Objections to MEPA Rationalisation of Development Boundaries

With reference to the recently announced extension of the development boundaries whereby yet more undeveloped land will be given over to further development and construction:

1. There has been manifest opposition to this proposal from the public. There has not been one published letter or article in our media which is in favour of this new extension of the development area. Everybody one meets in the street is against extending the development area. The only support comes from those from those with a vested interest, such as developers and the hundreds of landowners who made submissions to MEPA for opening up new lands for development in the hope of personal gain.

2. Non Governmental Organisations are against extending development zones. Even those who could conceivably stand to gain from the new building opportunities, including the Chamber of Architects, the Chamber of Planners and the Malta Hotels and Restaurants Association have expressed themselves against extending the development zones.

3. The Church's Environment Commission has expressed its concern over proposals and declared its opposition to extension of the development boundaries.

4. There is no social need for more dwellings. Nearly one in four of residential units in Malta lie vacant and there is twice as much development space as is required until 2020 even without opening up new areas to development.

5. This is not an informed decision and it seems to have been made in haste. A decision to expand the development area should have, at the very least, awaited the results of the 2005 Census which will would have provided full data on vacant housing and and availability. of unused dwellings.

6. We have the highest proportion of built-up land in Europe; 22% of our land surface is already built up, as compared to the European average of 7%.

7. This proposal will reverse the progress achieved in getting the public to accept that development could not take place out of the Development Zone. It will lead those whose land has not been included this time, to put pressure on future governments to repeat this exercise in order to ensure inclusion of their land. It will therefore, in most likelihood, lead to the permanent destruction of far more than 2.4% of Malta's unspoiled landscape.

8. Many of the lands proposed for development do not adhere to the Parliamentary criteria which are, themselves, open to change. These include terrains which are not fully flanked by urban areas, land of ecological value, trees which are protected species, areas of established or potential archaeological value as well as agricultural land. They also violate the principle against ribbon-development joining one village with another as a continuous built-up area.

9. Malta is already plagued by overdevelopment and the Maltese can no longer tolerate this widespread building activity with levels of dust and noise which would be considered unacceptably-high in any other European Country. This excessive construction activity is causing a deterioration of the quality of life of the public. Extending the development boundaries will result in yet more construction activity which will continue to add to the existing environmental pollution.

10. The widespread building activity and development is causing health problems, especially childhood asthma where we already have the highest rate in the Mediterranean. Extension of the development area will only intensify these health problems.

11. The irrevocable loss of more countryside and increase in construction activity will also have a negative effect on tourism, the mainstay of our economy.

12. The extension of development boundaries will result in the sanctioning of yet more illegal structures. This is wrong as it will only encourage further illegal building activity.

13. In the absence of fiscal measures, such as taxation of vacant properties to discourage speculation on property, the price of property will continue to spiral. This artificial inflation of property prices will be to the detriment of young people and newly-weds who now have to make huge sacrifices to buy their first home.

14. This extension of the area for development and construction is therefore not in the national interest. Compensation for the few instances of true injustice makes up only a fraction of the total land involved and should be compensated financially, not used as an excuse to destroy our rural heritage. The other cases, which are related to injudicious commercial ventures have no right to be compensated by the granting of public land, a fact which will serve as a precedent to other claims. The 'rationalisation' scheme as presented by Mepa will create as many anomalies as it seeks to redress, and will require further 'corrective measures' in the future. The only perceivable object of the proposed extension of the development is to give a temporary boost to the construction industry. Sacrificing yet more of our landscape for short-term gain is wrong

15. Some of the owners, of land earmarked for development, have not requested and do not want such development; why was their land included? As Government is the largest single landowner in the project, it has therefore taken on the role of a major speculator. Many of the plots are subject to a single, unified development. This is of direct benefit to large developers, resulting in speculation rather than social values.

16. No Strategic Environmental Assessment or Environmental Impact Assessment as required by EU Directives has been made of the extrusion of the development zone.

17. The new provision is scheduled to be approved by parliament by July, but does not allow for their assessment in the light of the results of the National Census to be published shortly after this approval by Parliament. The development zone proposals were drawn up hastily, with insufficient time allowed for public consultation or for study of the public's objections by Members of Parliament.

18. Protection of our environment is entrenched in our Constitution which declares (Chapter II, 9) "The State shall safeguard the landscape and the historical and artistic patrimony of the Nation."

19. The EU State of the Environment Report 2005 pointed out as follows : "Landscape is threatened by increasing built-up area, industrial and coastal development, taller buildings on urban fringes obstructing views of historical centres ..." The report expresses "concern that pressure will increase to bury more of our land under more and more vacant buildings…….This is resulting in loss of historic fabric, inappropriate design of new and restored buildings ..." To make matters worse, the report points out that while 51 per cent of Malta was identified as of high or very high landscape value in 2004, only 12 per cent of Malta's landscape has been formally protected.

20. The EU State of the Environment Report goes on to say that governments should integrate environmental concerns into all policy areas and they demand closer and better co-ordination between health and environmental policy-making as environmental degradation has been identified as one of the main causes harming people.

We live in a democratic country and it is the duty of a democratic government to listen to the people and act accordingly. Under the circumstances, and in the interests of transparency, can MEPA please provide plausible justification for allowing extension of the development zone. As things now stand there is nothing whatsoever to indicate that extension of the development boundaries fulfils any social need or that it is in the national interest and does not it seems to serve the common good.

As EU citizens we have the right to be provided with a convincing justification for a development which goes against the interest of our endangered environment, for which there is no justification, which goes against our constitution and which nobody in Malta seems to want.

If the extension of the development zone is approved by parliament, this will constitute an undemocratic action. Maybe, just this once, some members of our ruling government members of parliament, who put the national interest above politics and profit, will have the courage to vote against the motion in Parliament.

FAA Committee members