Cham­ber of Ar­chi­tects calls for re-eval­u­a­tion of Paceville mas­ter plan

The Kamra tal-Per­iti (Cham­ber of Ar­chi­tects) has raised con­cerns about the mas­ter plan for Paceville as it has been pre­sented ands calls a for a reeval­u­a­tion ex­er­cise be­fore any sug­ges­tions are im­ple­mented.

Malta Independent - - NEWS -

The prepa­ra­tion of a Vi­sion for Paceville is in it­self a pos­i­tive ini­tia­tive, the cham­ber said in a state­ment. In­de­pen­dently of the con­tent or ap­proach, it is com­mend­able that a draft De­vel­op­ment Frame­work has been pro­posed which sets out a strat­egy for growth and for the re­gen­er­a­tion of the area, plans staged im­prove­ments over time, re­flects a change in the way ur­ban plan­ning and de­vel­op­ment ought to be stud­ied, and fu­ture plan­ning un­der­taken.

In­deed, sim­i­lar ini­tia­tives ought to be more fre­quent and should serve as an im­pe­tus for the mech­a­nism to be en­cour­aged in other ar­eas, al­beit un­der the um­brella of one strate­gic plan and vi­sion for the na­tion as a whole, and not in an ad hoc and hap­haz­ard man­ner which raises more doubts than it pro­poses a clear vi­sion that is of ben­e­fit to the whole of so­ci­ety.

The fact that Govern­ment and the Plan­ning Au­thor­ity have ap­pre­ci­ated that the draw­ing up of a com­pre­hen­sive study is the best route to fol­low, au­gurs well for the fu­ture. Nev­er­the­less, it is im­por­tant that the plan­ning ex­er­cise un­der­taken pro­vides the suf­fi­cient level of de­tail and anal­y­sis re­quired, and is car­ried out in tan­dem with other se­ri­ous na­tional plan­ning is­sues such as trans­port and in­fras­truc­tural re­quire­ments.

The fo­cus on im­prove­ments in the pub­lic ur­ban realm is ab­so­lutely cor­rect, the cham­ber said. The ex­ten­sion of pedes­tri­anised ar­eas, and of shared sur­face treat­ment ar­eas, is also a step in the right di­rec­tion, even if more study is re­quired to un­der­stand the im­pact on ex­ist­ing ac­tiv­i­ties. The pro­vi­sion of open land­scaped pub­lic spa­ces is laud­able and the con­cept of pre­serv­ing and val­oris­ing the her­itage as­sets in the area is cer­tainly a sound one.

It is a pity, there­fore, that a laud­able ef­fort to see the big­ger pic­ture in a long-term per­spec­tive is di­min­ished by a num­ber of se­ri­ous flaws in the Frame­work. The ex­er­cise seems to have de­gen­er­ated into a jus­ti­fi­ca­tion of pre­vi­ously-de­ter­mined de­vel­op­ment vol­umes, in pre­vi­ously de­ter­mined lo­ca­tions. The quan­tum of de­vel­op­ment pro­posed at Paceville is ac­com­mo­dated but never chal­lenged. Con­se­quently, the iconic sky­line is taken as an as­sumed desider­ata. The ur­ban de­sign prin­ci­ples which are pro­moted in the doc­u­ment are of top qual­ity, but the same prin­ci­ples seem to be con­tra­dicted by the scale of de­vel­op­ment pro­posed which is never jus­ti­fied.

The Frame­work doc­u­ment is pep­pered with the right ref­er­ences to con­tem­po­rary sus­tain­able ur­ban de­vel­op­ment prin­ci­ples. This is jar­gon found in text­books on plan­ning and ur­ban de­sign, but which mean noth­ing if not grounded in so­cio-eco­nomic and plan­ning re­search. When as­sess­ing the de­tailed pro­pos­als, one strug­gles to un­der­stand how such prin­ci­ples im­ple­mented.

There is ref­er­ence, for ex­am­ple, to com­mu­nity fa­cil­i­ties un­der the im­pres­sive head­ing of so­cial sus­tain­abil­ity, but nowhere is there any in­di­ca­tion of what fa­cil­i­ties would be pro­vided. The doc­u­ment refers to pre­serv­ing the in­her­i­tance of lo­cal tra­di­tions but makes no men­tion of what these tra­di­tions are.

The doc­u­ment sug­gests that so­cial co­he­sion is the re­sult of en­trepreneur­ship and the tourism in­dus­try. This ar­gu­ment is highly de­bat­able. Tourism is cer­tainly not the best tool to fos­ter so­cial co­he­sion - on the con­trary, it tends to erode com­mu­nity re­la­tion­ships, and hence so­cial co­he­sion. In ad­di­tion, de­vel­op­ment which em­pha­sises so­cial dis­par­ity does not strengthen co­he­sion.

A promis­ing doc­u­ment, fo­cus­ing on the need to im­prove the pub­lic ur­ban realm, is crip­pled by the lack of so­cial re­search and the judg­men­tal propo­si­tions. The fail­ure to con­sult, in any way, with res­i­dents and eco­nomic op­er­a­tors of Paceville, is a se­ri­ous de­fect. The authors re­port a “num­ber of site vis­its“, but oth­er­wise do not ex­plain the method­ol­ogy fol­lowed in the as­sess­ment of the sit­u­a­tion, and hence in the for­mu­la­tion of pro­pos­als. There is noth­ing in the doc­u­ment which sug­gests that the rights of res­i­dents and lo­cals to par­take of the “eco­nomic growth“that will re­sult from the pro­posed de­vel­op­ment will be safe­guarded.

The De­vel­op­ment Frame­work pro­poses ex­ten­sive ex­pro­pri­a­tion of pri­vate land and prop­erty - as­sets that many peo­ple’s lives, homes, busi­ness and in­vest­ments have been built upon, on the ba­sis of the cur­rent le­gal frame­works.

The doc­u­ment be­comes highly dis­crim­i­na­tory, fo­cus­ing pri­mar­ily on busi­ness in­ter­ests that are al­ready pub­lic - whilst not con­sid­er­ing pos­si­ble fu­ture de­vel­op­ments of a sim­i­lar or smaller scale else­where.

The Kamra tal-Per­iti has sub­mit­ted its for­mal re­sponse (at­tached) to the Plan­ning Au­thor­ity as part of the on­go­ing pub­lic con­sul­ta­tion process. This re­sponse out­lines a num­ber of mat­ters that, in the opin­ion of the Kamra, re­quire ad­dress­ing be­fore this doc­u­ment pro­ceeds to be­ing trans­lated into a Lo­cal Plan for the area. These in­clude the fol­low­ing pri­mary con­cerns: • that the doc­u­ment can­not and should not be pre­sented as a Master­plan or a Lo­cal Plan re­view, but as a De­vel­op­ment Frame­work as in fact pre­sented by the authors them­selves; • that the draft fails to ad­dress the cri­te­ria es­tab­lished in the Terms of Ref­er­ence pro­vided to the con­sul­tants by the Plan­ning Au­thor­ity; • that the frame­work con­flicts with the Strate­gic Plan for the En­vi­ron­ment and De­vel­op­ment (SPED) in terms of the pro­posal for hav­ing tall build­ings, the sig­nif­i­cant in­crease in res­i­den­tial and com­mer­cial floorspace, the adop­tion of low park­ing stan­dards and the pro­posal of a sig­nif­i­cant land recla­ma­tion project; • that the vol­umes and pop­u­la­tion den­sity pro­posed have all the mak­ings of a po­ten­tial de­vel­op­ment bub­ble, with the al­lo­ca­tion of space be­ing pro­posed in a highly in­equitable man­ner and with a com­plete lack of con­sid­er­a­tion for pri­vately owned prop­erty, while at the same time al­lo­cat­ing sig­nif­i­cant de­vel­op­ment po­ten­tial to pub­lic land which is be­ing there­fore given to spec­u­la­tive pur­poses; • that the sub­mis­sion of the draft to a Strate­gic En­vi­ron­ment As­sess­ment (SEA) process is highly pre­ma­ture and not in line with the reg­u­la­tory pro­ce­dures in this re­gard; • that the doc­u­ment presents a num­ber of short­com­ings which are pri­mar­ily a re­sult of the fact that it is based on pre-es­tab­lished in­ten­tions, and there ap­pears to have been lit­tle, if any, at­tempt to un­der­stand the prob­lems, the as­sets, and the par­tic­u­lar dy­nam­ics of the area with a view to­wards achiev­ing a pro­posal which truly val­orises those as­pects which make Paceville unique, and to build on these in or­der to achieve a sus­tain­able growth of the area which is founded on sound so­cial, eco­nomic and en­vi­ron­men­tal con­sid­er­a­tions; • that while the Frame­work in­cludes a num­ber of good pro­pos­als re­gard­ing the in­fra­struc­ture re­quired to sup­port the pro­posed de­vel­op­ment, these are pro­posed in iso­la­tion rather than be­ing pre­sented within a Na­tional Frame­work and Paceville ap­pears to have been sin­gled out for sig­nif­i­cant in­vest­ment at the ex­pense of other lo­cal­i­ties; • that the trans­port strat­egy is flawed be­cause it only ad­dressed trans­port within the plan area and does not of­fer a co­or­di­nated ap­proach tak­ing into ac­count ac­cess to and from Paceville; • that while the Kamra tal-Per­iti is not con­trary to the de­vel­op­ment of tall build­ings, it can­not ac­cept the ab­so­lute ab­sence of any jus­ti­fi­ca­tion of ei­ther the vol­ume, or the lo­ca­tion of such tall build­ings, and the fact that the authors ap­pear to have as­sumed that the pro­vi­sion of such struc­tures are the only so­lu­tion to an “at­trac­tive, safe, ef­fi­cient and en­vi­ron­men­tal (sic) friendly place, where peo­ple live, work, play, and in­ter­act ..... “; • that the pro­posed de­vel­op­ment poses sig­nif­i­cant en­vi­ron­men­tal con­cerns in terms of sus­tain­abil­ity, ma­te­rial re­sources and waste gen­er­a­tion which are not ad­e­quately ad­dress within the doc­u­ment; • that con­sid­er­a­tions re­gard­ing fi­nanc­ing, phas­ing and im­ple­men­ta­tion of the De­vel­op­ment Frame­work are es­sen­tial but are not suf­fi­ciently elab­o­rated upon, and the com­plete lack of cog­ni­sance of pri­vately owned prop­erty in the area and the cum­ber­some le­gal pro­ce­dures that would be re­quired to ac­quire such prop­erty raises se­ri­ous doubts about the achiev­abil­ity of this plan. The Kamra tal-Per­iti is there­fore of the opin­ion that, while this De­vel­op­ment Frame­work has a num­ber of pos­i­tive as­pects that bode well for a suc­cess­ful re­gen­er­a­tion of the Paceville area, it also man­i­fests a num­ber of is­sues which are of con­cern and which re­quire sig­nif­i­cant re-eval­u­a­tion prior to mov­ing this doc­u­ment for­ward for adop­tion as the ba­sis of a Lo­cal Plan for the lo­cal­ity.

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