Several commentators have made the case for the Paceville master plan to be scrapped. I add my voice to these calls. My main arguments are based on major flaws in the process that led to the preparation of the master plan.

There was no analysis of existing environmental and social conditions of the area. The plan preparation process should start with a careful analysis of the physical, environmental and social conditions of the area. Consultations at an early stage with people who live or work in the area are essential.

The planning approach adopted for the master plan is incorrect. The master plan takes as its ‘baseline’ nine major development proposals that were submitted, formally or informally, to the Planning Authority. This imposition by the PA is not justified by any study or analysis.

The master plan consultants developed their proposals around, and broadly in accordance to, the requirements of the nine baseline proposals. This is turning urban planning on its head. Instead of a plan used to evaluate development proposals, we got a master plan which is determined and shaped by the development proposals.

The PA’s imposition of the ‘baseline’ developments on the master plan signifies endorsement, in principle, even if the eventual details would have to be worked out. The baseline developments are being endorsed by the PA without a proper assessment of each.

Moreover, there is no justification based on the local plan or any other policy documents. If the master plan is approved as is, the PA would have short-circuited the planning process, a process to which it is legally bound to adhere.

There is no strategic justification for the substantial increase in floor space that will result from the nine baseline developments. The master plan proposes a sharp increase in the number of luxury apartments, in office and retail floor space and in the number of hotels rooms.

Instead of a plan used to evaluate development proposals, we got a master plan which is determined and shaped by the development proposals

These will be over and above other developments that are and will be taking place in Paceville and elsewhere in Malta and Gozo. There is no identifiable demand for this massive increase in floor space, be it residential, commercial or hotels.

Taking retail for example, there has been a steady increase in retail in Malta over the last decade and there is no way that we can sustain further substantial increases. Decisions that will have long-term economic and social impacts are being taken in a vacuum.

The master plan ignores the Floor Area Ratio (FAR) policy. The Planning Authority’s abandonment of FAR is a grave error. It 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.

The FAR provides a measure with which the PA can take decisions on major developments. Without the FAR, the PA will have to make highly subjective decisions on building heights, based on equally subjective assessments of skyline. It will boil down to negotiations with each individual developer, based on subjective criteria. As soon as one developer is granted some kind of concession, the next developer will immediately ask for more.

The master plan includes proposals that will require the forced acquisition of private property. Since the 1990s, public authorities have avoided expropriation of private property, except when essential and unavoidable, like for example when a road needs widening.

Over the years, I have seen dozens of local plans, action plans and development briefs and never have I come across any planning document that advocates the expropriation of private property, other than for infrastructural needs. Infringing on people’s enjoyment of their property in this manner is unacceptable.

In the master plan, the situation is made worse: the owners find out that their property is being considered for expropriation through a document issued for consultation.

The master plan is not doable. There are two factors that make it unachievable. The first concerns the requirement of forced acquisition of private property for important elements of the plan to be achieved. The expropriation will give rise to cumbersome legal procedures making it possible for any one of the private owners to block the process, or at the very least to delay it significantly.

The second factor has to do with public funding. For the proposed plan to be implemented significant sums of public funds will be required. As a minimum, €150 million will be needed for the expropriation of private property and anything between €50 and €100 million for the public spaces and the infrastructure.

Anyone who works in the public sector knows how difficult it is to get additional funding from the Finance Ministry; it is like drawing blood out of stone. Then there is the issue of equity.

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?

For these reasons, the master plan ­is fundamentally flawed and should, therefore, be scrapped.

There are other matters which are of concern. First, when the PA receives proposals for development, it normally carries out a preliminary assessment based on the local plan and other policy documents. In this case, instead of a preliminary assessment, the PA simply passed on the nine proposed developments to the master plan consultants, imposing them as baseline.

For these baseline developments, it seems that the PA did not carry out a preliminary assessment. A case in point is the proposed development at Cresta Quay. For many reasons, development on this site is a non-starter. It is on the rocky foreshore, 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 the PA to do would have been to advise the developer that a high- rise building on that site is not acceptable.

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 private developers. In a sense, they are also the authorities’ commitment to the public and to nearby residents.

The PA should show more respect to development briefs that are in vigore, because when the goal posts are shifted, the PA 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 for the removal of one open space that is readily available within one of the major development sites.

John Ebejer is a University lecturer, an architect and urban planner.

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