In its submission as part of a consultation exercise related to the draft Rural Policy and Design Guidance 2020 the Interdiocesan Environment Commission (KA) insists that the draft policy on its own is not enough to protect the countryside from undesirable development and to safeguard a thriving farming community.
In the submissions, it put forward during the 2019 consultation exercise related to the same subject[i], the KA had called for the publication of data which would help assess the outcomes of present policies that would inform in a public manner amendments to such policies. In proper monitoring of policies, policymakers need to compile the facts about where a policy has been successful and where it has failed. The KA is disappointed that, apart from no sign of any comment by the PA in its response to this suggestion, the draft policy does not present any of these facts or make reference to the monitoring report as was required by the same policy. The KA had also requested the publication of such policy assessment in the revision of the fuel stations policy and its suggestion was not heeded.
The proposed Rural Policy and Design Guidance 2020 has as its main positive point the elimination of the abuse that came from the permission of development of dwellings on the basis of pre-existing ruins. Having long campaigned against this abuse in various press releases it has issued in the last years, the KA commends its rectification hoping that this will have the desired results.
The KA proposes a number of steps to be taken if one really wants to protect the countryside and safeguard the farming community. Such steps include the following:
- Carrying out the necessary reforms in the wholesale market for fruit and vegetables (il-pitkalija) so that farmers’ activities become more economically viable and exploring the introduction of an insurance cover for farmers so that they are not left wholly unprotected in case of adverse weather conditions or other challenges brought about by phenomena beyond their control.
- Revising the Strategic Plan for the Environment and Development (SPED) to limit to the barest minimum any form of construction in the countryside.
- Delineating areas in the countryside where absolutely no development of any sort can take place.
- Revising the Development Notification Order thus ensuring that permitted development in rural areas under this order is further restricted, and would not possibly give rise to piecemeal developments.
- The Environment and Resources Authority and the Superintendence of Cultural Heritage should be given a veto on development applications that affect areas and properties that fall under the competence of these entities.
- The number of members on the Development Control Commissions should increase from three to five. This would reduce the risk of granting scandalous development permissions as has often happened in the past.
- Decision-makers should stop using the concept of “precedent” when deciding on development applications. This is anathema to the Maltese legal system and does not make sense in planning terms.
- The Government should not engage consultants, (whether paid or pro bono), who have manifest conflicts of interest, when drafting or deciding on planning policies.
- So-called “disturbed land” should not be the basis for any development. Such land should be restored and not serve as an excuse for development.
- Revising the Development Control and Design Guidance where it relates to ridges. In the 1980s and 1990s extensive damage was done to ridges in Gozo (Żebbuġ, Xagħra, Nadur and Xlendi). After recognizing well belatedly the damage done to ridges, the policy was changed and the surviving ridges were spared further onslaught by rapacious developers. In 2015 however, this policy was changed again and the ridges in Gozo are yet again being destroyed by insensitive developments with the blessing of policymakers and decision-makers who should know better.
The submission (in full) on the draft Rural Policy and Design Guidance 2020 that were submitted to the Planning Authority can be accessed here.
[i] Submission in the Public Consultation exercise on the objectives of the review of the 2014 Rural Policy and Design Guidance – Kummissjoni Interdjoċesana Ambjent – 15th November 2019