FLIMKIEN GHAL AMBJENT AHJAR – MEPA’s lack of Urban Planning
FAA is extremely concerned by the number of planning policy revisions that are being launched by MEPA in quick succession, namely the Policy and Design Guidance, Revision of the Local Plans, Development Zone Policy, Heights Adjustment Policy, Fireworks Factories Policy, Floor Area Ratio Policy, Solar Farms Policy, Cemeteries Policy and the Inner Harbour Area (Marsaxlokk) Development Brief.
FAA condemns the fact that land reclamation projects are not being regulated by a national policy, nor by a marine local plan, a ploy conceived in order to avoid the EU obligation to undertake a Strategic Environment Assessment (SEA). Almost 10 years after joining the EU, it seems our main aim is still to shirk EU obligations. FAA asks whether MEPA intends carrying out an SEA to assess the cumulative impact of all the proposed new policies.
All environment groups agree on the fact that these policies should have been launched AFTER the conclusion of the Strategic Plan for the Environment and Development (SPED) which replaces the Structure Plan and establishes the guidelines for all subsidiary policies. Issuing the ‘minor’ policies before the masterplan will create conflicting policies and more loopholes and grey areas, besides the fact that such haste does not allow for in-depth studies and meaningful consultation, not even with professional bodies, let alone with the public.
FAA condemns the fact that the work carried out by MEPA officials on the SPED during the previous administration was scrapped due to the fact that it did not the new Government’s priorities. This amounts to political interference in environmental policy and means that it is not studies on national sustainability, land use requirements and health issues that are the real priorities of the SPED but political expediency.
FAA is particularly concerned by the tall buildings (FAR) policy, as a report just issued by the Council for Tall Buildings and Urban Habitat along with UNESCO reveals that “knowledge related to Urban Design, City Planning and Social Issues is somewhat underdeveloped.” How can we commit our towns to high-rise buildings when international bodies are highlighting the lack of research in the life-cycle of buildings, questioning the genuine sustainability of high-rise, the suitability of materials to different climates, wind performance, fire safety and the social impact of high-rise especially among families, the old and disabled.
EU policies puts obligation on MEPA to ensure that all new developments are energy efficient. Yet MEPA case officers and the DPA disregard enforcing a law which requires that ALL planning applications for dwellings be accompanied with an Energy Performance Certificate, as stipulated in the Energy Performance of Buildings Regulations 2012, retroactive to developments dating to 2009. There are legislated penalties for these omissions.
Months ago FAA flagged up to MEPA that a cement Silo was being built against the Development Planning Act which requires that all developments are obliged to go a thorough process which includes publishing a planning application for public consultation. TWO Health Risks Assessments demanded by MEPA from both the Kordin Grain Terminal and UC. Ltd concluded the serious risk to our health by toxic contamination of the grain by the cement. It is unacceptable that in view of this risk to public health, MEPA has not yet taken direct action and dismantled this ticking time bomb.
MEPA has been remiss in not ensuring that its own polices that require developments of 40 apartments have play and amenity space equivalent to 10 square meters per apartment. Because of this lax attitude we are ending up with developments that are nothing more than pigeon holes with no attempt to contributing to a better quality of life.
MEPA has been allowing Maltese traditional townscapes to be ruined by allowing three and four storey blocks in predominately two storey streets. MEPA has also created dangerous precedents by granting permits for a two storey building paces away from the Ta’ Hagrat Temples UNESCO World Heritage Site, and permitting the setting up of a commercial communications tower at Dwejra, a protected landscape area, metres from the scheduled Victoria Lines.
Friends of the Earth Malta – AIR QUALITY & Liquefied Natural Gas at DELIMARA
Last year the EU Environment Office announced that during 2012, Malta had achieved conformity with EU standards of air quality, however during a meeting at Europa House in Valletta between local e-NGOs and the EU Environment Office, we asked the EU delegates to see could see what data and what methods of data treatment MEPA provided. Instant answer: “We cannot do that as data transmitted to Brussels is confidential. We assume governments inform their own people!”
Our governments are rather economical with information, of course. MEPA has five Air Quality “boxes” gathering data sited at: Gharb (Gozo), Attard, Msida, Kordin and Zejtun, (in this last area they now have the box formerly at the Marsaskala Family Park too).
1. All “boxes” have gaps, some brief (a few hours or a day or two) some of a month or more in the data collection relating to one or more parameters. Msida had no Benzene or Toluene measurements this past month. How are these gaps “treated” in the final presentation of Malta air quality?
2. “Boxes” have different sets of parameters. Only Msida has Benzene/Toluene. Attard had just Ozone up to a year ago and nothing since then.
3. As far as conditions at specific sites are concerned, it is not much consolation to people living at Msida to know that Malta has met EU standards for Air Quality, when Msida patently has not, particularly for the most dangerous components of air pollution: benzene and toluene, and PM10 and PM2.5. The first pair – benzene/toluene are known to have carcinogenic (benzene) and foetus (toluene) effects at very low levels of extended exposure. The second pair – PM10/PM2.5 – have been strongly linked to increased (+10%-13%) risk of heart attacks “even at levels below current EU limits”; and this apart from their long-known effects relating to asthmatic and lung conditions.
Conclusion: we are being badly served by MEPA, our governments and the EU on matters of Air Quality. Aspiring MEPs please note.
B. There is currently a loud and often confused debate on the placing of the Liquefied natural gas (LNG) storage for Delimara Power Station (DPS).
The current proposal is to have a 160,000m3 tanker moored at a new quay at DPS, feeding an on-shore re-gasifer unit. An incomplete and therefore not-so-weighty Risk Assessment (RA) has been made. Conclusion: One (1) serious accident in 10,000years.
Objections and suggested alternatives:
(a) A serious accident can still happen. Answer: then use some assessment device other than a RA which, however refined, can only deliver a “probability”.
(b) Use Hal-Far for LNG storage. Answer: Unless re-gasifer unit is taken there as well, impractical, engineering nonsense, and probably high risk with all the other fuels (LPG and oil) stored in the vicinity.
(c) Moor tanker outside bay: a proposal made before tender was awarded. Not practical now as tanker chosen has no place for a re-gasification unit. The ship, an FSU, will have to be turned into a FSRU. Enemalta has said that there is neither the time nor the money to go for that solution. But time especially, was determined in the heady days of an election campaign. It may be wise to re-consider, though the acquisition of a FSRU may well add on 18-24 months to start up time; but that is not very much seeing Electrogas are going to be with us for 18 years. Money, now that the tender has been awarded, may be harder to come by. On the other hand, we could tap some of the expected bonanza from the IIP for that purpose.
Malta Organic Agricultural Movement (MOAM) – Dysfunctional MEPA
MEPA’S announcement that over a thousand enforcement notices have gone missing from MEPA’s own internal planning application comes as no surprise. What made it worse was the fact the environmental NGOs have been complaining for years on end that the enforcement directorate was simply non-functional, or dysfunctional. The cause of this could be various. But the fact remains that the person/s responsible to ensure that these things do not happen, chose, for some unknown (but imaginable) reasons, to close an eye, if not complete blindness.
To add insult to injury, it was several months later, and only after an audit was carried out, that the discrepancy was confirmed. Such a failure completely discredits the authority and its ability to control any form of illegal development.
Weeks into the scandal, and still MEPA has not issued any statements on the status of the investigations and if anyone has been suspended. MEPA did not even say if the I.T. system has been secured to prevent further tampering with the data. It is also not clear if any hard copies have also been removed.
Very often, environmentalists and anyone who criticises the MEPA institution, ends up being targeted personally by the authority. But MEPA and the authorities have to bite the bullet and accept the fact that the general public perceive MEPA (the entity as a whole) as the most corrupt institution on the island. This perception leaves a lot to be desired from an authority that is in the first place there to make sure that the planning and construction sector is regulated and that any abusers, whoever they may be, are brought to justice.
The NGOs are still awaiting some form of explanation as to what is to happen with the lost enforcement cases!
Malta Water Association – Malta needs a National Water Management Plan – YESTERDAY!
Malta’s groundwater resources are in a perilous state. Groundwater suffers from severe over-exploitation, estimated at 50% higher than the sustainable replacement by rainwater – leading to seawater intrusion. Moreover, 90% of the groundwater bodies show nitrate levels that exceed the EU limit of 50mg/l.
If we continue over-abstracting and polluting groundwater, and neglecting rainwater harvesting, there will soon be a time when Malta would have to depend exclusively on RO water for its domestic water supply. This is unsustainable and detrimental to the Maltese economy, and terrifying from a strategic point of view – because should anything happen to the RO plants, Malta only has 2 days’ supply of potable water in its reservoirs.
As a grouping of professionals with various expertise and interests in water management in the Maltese Islands, the Malta Water Association has been calling for abandoning the piecemeal approach and the drawing up of a National Water Management Plan.
In the run-up to the last general elections, the Malta Water Association drew up an extensive set of recommendations to the political parties. The fact that the political parties acknowledged the need for a National Water Plan in their manifestos shows that there is a political consensus that such a plan is essential.
While this is very encouraging, there are three imperatives that are necessary for a National Water Management Plan to succeed:
1) That the necessary financial and human resources are allocated for the development of the Plan. Water is a very complex medium; its movement under the ground has been poorly studied; the sustainable yield of the aquifers is not properly defined and there is a lack of information on the demand side with one of the more contentious issues being the water consumed by agriculture;
2) Education. All water users must be adequately informed why certain actions and hard choices are necessary. At the same time, the impact of corrective measures arising from the Plan should be mitigated by a renewed impetus in alternative sources of water, such as rainwater and flood water runoff harvesting and the reclamation of wastewater;
3) There needs to be political consensus on the deliverables of the Plan (where do we want to go, how and by when?). The Plan’s timeframes will necessarily span across a number of political administrations so the only way to ensure continuity and measureable progress is to ensure a commitment by both parties from the outset.
The Malta Water Association calls for partisan politics to be absent in the debate on water resources management. To this end, the Malta Water Association will continue its efforts to get the political class together so that water does not become yet another political football.
Noise Abatement Society of Malta (NASoM)
To point out the obvious is a waste of time, but to our consternation the obvious, or more to the point the management of unwanted noise, is still at the very bottom of the government’s program, although it is a hazard to human health & the wellbeing.
Excessive noise seriously harms human health and interferes with people’s daily activities at school, at work, at home and during leisure time. It can disturb sleep, contribute to cardiovascular and mental health problems, reduce work performance, provoke annoyance responses and changes in social behavior.
Exposure to constant noise above 85 dB (A) for extended periods of time will cause permanent loss to hearing. Even at low levels, without our realizing it, noise causes stress due to the inability to concentrate, communicate, or rest. This type of noise is constantly invading our privacy at our homes.
Noise is generated from the following sectors:
Ambient Noise is generated from Commercial, Industrial & Transportation activity.
Neighbourhood noise is due to activity from pubs, clubs, discos, commercial or local industry, construction sites, and traffic in urban areas.
Neighbour noise is produced by the person’s neighbours.
More specifically, serious noise hazards in Malta are produced by:
– Port activity especially during rest periods,
– Scrap yards in residential areas;
– Traffic in urban areas, Construction works;
– Entertainment establishments, especially open air discos;
– Vehicle repair shops in residential area;
– Locally organized Open-air Entertainment activities in residential area;
– Vendors activity (pneumatic horn);
– Noisy neighbours.
Those responsible to enforce the regulations which control noise from the various sources are: The Trading regulations Unit in conjunction with the Director Trade Services, Malta Tourist Authority, Building Regulation Office, MEPA, OHSA, Health department. The Police enforce the law. In spite of all the regulatory authorities involved, the present noise management is inconsistent and inconclusive, rarely bringing relief to those suffering from noise pollution.
The Malta Transport Authority manages the Motor Vehicles Regulations, including the VRT. The permitted noise level of the exhaust system, vary from 119 to 100 dB (A) accord to the vehicle make & power.
However, Directive 2007/34/EC, concerning the permissible sound level and the exhaust system of motor vehicles, limit the sound values of the moving vehicle between 74 dB (A) and 80 dB (A) according to make & power. For the record this directive is not transposed in our legislation.
The solution, in part, is available in the, “Noise Prevention & Control (framework) Regulations”. These were published at the end of the previous legislature. Unfortunately neither the government nor the opposition seem to be too bothered to have these regulations enforced.
Nevertheless, without the government commitment and the drive of the stakeholders the framework would be another paper tiger.
RAMBLERS ASSOCIATION OF MALTA
Id-dokment “ODZ POLICY DOCUMENT” jispjega x’se jkunu l-linji godda li ser tiehu l-MEPA fuq ZONI fejn mhux permess ZVILLUP”. Fih 31 policy … u ftit huma dawk li tista’ taqbel maghhom jekk tkun thobb l-ambjent naturali. Izda Il-gimgha li ghaddiet dan id-dokument diga gie approvat mill-bord tal-MEPA bi 12-il vot favur, 2 kontra u wiehed assenti.
Gie mfassal, skont minn kitbu, biex ikollna agrikoltura iktar sostenibbli u ambjent naturali isbah. Li jrid jikkkonserva l-ambjent naturali ghalina u ghal-generazzjoni-jiet ta’ warajna.. Jghid li jrid jiskuraggixxi bini zejjed fl-ODZ, li jrid jghin liz-zaghazagh biex jidhlu ghal intraprizi godda fil-biedja
Imma mal-ewwel paragrafu tinduna li dawn il-policies jitkellmu hafna fuq bini u ftit hafna fuq konservazzjoni: Lsta twila ta’ x’jista’ jinbena: bini gdid, msebbah, mibdul ghal uzu differenti, mizjud sa certi limiti, imma meta hemm bzonn anke b’iktar, li zieda ta’ 10% fuq dak stabbilit ghal kull zvilupp tigi tollerata.
Nafu, per ezempju jekk Malta ghandiex bzonn izzid it-tkabbir ta’ certi annimali jew hxejjex u mhux ta’ ohrajn? Ser nghidu kemm lesti li nzidu, p.e. fil-5 snin li gejjin? Ghaliex l-impressjoni li tiehu hi li din hija gabra ta’ talbiet li saru minn individwi u ta’x’ hasbu dawk li fasslu d-dokument, mhux ta’ studji serji.
Se jkunu permessi xi 15 il-tip ta’ bini mbarra serer, hitan tas-sejjieh gholjin u mhux bil-gebel propju, swimming pools, stalel, bini iehor li mhux postu f’ambjent abitat, Tkabbir, jew bini mill-gdid ta’ bini ezistenti, basta li xi hadd kien joqghod fiha qabel is-sena 1992? Mhux jekk hemmx xi hadd joqghod fiha issa. Ifakkruna fil-kaz tal- Bahrija.
U bini ghall agriturizmu. U f’dan id-dokiment ma jissemmewx il- fabbriki tak-murtali, u ir-ranges tal-isparar li huma kollha f’ODZ.
Issa barra hekk issib hafna klawsoli li huma vagi, u dawn ser jigu interpretati minn nies li mhux dejjem ihobbu hafna l-ambjent naturali. Il-bicca l-kbira tal-klawsoli ghandhom bzonn kjarifiki, precisazzjonijiet u diskussjonijiet biex wiehed ikun jista’ jghid li kien hemm konsultazzjoni ta’ veru. Hemm anke affarijiet neqsin, bhal per ezempju x’jigri meta xi progetti jigu abbandunati.
U dan il-bini kollu se johloq bilfors bzonn tas-servizzi: ilma, dawl, drenagg, toroq,…li jfissru spejjez ghac-cittadini.
Tiskanta mbaghad kif il-MEPA ma tiddejjaq xejn twieghed li ser taghmel supervizjoni jew monitoragg ta’ xi whud mill-progetti meta Malta kollha taf li l-MEPA ghandha mad 9,000 Enforcement Notice b’lura, li qatt ma hadet passi fuqhom. Issa mal 4000 minnhom, ghal raguni jew ohra, ma tistax iktar tesegwihom, Baqaghala imma mal-5000 x’tiehu hsieb.
F’iktar minn 40 pagna l-ebda kelma fuq kif
• ser tissewwa almenu parti mill-hsara kbira li garrab l-ambjent naturali fl-ahhar 20 sena, hafna minnha tort tal-MEPA stess
• kif ser jissahhah l-infurzar biex ma jizdedux l-abbuzi
• se tinbena sinergija mad-Dipartment tal-Artijiet tal-Gvern biex l-ambjent jigi protett,
• m’hemm l-ebda provizjoni li tghid li fil-hrug tal-permessi tkun il-fergha tal-ambjent tal-MEPA, u mhux dik tal-ippjanar li tohrog il- permessi, u li tara li l-kundizzjonijiet stipulati jkunu osservati.
Zewg kelmiet dwar l-Agriturizmu: jigu specifikati 4 tipi ta’applikazzjonijiet accettabbli. Imma m’huma cari xejn il-kriterji ghal kull tip: kemm tmien ta’ raba f’fkull kaz, kemm kmamar permessi, x’esperjenza jrid ikolu l-bidwi, jekk ghandhomx permess ghal swimming pool, ecc. U ma nafux jekk hux bizzejjed li bidwi jkun rtegistrat u mhux ukoll li ilu, u ghadu, attiv fil-linja tieghu ghal certi tul ta’ zmien.
