Astrid Vella
Plenty has been said about the fact that the site of the Ta’ Cenc expansion application is a Site of Ecological Importance, a special landscape area Natura 2000 site, and an area rich in archaeology. However, besides these very valid facts, this case should be highlighting the growing shortcomings of Malta’s planning regime which are not limited to Ta’ Cenc but threaten all Malta’s natural heritage.
In spite of decades of calls for holistic planning, we are still tackling applications piecemeal instead of first assessing the national or regional benefit of major projects. Would Gozitan tourism really gain from projects like Ta’ Cenc and Hondoq ir-Rummien? Gozo has so many under-utilised holiday farmhouses and rental villas, that it follows that the Gozitan economy would have more to gain from the creation of unspoilt heritage and nature parks to attract Maltese and foreign tourists who would then occupy the available bed stock.
Given that Gozo has already lost a significant amount of unbuilt land for the development of hotels, including the San Lawrenz, Andar, and Mgarr hotels, some of which were subsequently re-developed into residential projects, can the encroachment of further land for speculative projects be justified in any way?
The issue of public interest and justification is crucial to Malta’s planning regime. What is the point of land use planning if not to regulate development into a coherent plan that benefits the population as a whole, rather than the conflicting interests of individual developers?
This was reflected in our early planning regulations: “The purpose of the following policies is to ensure the main areas of environmental concern, justifying the application in economic and environmental terms, and providing for proper environmental protection and restoration.” Although justification is increasingly being introduced as a planning requirement across Europe and Canada, where land is not scarce, this provision has been quietly dropped from Malta’s latest planning legislation – the Strategic Plan for Environment and Planning (SPED).
The 2003 ‘Development Outside Built-Up Areas’ policy states: “The requirement for justification on planning grounds is to ensure that a development application is not permitted simply because of land ownership considerations or because it is convenient or less costly for the applicant to breach normal planning policies.” This spells out the scenario we are seeing time and again in recent planning applications such as that of Zonqor and Munxar (Malta). As was pointed out during the Sannat Ta’ Cenc consultation, the failure of the SPED to reflect sound planning principles of the past is already being felt in weaker planning regulation and more speculation.
The eNGOs also questioned the photomontages that were presented at the Sannat consultation. Flimkien għal Ambjent Aħjar (FAA) has, for a number of years, advocated that photomontages should be prepared in such a way that they show exactly what the proposed development will look like. Yet, we are still seeing photomontages which are of dubious quality and which portray a very different image to what the project will eventually look like – clearly a travesty of why photomontages are prepared in the first place. FAA has often pointed out that the use of photographs taken with a wide angle camera, or from locations which diminish the impact of the proposed development is simply not acceptable. Unfortunately, these techniques that diminish the visual impact of buildings in order to gain support for a particular development are still being used. FAA has repeatedly highlighted that although verifiable photomontages – ie photomontages that can be double-checked for accuracy – are now available in Malta, Mepa is still being presented with photomontages which cannot be checked for their precision and fidelity to the true dimensions and appearance of the project.
It is commendable that Mepa has prepared a best practice guide for photomontages, emphasising that they must clearly show “the scale and nature of the proposed intervention”. In addition this document emphasises a number of issues such as that “Viewpoints must be carefully selected with respect to their representativeness and their significance.” and that “Visual simulations need to be prepared and presented in a way to allow the verification of the images.” We are pleased to see that Mepa has acted to ensure that photomontages will be of a high standard although it remains to be seen whether the current situation will persist after the 1st March 2016 introduction of these guidelines.
However, the glaring question remains: why have these guidelines not been implemented immediately, at least for projects of national importance? Why were the viewpoints in the Ta’ Cenc new plans not revised in line with the new recommendations instead of the very distant views we were presented with? What action has been taken to ensure that the photomontages give correct information and enable the public to judge the project correctly? FAA would also have preferred to see night-time photomontages for this project. It is a fact that light pollution can transform an otherwise acceptable project into an unacceptable one.
In 2012, the document setting out the objectives of the SPED had stipulated: “Gozo will become an ecological island. It shall protect the Gozitan lifestyle, the island’s environment, resources, culture and identity, and ensure that these play a significant part in attracting more visitors to the island.” This is nowhere to be found in the 2014 document. Has this government favoured the developer emperors of Gozo over the public interest? Mepa still has the opportunity to show that this is not so.