Issue link: https://maltatoday.uberflip.com/i/1527863
ANALYSIS maltatoday | SUNDAY • 13 OCTOBER 2024 ERA's new approach under scrutiny lic can make representations dur- ing the normal planning process." When asked whether the 'zero option' and alternatives, includ- ing potential alternative sites and technologies, are considered and assessed when an EIA is not con- ducted, the ERA officials replied that these are still assessed during the screening of the project. "In cases where there is no need for an EIA, the screening process it- self takes this into consideration." For example, if the ERA con- cludes that a project as proposed is objectionable and such issues cannot be addressed effectively through an EIA, the authority, in this case, advocates the "do-noth- ing option". Moreover, the ERA can also sug- gest alternatives and guide appli- cants and developers toward them in the process. "For example, a developer can be guided into ex- cluding ODZ areas and limiting development to committed areas during the screening stage." In this way, the ERA insists that it is tackling these issues head-on at the earliest possible stage, "rath- er than pushing the developer into lengthy studies, possibly giving the impression that these problems can be solved simply because an EIA is presented." In fact, according to the ERA, the public policy benefit of its approach is to avoid situations where studies drag on for years, as happened in past projects like the proposed development in Ħon- doq ir-Rummien, Ta' Ċenc, and the Verdala golf course. The ERA officials contend that the "more streamlined procedure" discourages 'tokenism' as well as the "dilution of salient issues", and favours timely consideration wherever such issues are foreseea- ble, such that these "can be avoid- ed or resolved at the earliest possi- ble stage and preferably at project inception stage" rather than left up to the end of a lengthy process. Fewer Social Impact Assessments One casualty of the new system is Social Impact Assessments (SIA), which assess the impact on local communities and were pre- viously included in EIAs but are now requested on a case-by-case basis by the Planning Authority. The ERA officials acknowledged that SIAs are particularly relevant in the case of urban developments and that these used to be tackled in EIAs. But they also noted that there were no clear guidelines on how these were carried out and dif- ferent methodologies were used, while today there are interna- tionally recognised good practice guidelines that are being followed. But ideally, according to the ERA, SIAs "should not be rele- gated to a sub-section of an EIA but should be treated on an equal footing with EIAs." Another problem raised by crit- ics of the new system is the lack of consideration for cumulative im- pacts of different projects which are being carried out within the same geographical area, some- thing which in theory has to be assessed when an EIA is required. The ERA officials insisted that cumulative impacts regarding impacts like air quality are still as- sessed when targeted studies are requested instead of an EIA. "But irrespective of whether an EIA or targeted studies are re- quested this is not a straightfor- ward thing. This is because any assessment is based on the sit- uation in the current context of the surrounding area, and which could change from one day to the next due to factors beyond the ap- plicant's and the authority's effec- tive control". As regards visual impacts of pro- jects where an EIA is not required the ERA officials pointed out that even when a proposal does not require an EIA, photomontages or visual amenity studies, may be required separately. One aspect which must be as- sessed in EIAs is the impact a pro- ject has on climate change and as- sociated mitigation measures. But such impacts were not assessed in cases where an EIA was deemed unnecessary, as was the case with the Gozo airstrip. While recognising that this is an important issue which must be covered in EIA reports, ERA officials pointed out that the cli- mate change impact of individual projects is often negligible. "What is more important is to consider is the cumulative impacts related to climate change which are more difficult to assess". Critics' concerns MaltaToday also reached out to planners and experts familiar with the EIA procedures including au- thors of past studies included in EIAs. Some welcomed the introduc- tion of a robust screening process, especially in nipping problems in the bud, thus avoiding the need of pointless studies further down the line. They positively noted ERA's pre- sumption against projects locat- ed outside committed areas but expressed concern that some of these projects like an old people's home in the ODZ in a strategic open gap in Naxxar, are still ap- proved by the Planning Authority despite ERA's objections. But several experts expressed misgivings on the lack of public consultation and narrowed focus on certain issues, inherent in the ERA's approach to EIA. Critics of the new approach ar- gue that screening is narrowly fo- cused on a limited range of issues, typically related to traffic, air qual- ity, noise studies, visual amenity assessments, and, occasionally, waste management studies at the exclusion of other aspects such as ecology, cultural heritage and ar- chaeology, geology, hydrology, ag- riculture, biodiversity and climate change. For example, EIA studies have had an important role in identifying previously ignored and neglected buildings or archaeo- logical remains, which are worthy of inclusion in the list of scheduled buildings. They note a worrying trend in ERA's approach of not requesting an EIA for Category II projects lo- cated within Development Zones, thus ignoring the environmental and social impacts on urban areas and populations. Moreover, one major short- coming in cases where an EIA is not carried out is the absence of studies which assess the synergies between different impacts of a project. This is because the stud- ies being requested focus solely on one specific issue. Projects where an EIA was not required ERA also provided MaltaToday with a list of projects where an EIA was not required but where it requested targeted studies on impacts like noise, air quality, and impact on the seabed. These included the Gozo rural airfield, the proposed Ħal Far race track, a high-rise in Ta' Giorni, an office and retail development pro- posed instead of the Toyota site in Ħaż-Żebbuġ, the development of 116 units in Mellieħa, a proposed shooting range in Siggiewi, a pro- posed shopping mall along Triq tal-Barrani in Ħal-Għaxaq, the construction of a regional health centre in St Paul's Bay, and recent- ly the development of 155 new apartments at Fort Chambray in Gozo. Social Impact Assessments (SIA) are a casualty of the new system and were previously included in EIAs but are now requested on a case-by-case basis by the Planning Authority Since 2018, ERA requested specific studies on issues like noise, air quality, and impact on the seabed for 52 projects that did not require a full EIA, including major projects like the proposed Ħal Far motorsport complex