Ster plan should be scrapped

Reason 1: The planning approach adopted for the master plan is incorrect. The master plan takes as its ‘baseline’ nine major development proposals that were submitted to the Planning Authority (PA). Plan proposals are developed around, and broadly in accordance with, the requirements of the nine ‘baseline’ proposals. This is turning urban planning on its head. Normally, designs provide the planning framework with which development proposals are evaluated. Here it is the other way round. The Planning Authority has produced a master plan that is determined and shaped by the development proposals.

Reason 2: The Planning Authority’s imposition of the ‘baseline’ developments on the master plan signifies endorsement in principle. The ‘baseline’ developments are being endorsed by the PA without a proper assessment of each. In effect this is a short circuiting of the planning process. The PA first imposes, without justification, the baseline developments on the plan and then eventually the PA will use that very same plan to justify the granting of the permits for the same baseline developments.

Reason 3: The master plan proposes a sharp increase in residential, commercial and hotel floor space. There is neither identifiable demand nor strategic justification for this massive increase of floor space. In tourism for example, the sharp increase of five-star hotel beds is not justified by an increase in demand and the end result will be that prices will be pushed downward. Decisions that will have long-term economic and social impacts are being taken in a vacuum and without reference to tourism or any other strategic plan.

Reason 4: The Floor Area Ratio policy is ignored in the master plan. The Floor Area Ratio (FAR) is a mechanism with which a public space is created over part of a large development site. In return, the developer gains additional building height from other parts of the site. Without the FAR, the PA will have to make highly subjective decisions on building heights, based on equally subjective assessments of skyline. The Planning Authority’s abandonment of the Floor Area Ratio is misguided as it will have serious long-term implications.

Reason 5: The master plan includes proposals that will require the forced acquisition of private property. In almost three decades of development, never has there been a planning document that advocates the expropriation of private property, other than for infrastructural needs. It is very disappointing to see a planning document being used to infringe on people’s right to peacefully enjoy their property. What is even worse is that the owners find out that their property is being considered for expropriation through a document issued for consultation.

Reason 6: There are factors that make the master plan not doable. The expropriation will give rise to cumbersome legal procedures making it possible for any one of the private owners to block the process. Moreover, for the plan to be implemented significant sums of public funds will be required. Anyone who works or has worked in the public sector knows how difficult it is to get additional funding from the Finance Ministry.

Reason 7: The foundations of any plan are a proper analysis of the existing environmental, social and economic conditions of the area and this includes public consultation. These are evidently missing from this document.

Reason 8: There is a legal requirement for any plan to be in general conformity with the Strategic Plan for the Environment and Development (SPED). As rightly noted by the Kamra tal-Periti (Chamber of Architects) in its comments, the plan is not compliant with SPED. The KTP mentions six areas of non-compliance but the most significant refer to residential floor space and to commercial floor space. For both, the SPED states the existing development areas amply cater for the projected demand. The master plan is not compliant because it proposes a significant increase in both residential and commercial floor space.

When a plan is issued for consultation there are always weaknesses that need to be addressed and improved upon. Amendments are made, sometimes radical ones, so that the identified deficiencies are addressed. In this case, there are fundamental flaws in the process and in the way basic planning principles are ignored. There is also the non-compliance with the SPED. The flaws run far too deep to be fixed by making changes to the document. There are ample reasons for the Paceville master plan to be scrapped, and the process started afresh.

There are other matters which are of concern. First, for the baseline developments, it seems that the PA did not carry out a preliminary assessment as it would normally do. For example, the proposed development at Cresta Quay is on a narrow strip of rocky foreshore. A major development here should not be accepted because it is a very restricted site and it would remove the last remaining natural rocky water’s edge around St George’s Bay. The right thing for PA to do would have been to advise the developer that a high rise building on that site is not acceptable. Instead it simply passed it on to the master plan consultants to include as a baseline development.

Second, the master plan completely disregards a development brief that is legally binding on one of the nine ‘baseline’ sites. The master plan does not provide for an open space in the Mercury House site. This is in conflict with the development brief for Pender Place and Mercury House. Development briefs are commitments which bind the authorities as well as the private developers. In a sense, they are also the authorities’ commitment to the public and to nearby residents. The Planning Authority should show more respect for development briefs that are in vigore because when the goal posts are shifted, the Planning Authority would be backtracking on the commitments it made to the public. It is also peculiar how the master plan recommends expropriation of private property to create open space in Paceville but then allows the removal of one open space that is readily available in one of the major development sites.

The plan is unfair in a number of different ways. Is it fair that these extraordinarily large sums of money are spent in one area (primarily to cater for the nine ‘baseline’ developments) when there are other areas which are also in need of investment for upgrading and regeneration? The master plan is also unfair with other developers. By setting the nine major developments as a baseline for the master plan, the Planning Authority is giving them preferential treatment. The implications of this approach will be farreaching. Investors with more modest development sites in Paceville and elsewhere would be expecting similar preferential treatment to their proposals. If these nine ‘baseline’ developers were aided in this manner, then why not them as well?

During a recent BICC conference, one of the speakers, an estate agent, made a case for the government to market luxury apartments at international property fairs. He rightly pointed out that for the various mega developments to be sustainable more needs to be done to attract overseas buyers. I put forward the question: “What happens if these extra buyers for luxury apartments do not materialise? Are we going to end up with high rise buildings that remain unfinished, as we say in Maltese ‘gebel u saqaf’?” The reply from the panel was that before beginning construction the developer would see that there is enough demand for most of the apartments to be sold. I am not convinced.

The PA, as well as the Environment and Resources Authority, will need to consider what the environmental impact would be if the construction of any of these mega projects is stopped half-way. It may happen that the developer is unable to raise adequate funds to finish the work because of unforeseen circumstances, including cost overruns and changing market conditions. The Maltese urban landscape is already plagued by far too many eyesore ‘gebel u saqaf’ buildings. Please, no more.

The master plan assumes that the only way for Paceville to have attractive, safe and pedestrian-friendly urban spaces is by having the kind of radical interventions that it is proposing. It is a wrong assumption. Any urban space can be transformed and made attractive if there is good design and, most important, political will and funding. Our urban areas are littered with poor unattractive spaces because political will and funding to enhance our urban spaces was lacking.

The Chamber of Architects prepared what, in my view, is an excellent urban planning critique of the Paceville Master plan and the authorities would do well to take note of it. In conclusion, I quote from the Chamber’s submission: “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.”