Timmy Gambin, in his contribution to the Times of Malta about ‘Cultural heritage sentinels’ (September 11), justified the abolition of the Cultural Heritage Advisory Committee within Mepa.

He did this on the premise that Mepa, in connection with applications for planning permits, sometimes received conflicting views on heritage matters from three sources: the Heritage Planning Unit within Mepa itself, the Heritage Advisory Committee (HAC) and the Superintendent of Cultural Heritage.

Gambin’s own contribution seems to be contradictory when he states that debates and sharing of ideas are always healthy, especially when more than one side of the coin is presented.

The issue of conflicting views had been partly addressed some years back by requiring the Heritage Planning Unit to be represented at meetings of the HAC. It is unfortunate that the Superintendent of Cultural Heritage never accepted to sit on the HAC as an ex-officio member but was only represented by one of his staff at some of its meetings.

When the HAC was initially constituted the chairman was also a member of the Development Control Commission such that he could represent the heritage lobby more incisively at meetings considering planning applications.

The very essence of the planning function should be the integration of policy across different sectors

The proposal to abolish the HAC results from the new legislative framework for the demerger of Mepa. Gambin argues that such a move is an improvement on the current situation once the Superintendent of Cultural Heritage will be employing five professionals to deal with planning applications.

I do not think you can replace the HAC simply by recruiting five professionals within the Superintendence of Cultural Heritage. I cannot comment on the current constitution of HAC because I do not know the currently appointed members, but the HAC as constituted under the previous administration was made up of members with a wide and varied experience which cannot be easily substituted by recruiting permanent staff.

Then membership included the Dean of the Faculty of History of Arts at the University; a learned legal practitioner and well established historical researcher; an architect who had a flourishing private practice deeply involved in major conservation projects; a UNESCO-acknowledged conservation expert; a historical researcher at the public notary archives; an architect of considerable experience in conservation policy, and so on.

Moreover, reviews by the HAC often resulted in direct discussions with applicants, requiring amendments to plans and proposals affecting sensitive heritage even though some initial proposals had been reviewed positively by planning staff.

The HAC also gave advice on policy issues affecting heritage properties and on protection of heritage through the scheduling process. It also reviewed delineation of urban conservation areas’ boundaries.

Gambin seems to suggest that consideration of planning applications affecting heritage matters should be evaluated by staff at the Superintendence of Cultural Heritage as distinct from staff at Mepa or any other legally constituted advisory body within Mepa.

But the Superintendent does not have a policy framework against which he can assess development proposals. He has to apply discretionary powers, unlike Mepa, which has a strategic planning document, local plans and development briefs setting the regulatory framework.

So surely there is a direct benefit in having full-time planning staff responsible for heritage planning plus an independently constituted advisory body to tender advice and recommendations on development proposals affecting heritage within a revamped Mepa structure. International charters and protocols such as the Council of Europe and the International Council of Monuments and Sites promote the integration of conservation policies within the planning process.

In my view the consideration of heritage matters must be guided not only by the intrinsic value of heritage but also by consideration among others of social issues, the urban context of the built form and the economic cost of bringing back in use vacant or derelict property.

So consideration of heritage matters is essential to be viewed within a wide perspective and retaining that process within the planning regime has benefits in the interest of heritage.

The very essence of the planning function should be the integration of policy across different sectors setting the vision for development to achieve sustainable development in the long term. Further fragmentation of the various inputs to the planning process will lead to weakening of the system rather than reinforcing the robustness of the planning framework.

Godwin Cassar is a chartered town planner, an architect and civil engineer, and former director general of the Malta Environment and Planning Authority.