Planning is for people

Land use planning should, and can, be developed into an effective tool to combat the impacts of climate change. This can be done by effectively encouraging development which contributes to reducing climate change impacts.

Apparently, it is too much to expect from our authority responsible for land use planning.

The development of large commercial centres may make economic sense, but do they make environmental and social sense?

This is what sustainable development is all about: that economic development must continuously factor in environment impacts as well as social considerations. The term sustainable development is on everyone’s lips, but it is definitely and continuously ignored when push comes to shove. When decisions are taken, unfortunately it is the euros which take a priority over sustainability.

It is not just about the actual land to be developed, or the buildings to be redeveloped. Much more has to be taken into consideration in each and every decision taken.

Consider for example the Lidl network or another multiple supermarket competitor chain currently planning an alternative network in Malta. Their impacts are multiple. There is definitely an impact on the existing commercial community which can be gauged by a retail impact assessment. There are however also widespread social and environmental impacts which are generally minimised or ignored by all the decision takers.

The social impact definitely needs a meticulous assessment. The changing nature of our residential neighbourhoods through the squeezing out of the small outlets, both commercial and artisanal, and consequently forcing all residents to look far beyond the community and its neighbourhoods for their needs, at times even their basic daily needs, is a major impact. This has and is still transforming our localities and consequently our communities such that at times you need to travel from one locality to another to satisfy your basic needs. This is not a positive development, yet it has been continuously ignored.

A direct impact of all this is that the expense to satisfy our needs is now increased to include the environmental impact of travel with the consequential contribution to climate change. Expenses are not only those which are paid in euro. These specific expenses are a charge debited to our ecological account.

Sustainable land use planning can put an end to all this. Unfortunately, it is not, as climate change impact has not been embedded as an essential element to be addressed by local land use planning!

Current land use planning practice needs to be turned on its head in order to prioritise community needs and impacts on the ecology over the requirements of the economy.

This is what the 15-minute city concept is all about! In reality it is nothing new as it signifies having our basic necessities close by, as in times gone by, when our localities were smaller and alive with vibrant communities. Small is beautiful we were told some years back by Erst Schumacher. The full title of his opus is more revealing: “Small is Beautiful. Economics as if people mattered.” People should be the focus of all our activity. Unfortunately, this is not the case.

I still vividly remember the phrase “planning is for people” in one of the André Zammit’s first urban planning lectures I attended at university. It was a phrase lifted from the UK Skeffington report drawn up in 1969 and examining the participation of the public in land use planning!

Where are the people and their needs in our land use planning? Following the various land use planning cases as they develop, it is clear that as practised locally, land use planning is more a compendium of rights relative to property development than a process regulating the use of land for the ultimate benefit of the whole community. Planning is for people, not for profit!

Land use planning: as if people really mattered!

published in The Malta Independent on Sunday 8 May 2022

L-appell dwar il-permess tad-dB f’Pembroke


L-appell kontra l-permess tad-dB biex iħarbat is-sit tal-ITS ġie sottomess.
Ir-raġunijiet għall-appell, fil-qosor huma s-segwenti:

1) Il-kunflitt ta’ interess ta’ Matthew Pace, membru tal-Bord tal-Awtoritá tal-Ippjanar u fl-istess ħin b’interess f’aġenzija tal-propjetá,
2) Il-kunflitt ta’ interess tal-Membru Parlamentari Clayton Bartolo, membru tal-Bord tal-Awtoritá tal-Ippjanar,
3) In-nuqqas ta’ skrutinju tal-presentazzjoni sħiħa minn Jacqueline Gili li twasslet għal-laqgħa tal-Bord bil-jet,
4) Nuqqas ta’ konformitá tal-proposta ta’ żvilupp mal-Height Limitation Adjustment Policy for Hotels,
5) Nuqqas ta’ konformitá tal-proposta ta’ żvilupp mal-Planning Policy Guide on the use and applicability of the Floor Area Ratio (FAR), artiklu 5.9 dwar l-ispejjes konnessi mal-iżvilupp tal-infrastruttura,
6) Nuqqas ta’ konformitá tal-proposta ta’ żvilupp mal-Planning Policy Guide on the use and applicability of the Floor Area Ratio (FAR), u dan dwar diversi dettalji tal-policy kif imfissra dettaljatament fid-dokument tal-appell,
7) Nuqqas ta’ konformitá dwar policies li jikkonċernaw l-impatt viżiv,
8) Hemm appartamenti li huma inqas fid-daqs minn dak stabilit mill-policies tal-ippjanar,
9) is-Social Impact Assessment ma sarx sewwa,
10) L-iżvilupp propost ma jikkonformax ma policies, liġijiet u obbligi internazzjonali dwar il-ħarsien tal-wirt storiku,
11) L-iżvilupp propost jikser diversi policies u liġijiet dwar il-ħarsien tal-kosta,
12) L-iżvilupp propost ma jsegwix policies intenzjonati biex iħarsu l-ispazji miftuħa,
13) L-impatt tat-traffiku mhux ikkunsidrat b’mod adegwat; ma sarux studji neċessarji u kien hemm nuqqas ta’ konsultazzjoni bi ksur tal-Konvenzjoni ta’ Aarhus,
14) Ma ġietx osservata l-liġi tad-Dimanju Pubbliku u dan dwar il-ħarsien tal-kosta,
15) Nuqqas ta’ konsiderazzjoni u piz mogħti lil materji diversi relevanti dwar ambjent, estetika u sanitá,
16) Nuqqas ta’ development brief u Master Plan,
17) Nuqqas ta’ ħarsien ambjentali dwar protezzjoni ta’ bijodiversitá, flora u fawna fuq l-art u fil-baħar, siti Natura 2000 u Għarq Ħammiem
18) Nuqqas ta’ osservanza ta’ liġijiet diversi dwar tniġġiż u emmissjonijiet kif ukoll dwar skart riżultanti mill-proġett.

The financing of Fawlty Towers

Townsquare.Fawlty Tower

The saga of the Mrieħel and the Townsquare towers is now entering a new phase, with the planning appeal stopwatch due to start ticking shortly –  most probably towards the end of the month. It is known that, so far, Sliema Local Council and a number of environmental NGOs will be appealing against the 4 August decision of the Planning Authority to approve the “Fawlty Towers” at Mrieħel and Townsquare Sliema .

Financing of the projects is next. The banks cannot increase their already substantial exposure to loans that are dependent on building speculation. Consequently, the developers will inevitably have to seek the involvement of private citizens and, possibly, institutional investors. Most probably, the process for financing the projects has already commenced; it will involve the issuing of bonds to the public and will normally be sponsored by a bank and a stock-broking agency.

The bank or banks and stockbrokers sponsoring the bond issue will have to ensure that the bonds are subject to an “appropriateness and suitability testing” subject to such direction as the Malta Financial Services Authority  may consider necessary and suitable. Also, in the light of past local unpleasant experiences, the Authority will undoubtedly be guided by the need to ensure  that prospective investors fully understand the inherent risks of the proposed investments.  It will also ensure that detailed information is published in the form of a suitable prospectus in which the small print is both legible and understandable.

Those who finance the high-rise projects should shoulder responsibility for their impact together with the Planning Authority and the developers. They will potentially make it happen, so they should carry the can. It is important to get this message through: those who will invest in the Gasan and Tumas bonds intended to finance the “Fawlty  Towers”  should receive more than a monetary return on their investment. The moment they sign up they will also assume co-responsibility – with the developers, the Planning Authority, the bank or banks and the sponsoring stockbrokers – for this projected development .

Word is going around on the need to boycott the services and products placed on the market by the Gasan and Tumas Groups. Journalist Jürgen Balzan, writing in Malta Today described these services and products as being wide-ranging (hotels, car-dealerships, gaming, finance and property) which easily impact on the daily life of a substantial number of Maltese citizens. However, such a boycott’s only link with  the “Fawlty  Towers”  would be through the owners.  It would be preferable for a boycott to have a direct link with the offensive action.  In this context, the forthcoming bond issue to finance the “Fawlty  Towers”  presents itself as a suitable opportunity.

A boycott is a non-violent instrument of protest that is perfectly legitimate in a democratic society. The boycotting of the forthcoming bond issue would send a clear message that people will not be complicit in further ruining the  urban fabric of Sliema and ensure that development at Imrieħel is such that the historic landscape is fully respected.

A social impact assessment, if properly carried out, would have revealed the apprehensions of the residents in particular the residents on the Tignè peninsula. But, unfortunately, as stated by Sliema Green Local Councillor Michael Briguglio, the existing policy-making process tends to consider such studies as an irritant rather than as a tool for holistic management and community participation.

We have had some recent converts on the desirability of social impact assessments, such as Professor Alex Torpiano, Dean of the Faculty for the Built Environment at the University of Malta. Prof. Torpiano, in an opinion piece published by the Malta Independent this week, stressed that spatial planning in Malta needs a social-economic dimension. Unfortunately, I do not recollect the professor himself practising these beliefs as the leading architect in the MIDI and Cambridge projects on the Tignè peninsula,  a stone’s throw from Townsquare!

Investing in this bond issue is not another private decision: it will have an enormous impact on the community.

Responsibility for this ever-increasing environmental mess has to be shouldered by quite a few persons in Malta. Even the banks have a very basic responsibility – and not one to be shouldered just by the Directors: the shareholders should also take an interest before decisions are taken and not post-factum.

I understand that the Directors of APS Bank have already taken note of the recent  statements regarding the environment by  Archbishop Charles Scicluna. As such, it stands to reason that APS will (I hope) not be in any way associated with the financing process for the “Fawlty  Towers”.  However, there is no news as yet from the other banks, primarily from the major ones – ie Bank of Valletta and HSBC.

This is a defining moment in environmental action in Malta. It is time for those that matter to stand up to be counted – and the sooner the better.

published by the Malta Independent on Sunday – 21 August 2016

Land use planning : beyond rhetoric

Freeport 2015


There is a common thread running through a number of local land-use planning controversies: they are tending to either ignore or give secondary importance to environmental, social and/or cultural issues, focusing instead on economic considerations.

On this page I have discussed the impact of the Freeport Terminal on  Birżebbuġa a number of times. The basic problem with the Freeport is that its impact on the Birżebbuġa community were ignored for a very long time. In fact, an attempt to include a Social Impact Assessment as an integral part of the EIA which was carried out some years ago was given the cold shoulder by MEPA. The end result was that the decision-taking process was not adequately informed of the impact of the terminal extension, both those already apparent and those which were yet to come. In particular, no assessment was made of the disintegration of the sports infrastructure in the area that has  slowly been eaten up – primarily by the Freeport.

Most of this could have been avoided through an active engagement with the local community over the years at the various stages of the project’s planning and implementation. This is why plans for the Freeport’s expansion, as indicated by the Freeport Corporation’s CEO  earlier this week in an interview with The Business Observer, should be explained  immediately. Even at this early stage it must be ascertained that the situation for  Birżebbuġa residents will not deteriorate any further.

No one in his right mind would deny that, over the years, the Freeport has made a significant contribution to Malta’s economic growth. Few, however, realise that the price paid for this economic success has been the erosion of the quality of life of the Birżebbuġa community. This is certainly unacceptable but it will only get worse, once the gas storage tanker for the Delimara Power Station is parked within Marsaxlokk Bay in the coming months, very close to the Freeport terminal.

The same story is repeating itself in other areas. Consider, for example, the 38-floor tower proposed at Townsquare and the 40-floor tower proposed for the Fort Cambridge project, both on the Tignè Peninsula in Sliema. The Townsquare assessment process is reaching its conclusion, whilst the one in respect of Fort Cambridge is still in its initial stages. Yet both are linked to the same fundamental flaw: the lack of consideration of the cumulative impact of the development of the Tignè Peninsula – which includes the MIDI development as well as the individual small scale projects in the area.

The adoption of plans and policies which have made it possible for the authorities to consider the development of the Tignè Peninsula were not subject to a Strategic Impact Assessment and, as a result, the cumulative impact of implementing these plans and policies were not identified and assessed. The end result is that the proposed towers are justifiably considered as another disruptive and unwelcome intrusion by the Tignè and Qui-Si-Sana communities.

The developers and their advisors focus exclusively on the impacts which are generated by their proposals, with the authorities generally avoiding the consideration of the big picture at the earliest possible stage.

Preliminary indications from the proposed Gozo Tunnel and the Sadeen “educational” setup at Marsaskala/Cottonera are already pointing in the same direction. In both cases, the alternatives that were generally brushed aside are the very options that need to be examined in detail in order to ensure that the challenges that will be faced in 2016 and beyond have not been prejudiced by myopic considerations in 2015.

Planning failures have serious consequences on those of our local communities that have to bear the brunt of the decisions taken for a long period of time. These can be avoided if the authorities refocus their efforts and realise that the economy is a tool which has to be a servant, and certainly not a master.

published in The Malta Independent on Sunday – 20 December 2015

Better safe than sorry

Delimara floating gas stirage terminal

Its been twelve months since Alternattiva Demokratika – The Green Party pointed out that safety and risk assessment will be the sticking point for the liquid natural gas (LNG) driven power station at Delimara. We were then told  that Labour’s plan had already factored in all issues pertaining to the Seveso Directive.

Well, plans have been changed. What were originally plans to have land based LNG storage facilities have been changed to a floating gas storage facility. The issue of safety has however remained. It was unaddressed then and is still not addressed now.

Other countries have taken the matter quite seriously. In Livorno, for example,  as a result of proper risk assessment studies a floating gas storage facility of a size comparable to that being considered for Delimara was sited 22.5 kilometres from the coastline. In addition a security area of an 8 kilometre radius was established. This security area which is under strict control to ensure that no unauthorised access occurs serves the purpose of reducing and containing the damage caused by a possible incident.

published in The Times of Malta, Saturday February 22, 2014

No such security areas have been established in the Delimara proposal such that whilst the probability of an incident has been identified as 1 in 10,000 years its impacts on the residential community as well on economic facilities could be devastating if such an accident occurs.

A thorough reading of the risk assessment study carried out by Roberto Vaccari and forming part of the Environment Impact Assessment for the Delimara LNG driven power station clearly identifies serious risks. Whilst Vaccari defines his study as being of a preliminary nature his conclusions, however, are clear enough pointers that the apprehension of 91% of the local population documented in the Delimara project Social Impact Assessment is more than justified.

Roberto Vaccari, for example, concludes on the possibility of an incident as a result of which a cloud of gas accumulates in the area in front of the Freeport Terminal, the fairway,  precisely where ships manoeuvre prior to their berthing to unload their shipment of containers. Just this possibility, on its own, should have been sufficient to lead to the conclusion that the proposed solution for the generation of electricity through the use of gas stored on a ship is a serious threat to the secure operation of the Freeport Terminal.

Roberto Vaccari justifiably points out that Marsaxlokk Bay, very close to the residential communities of Birżebbuġa and Marsaxlokk,  already harbours most of the Maltese sites subject to Major Hazard Regulatory control under the provisions if the EU Seveso Directive. The Delimara Power Station itself, the Birżebbuġa fuel storage depot, Oil Tanking facilities, the Wied Dalam installation, the Mediterranean Offshore Bunkering and the San Lucian facilities as well as the recent addition of the Gasco facilities at Bengħajsa are too close for comfort. Roberto Vaccari points out to the domino effect potential which could be triggered on each of these sites by an LNG incident at Delimara.

The mooring of the floating gas storage unit along the Delimara coast also gives rise to a serious conflict with existing uses in Marsaxlokk Bay. It conflicts with the operational requirements of the Freeport Terminal situated at the entrance to the Bay. The conflicts are of a navigational nature as the area currently utilised by container vessels to manoeuvre until they berth, the fairway, overlaps with the navigational requirements of the floating gas storage unit in particular during refuelling. It is known that container vessels at the Freeport Terminal do require tugboat assistance particularly when strong North-Easterly winds are prevalent. The navigational requirements in such circumstances for an increased activity require much more space (and tugboats) than is available in Marsaxlokk Bay. As far as is known this has not yet been considered.

Both the authorities as well as the EIA have also been particularly silent on the impacts which the floating gas storage unit will have on the fishing community in Marsaxlokk. It is unofficially known that plans are in hand to severely curtail all maritime movements within Marsaxlokk Bay during refuelling of the floating gas storage unit. The refuelling process which may take up to 48 hours  ten times annually will be a severe handicap not just on the operations of the Freeport Terminal but it may also deal a fatal blow to the livelihood of the fishing community at Marsaxlokk.

All of the above should have led to the conclusion that the unloading and storage of LNG at Marsaxlokk Port is an unnecessary source of danger to both residents and the country’s economy.

Malta is still in time to seriously explore other options. Ignoring political pique the only practical solution is to utilise a gas pipeline which a PN led Government had unfortunately refused when offered by Italy in 1999.

What is sure is that safety is priceless. It is better to be safe than sorry.

Bomba tal-ħin f’Delimara

Il-proposta ta’ Power Station f’Delimara li taħdem bil-gass flok bil-Heavy Fuel Oil ser twassal għal titjib fil-kwalita’ tal-arja f’Marsaxlokk, Birżebbuga u l-inħawi tal-madwar. Imma huwa ukoll ċar li l-preokkupazzjoni tar-residenti kif espressa fl-istudju dwar l-impatti soċjali għadha m’hiex qed tiġi indirizzata b’mod adegwat. L-istudju dwar ir-riskji mill-gass maħzun fil-Bajja ta’ Marsaxlokk m’huwiex wieħed konvinċenti.

Huwa neċessarju, anzi huwa essenzjali, li l-ħażna tal-gass għall-użu tal-Power Station tinħareg il-barra mill-Bajja ta’ Marsaxlokk.

Alternattiva Demokratika hi konxja li s-soluzzjonijiet tekniċi neċessarji jirrikjedu kemm iż-żmien kif ukoll spejjeż addizzjonali sostanzjali. Huwa importanti għaldaqstant li titwarrab l-għaġġla żejda biex ikunu jistgħu jsiru dawk l-istudji addizzjonali li huma neċessarji biex ma jibqa’ l-ebda dubju li r-riskji kollha li għalihom il-komunitajiet ta’ Marsaxlokk u Birżebbuġa ġew esposti jkunu indirizzati b’mod sodisfaċenti.

Alternattiva Demokratika hi konsistenti. Dan il-kliem qalitu diversi drabi, anke waqt il-kampanja elettorali tal-elezzjoni ta’ Marzu 2013 wara li l-Partit Laburista ħareġ bil-proposti tiegħu li, dakinnhar, kienu nieqsa minn informazzjoni essenzjali.

Is-saħħa u is-sigurta tar-residenti ta’ Marsaxlokk u Birżebbuga għandhom jiġu qabel kull konsiderazzjoni oħra.

Il-kunsens nazzjonali dwar il-ħtieġa tal-użu tal-gass fil-ġenerazzjoni tal-elettriku għandu jitwettaq f’rispett sħiħ lejn ir-residenti. Jekk dan ma jsirx jista’ jwassal biex fil-Bajja ta’ Marsaxlokk tkun istallata bomba tal-ħin.

Il-gass għal Delimara: nħarsu s-saħħa u s-sigurta tar-residenti

Delimara.gas terminal

Il-ħidma biex il-ġenerazzjoni tal-elettriku ma tibqax bl-użu ta’ żejt li jħammeġ (Heavy Fuel Oil) iżda bil-gass, minn dejjem kienet appoġġjata minn-Alternattiva Demokratika.

Kwalita’ aħjar tal-arja u traħħis fil-kontijiet tad-dawl u l-ilma huma l-konsegwenzi diretti ta’ dan il-pass.

F’dawn il-ġranet għaddejja d-diskussjoni dwar l-istudju fuq l-impatt ambjentali ta’ dan il-proġett. Hemm qbil ġenerali fuq ħafna mill-kontenut ta’ dan l-istudju.

Mill-istudju dwar l-impatt soċjali tal-power station bil-gass iżda, toħroġ b’mod ċar il-preokkupazzjoni tar-residenti ta’ Marsaxlokk għall-ħażna tal-ġass fuq opra tal-baħar speċjalizzata (floating gas storage facility). Huwa stmat li 91% tar-residenti ta’ Marsaxlokk ma jaqblux li l-gass għall-użu tal-power station jinħażen ġol-Bajja ta’ Marsaxlokk.

L-istudju ippreżentat dwar ir-riskju li l-ħażna tal-gass fil-Bajja ta’ Marsaxlokk, biswit il-power station u faċċata r-raħal ta’ Marsaxlokk, ma jikkonvinċi lil ħadd. In-nies m’hiex konvinta illi r-riskju għal saħħithom, għal ħajjithom u għall-propjeta’ tagħhom hu wieħed minimu. Mhux konvinti li r-riskju hu wieħed minimu. Mhux konvinti li r-riskju hu aċċettabbli.

Kien għalhekk f’waqtu dak li qal il-koordinatur tal-EIA li ser isir studju iktar approfondit tar-riskji involuti. Huwa tajjeb li ser isir dan l-istudju addizzjonali imma hu meħtieġ ukoll illi ma jittieħdux deċiżjonijiet mgħaġġla  qabel ma jkun konkluż dan l-istudju.  Għax sakemm ma jkunx konkluż studju konvinċenti, l-anqas temporanjament m’hu aċċettabbli li l-ħażna tal-gass għall-użu tal-power station tkun ġol-Bajja ta’ M’Xlokk.

Waqt il-konsultazzjoni pubblika ta’ nhar it-Tnejn intqal illi l-Enemalta m’għandiex flus għal soluzzjonijiet oħra, li jiswew ferm iktar kif ukoll li jieħdu iktar żmien biex jitwettqu.

Il-ħarsien tas-saħħa u l-ħajja tar-residenti ta’ M’Xlokk u Birżebbuġa kif ukoll is-sigurta’ tagħhom u ta’ ħwejjiġhom huma importanti iktar minn kollox, inkluz mill-flus li jkun meħtieġ illi jintefqu għall-proġett. Nittama biss li qabel ma jittieħdu d-deċiżjonijiet ikollna f’idejna l-studju li jgħarbel sewwa r-riskji u dan biex ħadd ma jibqagħlu iktar dubji.

Alternattiva Demokratika ilha żmien tgħid li din hi d-diffikulta unika u reali tal-proġett tal-Power Station f’Delimara li jaħdem bil-gass. Is-saħħa u s-sigurta’ tar-residenti jiġu qabel kollox.

ippubblikata fuq iNews l-Erbgħa 29 ta’ Jannar 2014