Mangion Mangion & Partners, Malta Architects, Civil Engineers and Planning Consultants

What was that?

Planning and Environmental considerations are interlinked. The whole issue hinges on the perspective from which the two aspects are viewed. I bet that each reader has read the title of this article twice and had to stop and think about what it really meant. Environment? Planning? Isn't this the same thing? What is this all about?

Planning is about thinking ahead, coordinating, managing and making the best possible use of resources. In order to formulate effective Land Use plans, three very important considerations have to be taken into account - the Economic aspect, the Environmental aspect, and the Social aspect. This is a basic requirement. Each aspect is equally important, however, in specific situations, each one aspect can assume more importance than the others. And it is the Political level that is responsible to give strategic direction.

Even if not in a formalized Planning context, in the 1980s politicians gave the Social aspect more importance through schemes that encouraged affordable home ownership. Some time later, the Economic aspect took over, with the emphasis being on attracting foreign investment and further encouragement to the construction sector. During the last few years, the Environmental agenda has become more important, mainly because in giving importance to the Social and Economic aspects, decision takers did not adequately consider the effects on the Environment.

Sustainability

But if, for a moment, we look deeper at what we mean by Environmental considerations, we see that it has also evolved to include very similar criteria to those traditionally considered in Planning, albeit from a more narrow and focused perspective. Environmental considerations are synonymous with the concept of Sustainability. The three fundamental pillars of Sustainability include the three "E"s - Economic, Environmental and Equitable social effects. As one can see, we have come back to the three important pillars of Planning.

Now this could be the reason why today we have Environment and Planning incorporated in the same portfolio of the Malta Environment and Planning Authority. This shows that the Political level is giving more importance to the Environmental aspect of Planning. But let's never forget that Environmental considerations are just one aspect of Planning, and through such an amalgamation, now being proposed to also have one Act, the other two aspects of Economic and Social considerations will continue to be further relegated to a lower division in Planning decision making and taking.

Environmental Impact Assessments

What should we say - EIA, EIS or EPS? For some this is quite obvious, but for many others, these terms are quite confusing. An EIA is the whole process - it is the assessment process from start to finish. On the other hand an Environmental Impact Statement (EIS) and an Environmental Planning Statement (EPS) are the studies themselves. These are the "Statements" prepared by the professionals carrying out the EIA. An EIS is usually prepared for more complicated projects whereas an EPS is prepared for simpler projects.

As the legislation stands today, the EIS is paid for by the proposer of the project, but the consultants sign a declaration of impartiality and need to be approved by the MEPA. The present legislation calls for a list of such consultants to be drawn up. Each EIS needs to include a Coordinator and a number of specialized consultants. Without removing any merit from that of the specialized consultants, the EIS Coordinator has the most important role, as his/her job is to coordinate the inputs of all the other consultants, formulate the EIS, relate directly with MEPA, and be present and reply to questions raised during the Public Consultation exercise. The coordinator needs to be a generalist, with very good knowledge of the respective fields, good coordination skills and most importantly, a good understanding of Planning (not just Environmental) issues. With the proposed reform, this list will be published for one and all to know who can be contacted to do such work, and the list will be revised every year according to their performance.

Unfortunately, the EIA process has developed into a lobbying football. Developers take it for granted that all effects of their proposals can be rectified through mitigation measures. Environmentalists, on the other hand, use the EIA process to shoot down all applications which need an EIA, whatever their impact on the environment. This leaves us with a 1 - 1 draw. Through the adoption of extremist attitudes, both lobby groups are being taken with a pinch of salt by decision takers. Where development should be permitted, more mature lobby groups try to get a development with the least impact on the environment. In the long term, this will benefit both the developer and the environment.

Economic and Social Impacts

As its name implies, the EIA process has tended to concentrate on the Environmental (Physical) aspects of the development being proposed. However, that only satisfies the Environmental aspect of Planning. MEPA realizes that this is an issue, and sometimes makes half-hearted attempts to include the other aspects of Planning into the EIA process. Sometimes, the EIA process includes some form of economic assessment. Now, one would argue that if the project is not economically feasible, then the developer would not even consider doing it. However, economic feasibility depends among others, on intensity of development and market changes. We have all heard about White Elephants, and we can assume that their proposers had carried out some form of economic feasibility studies. The whole point is that it is very easy for the developer to withhold confidential information, without which a proper assessment cannot be made. The only way to do this is to exclude the Economic assessment from the EIA process and get independent advice about the feasibility of the project. Half hearted attempts will not convince anyone.

It is very rare for an EIA to consider Social impact. The concept itself has only developed recently, even abroad. However, this does not diminish from its importance. The assessment of Social impact is truly in its infancy in Malta. As in the case of Economic impact, assessment independent of the EIA procedure needs to be carried out.

Do we need all this?

If we are serious about carrying out proper Planning, then the only conclusion is that yes, we do. Planning needs to take Environmental, Economic and Social considerations into account. Environmental considerations alone are not conducive to good Planning. Any approved development will have an impact on the public in general, and it is our responsibility towards future generations to encourage positive projects and discourage negative ones. A few years back, who would have taken the EIA process for granted? Today, many people do.


Perit Vincent Magri is specialized in Land Use Planning, having graduated from the University of Malta and the University of Newcastle-upon-Tyne. He has worked in Planning since 1988, both as part of the Planning Directorate in the early days of Planning in Malta and in the Private sector. He currently forms part of the team at Mangion, Mangion and Partners (Architects, Civil Engineers and Planning Consultants) - and can be contacted on vmagri@mmp.com.mt or 21336704