Saving the little that we have

Almost two years ago, Architect Edward Said submitted a request to the Planning Authority and the Superintendence of Cultural Heritage in order that they take steps to protect a Villa along the St Julian’s promenade. The Villa known as Palazzina Vincenti was designed and constructed for his own use by Architect Gustavo Romeo Vincenti. Architect Vincenti died in 1974.

As far as is known, neither the Planning Authority nor the Superintendence of Cultural Heritage have acted upon the submissions received requesting the protection of Palazzina Vincenti. At the time of writing the Superintendence has passed the buck to the Planning Authority! In the meantime, a development application has been submitted for the demolition of Palazzina Vincenti and its substitution with a 17-storey 136 room hotel, including three levels below street level providing garage space for 58 cars.

In a report drawn up by Architect Edward Said, Palazzina Vincenti is described as “a masterpiece of architecture defined by pure geometric volumes”.  It is considered as one of the earliest examples of the use of reinforced concrete in domestic architecture in Malta.  Quoting from a 2018 Masters of Architecture dissertation by David Ellul, Architect Said emphasises that by taking full advantage of the potential of reinforced concrete, Vincenti’s artistic expression was freed from the limitations of traditional materials. The result is this masterpiece which can be lost quite soon!

Even though to the untrained eye Palazzina Vincenti may seem to be an ugly building specimen, ill-fitting in its present-day concrete jungle surroundings, it is still a masterpiece worth preserving for posterity.

I fail to understand why two years after a request for protection has been submitted no action has yet been taken. As a result of such inaction, the message conveyed by the authorities is a very clear one: that the site occupied by Palazzina Vincenti is ripe for development. This is an inevitable conclusion conveyed by those in charge as a result of their failure to act.

At this point in time, as a minimum, it is expected that an emergency conservation order protecting Palazzina Vincenti is issued urgently. This would be a clear sign to those currently benefitting from a prolonged phase of “development greed” that a red line has been drawn around our heritage, thereby protecting it. It would also provide some breathing space which would be of considerable help in order that the Planning Authority may bring its house in order.

Some have the mistaken idea that all our heritage is necessarily old, very old, going back centuries. This is certainly not the case as this specific architectural masterpiece is less than 75 years old. Unfortunately, there have been other worthy examples of our architectural heritage which have been lost through carelessness, insensitivity and institutional ignorance.

I could remind readers of another outstanding example of modern architecture which has gone to the dogs, this time in Gozo, some 15 years ago. Parts of the Qala Primary School in Gozo were demolished to make way for an Institute of Tourism Studies campus in Gozo. The said school was designed and constructed under the supervision of Architect Joseph Huntingford who as the government architect in charge of schools was responsible for most new schools constructed in Gozo between 1950 and 1961.

Way back in 2006 the Chamber of Architects and Civil Engineers had described the Qala Primary School as one of the finest examples of modern architecture on the island. Even then the Planning Authority was advised to handle our heritage with care. But it was of no use. The advice was ignored as parts of the school were demolished to make way for the ITS campus.

There is still time to save Palazzina Vincenti from being sacrificed on the altar of “development greed”. We need to be more appreciative of our heritage. We have so little of it. I am not however so sure as to whether the Planning Authority is capable of taking decisive action. It has been desensitised for far too long.

published in The Malta Independent on Sunday: 12 December 2021

Reflections on an Environment Policy

The current debate on what should form part of a National Environment Policy is a healthy exercise. It is focusing not only on the different aspirations of each citizen but also on the role of each one of the towns and villages which together constitute this country.

The environmental issues we face are the result of the manner we organise our lives both individually and as a community. In fact it can be safely stated that the manner in which economic activity has been organised throughout time has created different environmental and social impacts.

The exercise at this point in time is hence the clear identification of these impacts and subsequently seeking the best manner in which they can be tackled. This is done on two fronts: firstly through the formulation of an environment policy and secondly by integrating this environment policy with economic and social policy within the National Strategy for Sustainable Development (NSSD).

The NSSD has already been formulated and approved by Cabinet almost three years ago after a long process of consultation. It established targets and objectives which have unfortunately been ignored by the same Government which has approved them. This necessarily leads to the conclusion that these exercises can be a waste of time as their only purpose seems to be an exercise to prove that the new hands on deck can do things in a better way than those they have replaced. 

The National Environment Policy Issues Paper identifies a number of areas which are to be tackled but excludes a number of important ones. What is in my view objectionable and bordering on the insulting is the ignoring by the Issues Paper of the NSSD. It also ignores matters which have been tackled by the NSSD as well as the specific targets identified. This the NSSD did after extensive consultation with civil society, which the Issues Paper promises to go through again.

 

Eco-taxation

One such case refers to the use of economic instruments to attain environmental objectives. The Issues Paper queries whether and to what extent there is agreement  with the use of such instruments to further environmental objectives. Simultaneously with the publication of the Issues Paper, Finance Minister Tonio Fenech through the pre-budget document was lauding the idea of introducing a carbon tax and the possible utilisation of the proceeds to affect a tax shift. This is in the spirit of the former EU Commission President  (French Socialist) Jacques Delors’ 1993 EU White Paper entitled “On growth, competitiveness and employment. The challenges and ways forward into the 21^st century”.

So whilst the Environment Ministry is requesting our opinion on the use of eco-taxation (and other instruments) it seems that the Finance Ministry is dead-set to proceed.  Do these two Ministries form part of the same government? 

Both the Environment Ministry and the Finance Ministry would do well to go back in time to the debate on the introduction of the eco-contribution (2003-05) where they could identify a number of issues raised by civil society.

Should fiscal objectives be the purpose of environmental taxation or would it rather be environmental improvement? All over the globe governments declare that their aim in applying eco-taxation is environmental improvement. Yet they resist transferring political responsibility for environmental taxation from the Finance Ministry to the Environment Ministry. Such a move would lend credence to statements on the environmental objectives of eco-taxation and would ensure that the design of specific measures is more in line with encouraging changes in behaviour. Retaining political responsibility for environmental taxation at the Finance Ministry on the other hand signifies that the objective is to tax behaviour but not  to change it. This reluctance is generally reflected in the manner  in which eco-taxes are designed. Fiscal policy makers pay attention to the fact that changing behaviour would mean drying up a source of revenue. Hence eco-taxes designed for fiscal objectives are intended not to affect the elasticity of demand. This is done by selecting items in respect of which there are no alternatives and thus irrespective of tax added to the price there is no alternative to purchasing the product or service. The eco-contribution exercise clearly illustrates this argument.

 

Environmental nuisance 

The Issues Paper has failed to project an understanding that environmental issues can be most effectively tackled at a micro-level. In fact the Issues Paper adopts an exclusively macro approach and does not give any weight to the real life issues. Issues of environmental nuisance are the ones which the man in the street feels strongly about. These include primarily noise, air quality and odour nuisance caused by neighbours in residential areas. They could range from an air conditioner fixed below your bedroom window to a neighbour’s fireplace chimney spewing smoke right into your living room or a bakery belching black smoke onto your washing line. Or the newly opened restaurant or snack bar in a transformed ground floor flat whose operator wouldn’t care less about where the odours from his kitchen end up.    

Information

Access to environmental information is an important aspect of environment policy. Yet the drafters of the Issues Paper ignored it. The environmental information aspects of the Åarhus Convention have been incorporated into Maltese legislation as a direct result of Malta’s EU accession. This legislation provides a mechanism through which the citizen requests the release of information which up till then would be withheld by the authorities. This is a very primitive form of governance. The state should release information without having its hand forced to do it. This is the minimum required in an age of transparency and accountability. 

Policy proposals and other initiatives must be buttressed by studies which not only justify the proposal or initiative but which also identify the resulting impacts and the manner in which these can be addressed. Studies must be published at an early stage and not in the final stages of a discussion. Otherwise the public debate cannot be fruitful.

Transparency and accountability

Transparency and accountability are not only duties of the state. They are also a responsibility of private enterprise.  Corporate Social Responsibility (CSR) reporting is one way in which private enterprise informs the public on its activities. It is a function as important as financial reporting. Financial reporting having been accepted by society for quite a long time as a reporting requirement.

In Malta currently two companies publish a CSR report. Vodafone (Malta) and Bank of Valletta (BOV) have already published two editions of their CSR report. There has been considerable improvement in the information made available by Vodafone (Malta) in its second report, but BOV’s reporting  can be substantially improved.

The environment policy should identify the type of organisations that should have the duty to report publicly and on a regular basis on their environmental and other impacts. By organisations I understand not just industry and business but also public corporations, government departments and local authorities. A reasonable first step would be for companies quoted on the stock exchange to take the lead followed by public bodies such as Enemalta, Water Services Corporation, Heritage Malta and Air Malta.

CSR reporting should be guided by international standards such as the Global Reporting Initiative G3 guidelines and should be subject to auditing in order to verify that the statements made reflect what the organisation is really up to. 

Alternattiva Demokratika, AD, the Green Party in Malta has earlier this month published a document in reply to the National Environment Policy Issues Paper which lists and discusses the areas missed out by the said Issues Paper.  In addition to focusing on the urgent need to implement the NSSD, environment information, environmental nuisance and environment information it also points out the need to tackle the uptake of environmental management systems such as ISO 14001 and the Eco-Management and Audit Scheme (EMAS) Regulations of the European Union, light pollution, contaminated land, environmental and sustainability planning at a locality level better known as Local Agenda 21,  the role of civil society and environmental NGOs in environment policy and environment  research.  

We hope that when the environment policy is drafted it will include the widest possible list of issues and will tackle them in an holistic manner keeping in mind the parameters established in the National Sustainable Development Strategy.                 

Alternattiva Demokratika considers that environment policy is one of several instruments through which improvement in the quality of life can be attained. Protecting the environment signifies that we better our quality of life. It also signifies that each one of us acts in a responsible manner. However primarily it must be government which leading the way should act in an appropriate manner in order that it leads by example.

 published in

The Independent on Sunday, October 17, 2010, Environment Supplement