Issue link: https://maltatoday.uberflip.com/i/519957
maltatoday, SUNDAY, 31 MAY 2015 15 they were thinking... for the most part they were just listening. I ex- pect they will go back to their par- liamentary groups and take posi- tions, and so on. Now we will see where the discussion will lead to. But there were a number of ques- tions raised at that meeting, and we're expecting to have answers to these questions. Not just as DLH, but I think the public de- serves to have these answers. This is a national strategic plan for the environment, and DLH is not the only organisation – far from it – that has raised similar concerns." Meanwhile, all this must be viewed in the context of a number of other decisions that seem to arise directly out of a weakening of the country's planning and en- forcement sector. The choice of ODZ land at Zonqor is the most obvious example. But there was also a recent reform of MEPA (which is in the process of having its 'environment' sector trans- ferred elsewhere) to relax restric- tions on development in the name of 'cutting back red tape'. The government is also embarked on a policy of land reclamation, and the latest surprise announcement concerns a Gozo cruise liner ter- minal at Simar quarry. Is it possible, then, that the gov- ernment might have had a strate- gic objective of its own in mak- ing this document unworkable in practice? "Let me put it this way. This document definitely will not pro- vide enough safeguards to prevent more expansion into rural areas, for example. And even if it did… it's already being ignored. If these [guidelines] are the real intentions of the government, they don't need to wait for parliamentary approval within the next month to start working along these lines. If these are the government's real intentions. But I can assure you they are not, and I can give two examples…" She rifles through the SPED document. "This is a quote from the social policy objectives, which is relevant to the Zonqor point issue: 'To guide the location of the bulk of new jobs and homes within the urban area'. But as we can see the 'bulk of new jobs', at this point – how many jobs are they projecting? 400? – are for a rural area, not an urban area. So if this is the strategic objective for the country, it's being ignored. No doubt about that. So the argu- ment, which I heard at the parlia- mentary committee, that this is 'not yet the approved document'… for me, it doesn't make any sense. If you've already agreed with the principles… isn't that what mat- ters? If this is what you are pro- posing Parliament to approve, you don't have to wait for approval to start implementing it. So this is one area where you can see clearly that the direction is not even be- ing considered." She turns a few pages to another highlighted section. "This is Rural Objective 3. And it says 'To guide development that is either justified to be located in the Rural Area according to govern- ment programmes'… 'or where alternatives are not possible', etc. This already allows for the pos- sibility to go outside the devel- opment zone. But then it says, if it does go into the rural area, it should not be in areas which are protected, or of high landscape sensitivity, and so on." Here she points out that a map is attached to this section, and that the area earmarked for the Amer- ican University (selected for that purpose by the CEO of MEPA) is marked as an area of high land- scape value. "So they have proposed Zonqor point to parliament – and this is an area of high landscape protec- tion – and in the same document they are saying, to quote exactly: 'to guide development away from areas of high landscape sensitivi- ty'… how can you do the exact op- posite of what you yourself have proposed to Parliament? Without any sort of the recognition… first of all that it goes against this doc- ument anyway… but even of the amount of opposition there is to it. Yet the government continues to defend the project. When it is the government itself that pro- poses it shouldn't be done…" Worst of all, Caruana Dingli continues, the new policy docu- ment cannot be implemented for the simple reason that there is no official body entrusted with the task. "SPED doesn't contain any guidelines about who it will be im- plemented by. What we queried was basically twofold: one, how the document will be used and interpreted, and two, who will ac- tually be in charge of implement- ing it. On the one hand, this was conceived as a holistic document. It was conceived at a time when both 'environment' and 'develop- ment' were dealt with holistically under one ministry. As a national strategic document, it was previ- ously handled by the ministry it- self, not by any independent au- thority. The ministry was given technical advice, of course, but the strategy document had to be owned by the government in the broader sense… otherwise it couldn't be implemented." In the meantime, however, it has been moved under the auspices of MEPA. "Now: when this comes to be implemented as a national strategic document, who's going to own it? Will it be MEPA, which will no longer have an environ- mental arm… because that's go- ing to be split off into a different ministry? So is this strategic plan for environment and develop- ment going to be handled only by development?" At the meeting, Petra Caruana Dingli suggested that the docu- ment be handled by a strategic unit within the Office of the Prime Minister. "It was just a suggestion, there are many other ways it can be done. But when I asked the question – who will implement this document? – I got no answer. When you publish a document of this nature, I think you should know who is going to implement it. It should actually be in the document itself. Not only that, but also the criteria by which de- cisions are taken, the timeframes, the monitoring, the reviews…" Yet another problem concerns the future updating of SPED. "At the moment, the way it is, the document is supposed to be re- viewed in 2020, so it only has a five-year lifespan. You'd expect a longer-term vision than that from a national strategy document: most strategies are conceived for periods of 20 years alone. But it doesn't specify the milestones, either. "In a 20-year plan, the first mile- stone might be targeted for the first five years. There are no spe- cific targets to be met here, and we don't know what will happen beyond 2020. Will we re-write it? Update it? There is absolutely nothing specified, except that the first review is due in 2020. It doesn't say who will review it, or how. I think a document becomes a wish-list if you don't know who's going to own it, enforce it, or any- thing else. It's just a lot of nice statements – some of them not even that great – but nobody will know what to do with them after- wards…" There is one last level at which the new strategic plan has already backfired… the Structure Plan it was supposed to replace is no longer in force, and the local plans that will provide it (one hopes) with the enforcement infrastruc- ture it needs are not yet finalised. In the interim, there is nothing of any substance to actually support the new policy guidelines. "Let me give an example. The current local plans, which are still in force, indicate that when decid- ing to go beyond the development boundaries, the decision will rest on whether it conforms to Struc- ture Plan policies SET 11 and SET 12. This is what a planner, or the MEPA appeals board, will have to decide on. Now, if you put out this document, which doesn't have a replacement for the Structure Plan… and then let's say you ap- prove it in a month, while the new local plans will not be around for much longer… So between SPED being approved and the finalisa- tion of the local plans, when the old plans are still in force… how are you going to interpret that?" Again no answer was provided when this concern was raised be- fore the parliamentary commit- tee. "In the absence of an answer – and I would have expected them to have the answer at hand – we propose that either there should be some sort of transition clause: for instance, when SPED doesn't enable an interpretation, we fall back on the old structure plan. Alternatively, don't approve SPED for now. It should come into force at the same time as the local plans. Otherwise we will have a vacuum that will open up too many pos- sibilities for abuse." Interview PETRA CARUANA DINGLI, council member of Din l-Art Helwa, has described the government's Strategic Plan for the Environment and Development as 'not fit for purpose'. She goes over the plan's main pitfalls possibilities for abuse WISH-LIST A document becomes a wish-list if you don't know who's going to own it, enforce it, or anything else. It's just a lot of nice statements – some of them not even that great – but nobody will know what to do with them afterwards If you've already agreed with the principles… isn't that what matters? If this is what you are proposing Parliament to approve, you don't have to wait for approval to start implementing it PRINCIPLES