The Kamra tal-Periti (KTP) notes with satisfaction the commitment of Government to undertake the much desired reform at MEPA, and applauds Government’s decision to give this reform process its due importance.
The KTP believes that it is essential for the reform to be based on a clear vision, for the environmental development (urban and rural) of the Maltese islands, which vision cannot be separated from the country’s economic and socio-cultural aspirations and envisages that the reform process might require a long‐term strategy built upon shorter term goals and achievements.
Without a clear vision based on critical core values, any reform risks being a costly and laborious exercise which will not result in a better environment. All the more so given the adversarial and legalistic system within which MEPA operates, and the often conflicting concerns of the various parties it serves.
The KTP believes that these core values should be structured around the central tenet that development should aim to achieve qualitative public benefit and that this requirement needs to be balanced against individual demands.
These core values should include: heritage (built and environmental) protection, environmental sustainability, the avoidance of undue speculation, quality living conditions in urban centres, and development which is of the highest quality, yet specific to its context. Investment in culture will further assist in the enlightenment of society.
While MEPA has achieved improvements in the overall process of urban development, it is clear that the end result, i.e. the quality of the rural, and particularly the urban environment which we inhabit, still leaves much to be desired.
Quality is not a result of planning tools and policy alone, yet an assessment of the planning tools at MEPA’s disposal is necessary to ascertain their suitability for the achievement of a quality environment.
The KTP notes that design quality has as yet not been a factor currently taken into consideration in the planning process. Because they have not been considered from a holistic urban design viewpoint, design guidance and policy (e.g. Local Plans, vague interpretations of the Structure Plan Policies) have also had a negative effect on quality of design and on quality of life. Moreover, highly prescriptive guidance documents like Policy and Design Guidance 2007 shackle rather than promote creativity, innovation, and quality. There is therefore a need for mechanisms which encourage creativity and quality.
There is in our opinion the need to establish a mechanism whereby projects of a significant scale or importance are assessed from the point of view of their contribution to society and the built environment.
We believe that there is the need for a reform in procedures and resources in order to ensure that these are sufficient to develop a quality approach to development and to ensure that development applications are handled in a timely and cost‐effective manner.
It is generally noted that procedures are often inefficient and too bureaucratic on minor projects, yet insufficient to ensure quality on major projects. Moreover, consultation procedures need to happen in parallel rather than sequentially to avoid tortuous alteration procedures. Furthermore, procedures need to be put in place to reduce laborious review processes for minor applications so as to direct the resources to developments that require a greater input.
The DCC boards should not adopt ad hoc policies, but they should give their feedback to the Directorate where they feel that policy does not sufficiently provide for suitable development.
We feel that the measurement of MEPA’s success or failure should not be calculated on its pending caseload but on the quality of ensuing development. The assessment of work output within the Directorate needs to shift away from a quantitative assessment of number of files processed to a quality‐based system where quality and diligence are given due merit.
With respect to resources, the KTP notes that adequately skilled resources are highly lacking in all levels of the organisation and feels that there is a need for skilled and experienced planning officers who can judge applications on their merits (and not against a list of tick boxes). The KTP also hopes that the need for the impact of planning policy (or guidelines) to be assessed from an Urban Design point of view will be recognized and addressed.
As for enforcement, the KTP is of the opinion that there is a lack of supervision by inspectors during construction and insufficient enforcement, and that there is a lack of adequate resources for heritage protection and listing of heritage buildings.
The KTP stresses the need to conclude the Structure Plan Review which is way overdue and outdated. Much of the research that has gone into its preparation is now several years old and obsolete.
We also feel that there is a need to rely less on political appointees and to have better representation on MEPA bodies from the various sectors of society.
There is a need for the strict implementation of good governance throughout the organisation, firstly in national planning and procurement processes, and later, in all sections of the organisation.
First and foremost there is the need of strengthening and empowering public participation and public consultation. This should be encouraged and supported and should be included at every stage of the process. Board decisions should be published in such a way that similar circumstances would benefit from such decisions.
The KTP feels that the non-functioning Planning Consultative Committee (PCC) should be reconvened and reconstituted, while the Users’ Committee should be strengthened.
Moreover, the KTP feels that discussions and consultations on policy-making and policy formulation should be the order of the day, and that a closer relationship should be sought between MEPA and the KTP.
Consistency in the treatment of applications should be sought and zero tolerance adopted towards applications outside development zones.
The KTP wishes to see more clarity in the DCC Boards with more local and broader representation.
Finally, the KTP is of the opinion that the management and the administrative roles should be separated from the professional planning function of the organization. Moreover, management should be instilled with the vision and drive to provide the best level of service possible to its customers in order for the organisation to ensure it achieves its mission.
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