February. Notwithstanding the fact that the ERA may recommend changes to the planned project as a result of its consideration of the EIA, it seems that the developers are sure that there will be no planning or environmental issues which can put the breaks to what most people consider an ill-advised project.

The documents presented for public scrutiny are voluminous, but possibly incomplete, and I have already written to ERA to complete the missing information gaps, at least those identified to date.

A basic document of interest, available on the ERA website, is the Project Description Statement (PDS) – the work of an as yet unknown partnership of architects going by the name of “Landmark Architects”. It transpires that this partnership is headed by former Transport Minister Jesmond Mugliett, who writes on page 5 of the PDS : “On the 2nd of February 2017, the Government of Malta and dB San Gorg Property Limited signed the contract for the granting of the RFP site. Both the Government of Malta and dB San Gorg Property Ltd. agree that evaluation of the project development should not extend beyond the minimum time frames established by Planning Law.” To my mind this signifies that the government has already tied the Planning Authority’s hands as to how it should operate in this case.

The developer is not (apparently) worried that the Paceville Master Plan was sent back to the drawing board after the agitated public consultation late in 2016. The author of the PDS, in fact, informs us that “The Government of Malta and dB San Gorg Property Limited continued with negotiations, eventually coming to an agreement that it was not in the interest of the project, the Maltese Tourism Industry and the Maltese economy to wait for the conclusion of this masterplan.”

Does this not undermine the whole consultation process? What planning rules and/or policies will the Planning Authority follow at the former ITS site? On what criteria will the development proposal be evaluated – it already clearly goes beyond what is permitted in the applicable 2006 local plan.

Some time ago, we were informed that no new developments in the area would be given the go-ahead until such time as a new draft Paceville Master Plan was launched. It was then emphasised that the proposals for the Pembroke ITS site can only be properly assessed when the Paceville Master Plan is in place.

This pledge has been blatantly ignored by the development proposal.

It was also pledged that the new proposed Master Plan will not be tainted by conflicts of interest as was the original one. Will this pledge also be ignored?

published in The Malta Independent on Sunday : 21 January 2018

Zero waste : a 2050 target

Malta’s Waste Management Strategy for 2014-20 establishes the year 2050 as the one by which our society should achieve a zero waste target. In fact the first of four principles of Malta’s national waste policy is specifically: “to reduce waste and to prevent waste occurring, with a view to achieving a zero-waste society by 2050” (page 14 of Malta’s strategy).

It is pertinent to point out that the Zero Waste International Alliance has defined zero waste as follows: “Zero Waste is a goal that is both pragmatic and visionary, to guide people to emulate sustainable natural cycles, where all discarded materials are resources for others to use. Zero Waste means designing and managing products and processes to reduce the volume and toxicity of waste and materials, conserve and recover all resources and not burn or bury them. Implementing Zero Waste will eliminate all discharges to land, water, or air that may be a threat to planetary, human, animal or plant health.”

A Zero waste philosophy is thus a strategy and a set of practical tools seeking to eliminate waste and not just to manage it. The point at issue is how to go about reducing and eventually eliminating the waste that we generate.

This is basically a cultural change, waking up from our slumbers and realising that we live in a world where resources are finite. It is about time that we address our ecological deficit: from which there is no bale-out option.

There is one basic first step in the road towards zero waste which should be carefully planned and managed and this is a meticulous recycling strategy. Zero waste municipalities in Europe are continuously indicating that an 80 to 90 per cent recycling rate is achievable. The fact that Malta’s recycling rate is, at best, estimated at around 12 per cent, shows that there is room for substantial improvement: a seven-fold increase in Malta’s recycling rate.

How can this be brought about?

A first step would be to discard the apparently easy solutions which lead nowhere. Government’s proposed incineration policy, as a result of which 40 per cent of the waste generated will be burned, is a policy that seeks to manage waste and does away with the target of reducing and eventually eliminating its generation. The very fact that incineration is being proposed signifies a failure in the implementation of the waste management strategy just three years after its last revision, in 2014.

A second step would be to ensure consistency in waste policy. Malta’s Waste Management Strategy is aptly sub-titled ‘A Resource Management Approach’. By no stretch of the imagination can Malta’s proposed incineration policy be deemed to be consistent with such an approach. It is, in my view, just a panic reaction to the fact that there is no more space available for landfills.

The issue involved is very straightforward: can we deliver on our own target of a zero waste society by 2050? In planning to achieve this objective, each Minister has to be a Minister for the Environment, as each Ministry has a role in preventing or re-using the waste generated by the different economic activities. It is certainly a headache not only for Environment Minister José Herrera, but also for all the other Ministers, in particular Tourism Minister Konrad Mizzi and Minister for the Economy Chris Cardona.

In analysing waste management strategy targets achieved to date, it is not only Wasteserve that should be in the dock. The Minister responsible for the Economy has a duty to give account as to what measures and initiatives are in hand to develop the circular economy. It is the point where the paths of environment policy and economic policy cross, and rhetoric has to give precedence to results achieved or in the pipeline to be achieved.

Likewise, it is about time the Tourism Ministry seriously addresses the waste generated by hotels, bars and restaurants. This is an area that has been neglected for several years and is creating considerable difficulties in various parts of the Maltese islands, especially those along the coastline.

It is about time we realised that the implementation of an environment policy is not to be restricted to the corridors of the Environment Ministry: it is an activity that should be carried out by each and every Ministry.

published in the Malta Independent on Sunday: 26 November 2017

A financial surplus, yet an environmental deficit

As was expected, last Monday’s budget speech solemnly announced a budget surplus for the first time in many years. However, the environmental deficit was, as usual, hidden between the lines.

The budget is aptly titled Preparing for the Future (Inlestu għall-Futur). In dealing with environmental issues, the budget speech does not lay down clearly the path the government will be following. At times, it postpones matters – proposing studies and consultations on subjects that have been in the public domain for ages.

On the subject of vacant properties, the government prefers the carrot to the stick. In order to get dilapidated and empty properties in village centres back on the rental market, it is offering a €25,000 grant to renovate such properties, but then rightly insists that, once renovated these should be made available for social housing for a minimum of 10 years. In previous budgets, various other fiscal incentives have been offered to encourage such properties being placed back on the market.

After offering so many carrots, it would also make sense to use the stick by way of taxing vacant properties in situations where the owner is continuously ignoring the signals sent regarding the social, economic and environmental impacts of empty properties.

The budget speech announced improvements to rental subsidies. However, it then opted to postpone the regulation of the rental market. It announced a White Paper on the subject which, when published, will propose ways of regulating the market without in any way regulating the subject of rents. In view of the currently abnormal situation of sky-high rents, this is sheer madness.

It is fine to ensure that the duties and responsibilities of landlords and tenants are clearly spelt out. Does anyone argue with that in 2017? It should have been done years ago. Instead of a White Paper a Legal Notice defining clear-cut duties and responsibilities would suffice: there is no need to wait.

It is, however, too much to bear when a “social democrat” Finance Minister declares  that he will not even consider rent control. There are ways and means of ensuring that the market acts fairly. Other countries have done it and are still doing it, as rental greed has no preferred nationality. Ignoring this possibility is not a good omen. The market should not be glorified by the Finance Minister; it should be tamed rather than further encouraged to keep running wild with the resulting social havoc it has created.

This brings us to transport and roads. The Finance Minister sends a clear message when he stated (on page 44 of the budget speech) that no one should be under the illusion that upgrading the road infrastructure will, on its own, resolve the traffic (congestion) problem. Edward Scicluna hints on the following page of his speech that he is not too happy with the current situation. He laments that the more developed countries encourage active mobility through walking, cycling and the use of motorbikes, as well as various means of public transport, simultaneously discouraging the use of the private car. However, he does not then proceed to the logical conclusion of his statement: scrapping large-scale road infrastructural projects such as the proposed Marsa flyover or the proposed tunnels below the Santa Luċija roundabout announced recently by Minister Ian Borg.

These projects, like the Kappara flyover currently in its final stages, will only serve to increase the capacity of our roads. And this means only one thing: more cars on our roads. It is certified madness.

While the Government’s policy of increasing the capacity of existing roads through the construction of flyovers and tunnels will address congestion in the short term, it will lead to increased traffic on our roads. This moves the problem to the future, when it will be worse and more difficult to tackle. The government is acting like an overweight individual who ‘solves’ the problem of his expanding wasteline by changing his wardrobe instead of going on a painful but necessary diet.

This cancels out the positive impact of other policies announced in the budget speech such as free public transport to young people aged between 16 and 20, free (collective) transport to all schools, incentives for car-pooling, grants encouraging the purchase of bicycles, pedelec bicycles and scooters, reduction in the VAT charged when hiring bicycles as well as the introduction of bicycle lanes, as well as encouraging the purchase of electric or hybrid vehicles.

All this contributes to the current environmental deficit. And I have not even mentioned issues of land use planning once.

Published in The Malta Independent on Sunday – 15 October 2017

Arvid Pardo : 50 years on

Going by the Prime Minister’s address to the EU Conference held in Malta this week on the protection of the oceans. it would be reasonable to assume that, as a maritime nation, Malta’s commitment is second to none.

Searching through the website of the Environment and Resources Authority (ERA) reveals a number of reports required by the EU Marine Strategy Framework Directive (MSFD) from EU member states. However, perusal of the relative EU website reveals that Malta’s reports were not presented within the timeframes established by the Directive.

Clearly, notwithstanding what the Prime Minister says, we still need to pull our socks up.

As an island state, it is essential that we lead rather than follow in maritime matters. There was a time when Malta was the leader, when Malta’s Ambassador to the United Nations, Arvid Pardo, presented the ground-breaking initiative to consider the seabed resources as the common heritage of mankind. That was 50 years ago, in November 1967, at a session of the United Nations General Assembly.

Arvid Pardo’s initiative on behalf of Malta was, for a considerable time, pushed to the sidelines by a Labour-led government, permitting other countries to take the lead instead. In fact, when push came to shove, Jamaica squeezed Malta out and was selected to host the International Seabed Authority in Kingston. Malta had, for some time, indicated that it was no longer interested in pursuing its own initiative.

Malta has a maritime vocation. As an island nation, it needs to consider maritime politics as both a duty as well as an opportunity. The implications of all this is explained in some detail in a marine economic and social analysis report commissioned by the ERA in terms of article 8 of the MSFD and available on its website.

Sub-titled “an initial assessment”, the 133 page report concludes that 15.4 per cent of the Maltese economy makes use of the marine environment either as a provider of resources, as an input in the product or service provided or as a sink function. This enormous importance of the marine environment to the Maltese economy is further increased when one bears in mind that in other European Union member states this same statistic varies between three per cent and five per cent.

The report further states that the 15.4 per cent contribution of the marine environment to the economy does not include the use of bathing areas as well as the use of the sea as the primary source of potable water in Malta.

Over the years, I do not recall other political parties giving any weight to the significance of the marine environment in their political discourse. It is about time that this changed, because it is imperative that we realise the central importance of the marine environment.

Malta should follow in Arvid Pardo’s footsteps and take the lead in maritime issues: there is so much to do. The fact that the Marine Framework Strategy Directive is still in its infancy offers a unique opportunity that was not sufficiently highlighted during the six month presidency of the EU held by Malta earlier this year.

In Arvid Pardo’s own words at the UN General Assembly on the 1st November 1967: we are naturally vitally interested in the sea which surrounds us and through which we live and breathe.

published in The Malta Independent on Sunday : 8 October 2017

Għall-Awtoritá tal-Ippjanar il-profitti tal-ispekulatur huma prijoritá

Id-deċiżjoni li ħa l-Bord tal-Awtoritá tal-Ippjanar nhar il-Ħamis b’għaxar voti kontra tlieta biex 4,748 metru kwadru ta’ art barra miż-żona tal-iżvilupp (ODZ) ikunu żviluppati f’Dar għall-Anzjani fin-Naxxar hi preċedent ikrah li l-Awtoritá għad jiddispjaċiha li ħaditu.

L-applikazzjoni bin-numru PA 3592/16 ġiet ippreżentata biex jitwaqqa’ bini li tela’ qabel l-1978 u floku tinbena faċilitá għall-kura tal-anzjani fuq art “ġa disturbata”.

L-ewwel punt ta’ interess hu dan il-bini ta’ qabel l-1978 li hemm fuq is-sit. Ir-rapport dwar l-applikazzjoni ta’ żvilupp jiddeskrivi din l-art bħala “razzett mitluq u fi stat ta’ abbandun”. Meta inbena, dan ir-razzett kien meħtieġ fl-interess ta’ l-agrikultura. Issa li dan ir-razzett hu abbandunat kien ikun iktar għaqli kieku l-art ġiet irrestawrata għall-istat oriġinali tagħha biex tieħu lura postha bħala parti mill-pajsaġġ rurali. Minflok qed tintuża bħala għodda biex twaqqa’ għar-redikolu l-politika dwar l-ippjanar tal-użu tal-art.

L-Awtoritá tal-Ippjanar skont dak li jipprovdi l-Pjan Strateġiku għall-Ambjent u l-Iżvilupp (SPED: Strategic Plan for Environment and Development) talbet lill-applikant biex jikkummissjona studju ħalli jiġi stabilit jekk fiż-żona ta’ żvilupp, fil-viċinanzi, kienx hemm art tajba għall-iżvilupp li setgħet tintuża għall-iskop mixtieq u ċioe biex tinbena dar għall-anzjani.

Dan ir-rapport (site selection report), datat Mejju 2016, fil-fatt identifika żewġ siti li t-tnejn kienu ikbar milli meħtieġ. Ir-rapport jgħid li s-siti identifikati kellhom “potenzjal kbir” bħala siti alternattivi għall-proġett taħt konsiderazzjoni. L-ewwel sit kellu qies ta’ 11,287 metru kwadru fil-waqt li t-tieni sit kellu qies ta’ 6,844 metru kwadru. It-tnejn kienu fin-Naxxar viċin tas-sit taħt konsiderazzjoni.

Wara, l-Awtoritá tal-Ippjanar talbet lill-applikant biex jipproduċi studju dwar l-impatti finanzjarji tal-proġett. Dan l-istudju kien lest fi ftit żmien tant li hu datat 30 ta’ Mejju 2016. Fi ftit kliem dan ir-rapport ta’ sitt paġni, miktub minn accountant, jikkonkludi li billi l-art tajba għall-iżvilupp tiswa’ ferm iktar minn art ODZ (li m’hiex normalment ikkunsidrata għall-iżvilupp) il-proġett seta jrendi biss jekk tkun użata art ODZ!

Fid-diskussjoni waqt is-seduta pubblika ta’ nhar il-Ħamis tal-Bord tal-Awtoritá tal-Ippjanar, iċ-Ċhairman Eżekuttiv tal-istess Awtoritá qal li l-istudju dwar l-impatt finanzjarju tal-proġett kien ivverifikat mill-konsulenti tal- Awtoritá li wara aċċettatu u talbet lill-applikant biex jibda jikkunsidra art fl-ODZ.

Din id-deċiżjoni tal- Awtoritá tal-Ippjanar taqleb ta’ taħt fuq il-politika dwar l-użu tal-art u prattikament tfisser li minn issa l-quddiem proġetti kbar barra miż-żona tal-iżvilupp mhu ser ikollhom l-ebda diffikulta biex ikunu approvati. M’hemmx ħtieġa li tkun professor biex tifhem li minn issa l-quddiem kull żvilupp ODZ jista’ jkun iġġustifikat mill- Awtoritá tal-Ippjanar a bażi tal-fatt li l-art ODZ tiswa’ ferm inqas mill-art tajba għall-iżvilupp.

Jekk inħarsu ftit sewwa lejn ir-rapport tal-accountant insiru nafu li l-art ODZ kellha l-prezz ta’ €1,200,000 fil-waqt li l-art l-oħra tal-qies meħtieġ għall-proġett kellha prezz ta’ madwar €5 miljuni u nofs f’kull każ. Differenza ta’ madwar 4 darbiet!

Bħala riżultat ta’ din id-deċiżjoni, fl-opinjoni tiegħi, l- Awtoritá tal-Ippjanar irmiet ix-xogħol utli li numru kbir ta’ professjonisti tal-ambjent u tal-ippjanar tal-użu tal-art għamlu tul dawn l-aħħar ħamsa u għoxrin sena. Hi deċiżjoni li tmur kontra l-emfasi kontinwa dwar il-ħtieġa li l-art limitata li għandu l-pajjiż tintuża b’mod sostenibbli. L- Awtoritá tal-Ippjanar għal darba oħra baxxiet rasha: il-kilba għall-profitti reġgħet rebħet fuq il-ħtieġa tal-ħarsien ambjentali. Il-bilanċ fil-kont tal-bank tal-ispekulatur hu iktar importanti għall- Awtoritá tal-Ippjanar mill-użu sostenibbli tal-art f’pajjiżna.

Meta ttieħed il-vot finali, tlieta biss kienu l-membri tal-Bord tal- Awtoritá tal-Ippjanar li ivvutaw kontra: is-Sindku tan-Naxxar Anne Marie Muscat Fenech Adami, iċ-Chairman tal- Awtoritá tal-Ambjent w ir-Riżorsi Victor Axiaq kif ukoll r-rapprezentanta tal-għaqdiet ambjentali – Annick Bonello It-tlieta li huma mmotivaw id-deċiżjoni tagħhom li jivvutaw kontra l-proposta ta’ żvilupp minħabba li mhux aċċettabbli li tkun użata art ODZ għal dan l-iskop.

Ippubblikat fuq Illum : Il-Ħadd 23 ta’ Lulju 2017

Planning Authority says: develop ODZ, it is cheaper!

The decision taken by the Board of the Planning Authority last Thursday, with ten votes in favour and three votes against the development of 4,748 square metres of land Outside the Development Zone (ODZ) for a home for the elderly in Naxxar, will come back to haunt it in the very near future.

Application number PA 3592/16  was submitted in order to demolish a pre-1978 existing building and construct a facility for the care of the elderly and nursing home on disturbed land.

The first point of interest is the existing pre-1978 building on site. The Development Permit Application report describes this as an unoccupied derelict farm. When it  was constructed, this building was necessary in the interests of agriculture. Now that it is in a derelict state, the land should have been returned to its former state, rehabilitated as part of the rural landscape. Instead it is being used as a tool through which to ridicule land use planning policy.

Applying the provisions of the Strategic Plan for Environment and Development (SPED) policy document, the Planning Authority requested the applicant to commission a site selection exercise in order to ascertain whether, within the development zone, there existed land in the vicinity that could be developed for the desired purpose – a home for the elderly. 

The site selection report, dated May 2016, identified two sites – both of which were larger than required.  Specifically, the report states that the identified sites offered very good potential as alternative sites for the project under consideration.  The first site had an area of 11,287 square metres, while the second had an area of 6,844 square metres. Both sites are in Naxxar, very close to the site that is the subject of the application.

The Planning Authority next proceeded to request the applicant to produce a financial feasibility study. This study was produced days after the site selection exercise was completed. In fact, it is dated 30 May 2016. Briefly, the six page study – drawn up by a certified public accountant – concludes that, due to the fact that land within the development scheme costs substantially more than ODZ land, the project would only be financially feasible if ODZ land were used.

During last Thursdays Planning Authority Board public hearing, the Authority’s Executive Chairman stated that the PA’s own consultants had check this feasibility study before accepting it and instructing the applicant to proceed with considering ODZ sites.

This PA decision turns land use planning policy on its head and practically gives the green light to large-scale ODZ development in the future. It does not require rocket science to arrive at a conclusion that this specific decision signifies that practically any ODZ development can be justified on the basis that ODZ land is cheaper than land in the development zone. Perusal of the feasibility study submitted by applicant to the Planning Authority indicates that the ODZ land to be developed for this project has been priced at 1,200,000. The alternative sites, of equal area to the ODZ site under consideration, were each priced at approximately 5,500,000 : a four-fold difference.

In my opinion, the result of this decision is that the Planning Authority has thrown into the dustbin the hard work of a large number of planning and environmental professionals over the last 25 years.   This decision contradicts the continuous policy emphasis on the need to use land in a sustainable manner. The Planning Authority has once more bowed its head when faced with gluttonous greed. Profit has once more carried the day, to the detriment of environmental protection. The speculators bottom line is more important to the Planning Authority than sustainable use of land resources.

When the final vote was taken, only three members of the Planning Authority Board voted against, namely the Mayor of Naxxar Anne Marie Muscat Fenech Adami, the Chairman of the Environment and Resources Authority Victor Axiaq and the environmental NGOs’ representative Annick Bonello. All three were motivated in their decision to vote against the proposal because they deemed it unacceptable to have the development in ODZ land.

published in The Malta Independent on Sunday – 23 July 2017

ODZ lessons : from  Żonqor to Għargħur


A planning application (PA3592/16)  to construct a home for the elderly in the area between Naxxar and Għargħur was due to be discussed by the Planning Authority Board on Thursday. Less than five hours before it was due to begin, however, the public hearing was postponed. There may be valid reasons for the postponement but, so far, such reasons – if they exist – are still unknown.

For the past few months, Alternattiva Demokratika, the Green Party in Malta, has been supporting the residents who are opposed to the development of this privately-owned  home in their neighbourhood since the planning application was first published.

There are various reasons which justify opposition to this proposed development. When faced with such a proposal, the first reactions understandably relate to the direct impact that it will have on the residential community – during both the construction phase and  the operational phase of the proposed facility. During the construction phase, this impact would include excavation noise and vibration, the nuisance caused by airborne dust during construction and the general inconvenience resulting from a large construction site very close to a residential community.

Once the home is in use, the traffic generated at all times of the day – as well as the occupying of residents’ parking spaces by visitors – will be one of the most pressing concerns to justify opposition to the proposal.

These are sensible reasons which justify opposition to the proposed development, even though some mitigation of these impacts is generally possible.

In my opinion, however, before even considering the proposal, it has to be emphasised that the construction of a home for the elderly outside the development zone (ODZ) between Naxxar and Għargħur is a good reason for objection in principle.

On the grounds of social policy, to continue encouraging the institutional care of the aged by way of residential homes does not hold water. It makes much more sense to help the older members of our society to remain in their homes as an integral part of the community, close to their roots, as long as this is possible. This should be the preferred option, rather than forcing them to abandon their roots and move away to the outskirts of our towns and villages.

The Social Policy Ministry harps on about the integration of the elderly in the community while the authority responsible for land use planning is facilitating their segregation. Obviously, somewhere there is a lack of understanding and coordination.

Locating homes for the elderly on the edges of our towns and villages is, in the long term, unsustainable. In addition to fostering segregation, instead of encouraging inclusion, it creates an environmental deficit by encouraging the displacement of a number of the residents of our town and village centres to what is now considered as ODZ land. As a result, this leads to an increase in the number of vacant residential properties while simultaneously adding to the built footprint of the Maltese islands – as if we do not have more than enough developed land!

The 2011 Census identified Għargħur as having a 28.5 per cent residential property vacancy rate. The rate for Naxxar was 24.5. These official statistics, which include both vacant properties and partially vacant properties, will undoubtedly get much worse.

This leads to another argument against the proposal to provide a home for the elderly in this particular area.  How can we justify taking up ODZ land for further development when even the site selection exercise, carried out as part of the application process, identified alternative sites within the development zone?

It seems that not enough lessons have been learnt as a result of the Żonqor debacle.  Is it not about time that the Planning Authority puts its house in order?

Policy coordination between the Ministries concerned with social policy, sustainable development, the environment and land use planning is obviously the missing link and should be addressed immediately.

published in the Malta Independent on Sunday – 25 June 2017