Issue link: https://maltatoday.uberflip.com/i/519957
14 IT would be fair to say that the proposed Zonqor point develop- ment has galvanised a seemingly dormant environmentalist lobby into sudden action. But as any en- vironmentalist will tell you, large scale opposition to single projects is not the most reliable token of ecological sensitivity. To most green NGOs, these one- off controversies should ideally be seen against a wider palette of en- vironmental concerns. And Petra Caruana Dingli, a council member of Din l-Art Helwa, was recently heard arguing (at a parliamentary committee meeting last week) that it is actually the government's na- tional Strategic Plan for the Envi- ronment and Development as a whole that needs to be revisited… not just its plans for Zonqor point. At DLH's office in Valetta, I find the former MEPA Director for Environmental Protection poring over printouts of the document known by the acronym 'SPED' (to which one is tempted to respond: 'Andale, andale, arriba, arriba, ar- riba…!'). Before getting down to the nitty gritty, it might be worth establishing what this 'SPED' thing is, anyway, and why it is so impor- tant. "SPED is intended to be a replace- ment for the Structure Plan, which was drafted in 1990. The Structure Plan – a hefty document, with lots of detailed policies, and so on. But it needed replacement. There was the Act of 2010 which specified the way it would be replaced; I'm not saying that the original poli- cies should remain, or be replaced with anything very similar; but the intention was that there would be quite a substantial document at the end of the replacement proc- ess. A high level document with sufficient detail to also, at times, be the deciding factor in planning ap- plications, and so on…" The original Structure Plan, she adds, contained policy guidelines on Urban Conservation Areas, Ru- ral Areas, Outside Development Zone issues… all the things one expects to have clear guidelines on to work with. "In 2012, the government at the time had published the objectives for this new document for public consultation. It was almost exactly the same as the document we have today (SPED): there was a whole series of quite high-level strategic objectives which, once the public had been consulted, were sup- posed to be translated into more detailed policy." So if the new document is almost exactly the same as the old one, one assumes that the step from 'objec- tives' to 'detailed policy' didn't ac- tually take place…? "No, because what happened is that in 2014… OK, let's take a step back. So those objectives were is- sued for consultation in 2012, and there was quite a lot of feedback from the public at the time… but then, the process was not conclud- ed. There was an election, and so on. After that we didn't hear any- thing for a while; and in 2014 the government issued a document and said, 'This is it. This is the Strategic Plan'. Which we had been asking for all along, by the way: 'What happened to the reform of the Structure Plan?, etc.'" Along with other NGOs, DLH (including Petra Caruana Dingli) was not overly impressed by the resulting document. "What we found was almost iden- tical to the document of 2012… without that second stage con- cerning policy formulation. And when we queried this, we were told that the decision was to change the structure of the document. The objectives laid down here – she in- dicates her own copy of SPED on the table – would be considered the full strategic plan, and those policies would now be formulated within the new local plans, which are currently being drafted." The Local Plans, she explains, are likewise in the process of being up- dated. But they are still at drafting stage. "So those policies that were expected to be in SPED are not there…" But unless I am mistaken, En- vironment Minister Leo Brincat admitted at one of those meetings that SPED was not intended to contain all the final policies. It still needs to be supplemented by other legislation… Caruana Dingli counters that this only means the current document is unenforceable for the present. "It was intended to have another large section for policy, and also one for implementation. Now, all the policies and implementation strategies are missing, and we are told to await the new Local Plans. But not even the draft Local Plans have yet come out. They would still need three months' public consul- tation, the government would have to go back to Parliament… we still have some way to go. I'm assum- ing they couldn't possibly be ready before next year." So had the incoming government in 2013 continued the process as it stood then, we would presum- ably have the full final document today… "After the consultation period ended in February 2012, the pol- icy formulation stage had begun and was at a very advanced stage. However, for various reasons… you can't put out a strategic plan just before an election. The gov- ernment could not, at that point, publish a direction for the next 10 years. So it wasn't finalised. Then there was this gap until 2014, where nothing was heard. Then we found the same objectives as the original document for consultation…" OK, so far we've discussed how this strategic plan was concocted, but this doesn't tell us much about how it will actually work in prac- tice. What sort of plan was DLH expecting? And in what way, exact- ly, is the current document flawed (beyond its inception, which we've already discussed)? "There are two aspects to it, in a way. Let us accept that the gov- ernment's direction is to have this as its policy document. We criti- cised that they are doing it in this manner; however, now it's gone to Parliament for discussion, and the document is coming out like this. There are at least two prob- lems. One is that this document has absolutely no indication about how its guidelines are to be imple- mented. And two, a number of the objectives are very open-ended, and do not have enough environ- mental safeguards built within them. So there's a problem with the way they are written, and also with the way they are going to be enforced." She reiterates her view, expressed at the parliamentary committee meeting, that the entire document is 'not fit for purpose'. "However, if even we do accept that we now have this, and we need to strengthen it so that it does be- come fit for purpose, there are two areas we need to work on. To tack- le the implementation level, and have it specified here…" she taps on the document. "And two, is to strengthen the individual clauses to make them more watertight." What sort of reaction did her criticism elicit at the parliamen- tary meeting? "The reaction was mixed. There were a number of MPs around the table, and I can't say exactly how Interview By Raphael Vassallo maltatoday, SUNDAY, 31 MAY 2015 Too many possibilities