by Petra Caruana Dingli
Those of you who are familiar with the Structure Plan will know that it is a pretty hefty document of 137 pages, accompanied by an explanatory memorandum of equal length and a list of diagrams. The Structure Plan is the foundation on which all our local plans and planning policies are built.
For those of you who are not so familiar with the contents of the Structure Plan, let’s take historic areas as an example. The Structure Plan contains no fewer than 18 policies, explained in some detail over six pages, which focus on historic areas alone. The rationale behind the policies is explained, and also supported in the explanatory memorandum.
So far, so good.
The government now intends to replace the Structure Plan, which was drawn up in 1990, with a new document of only 27 pages in total called the ‘Strategic Plan for the Environment and Development’ (SPED).
Just to demonstrate what this means in practice, instead of our current 18 policies on conserving and protecting historic areas, the government has scrapped the lot and replaced it with one “objective” of 37 words on “historic cores”– the equivalent of a short paragraph. Let us fondly call it our ‘Historic Cores Paragraph’.
Our new Paragraph is essentially the government’s holistic strategy and vision for the future of our historic urban areas – or ‘urban conservation areas’ (UCAs) as they are often called.
Our new Paragraph does not indicate why historic areas are important, or why they should be protected or conserved in the first place. It says nothing about the role and types of scheduling or about discouraging the demolition of old buildings. It says nothing about different kinds of historic urban areas, such as the diverse needs of quaint old village cores as opposed to important historic centres such as Valletta or Mdina which are UNESCO World Heritage sites. It does not consider buffer zones. It bypasses the idea of achieving a balance between heritage and the economic needs of the community, or the overall aim of retaining old buildings in use. I could go on.
All that our new Paragraph tells us is that ‘conservation area action plans’ should be drawn up, and that these action plans should encourage suitable small-scale businesses in historic areas, particularly tourism-related businesses. The action plans should also “facilitate appropriate housing types”, whatever that means, and control certain visual and spatial features of developments. That’s it.
Faced with our new Paragraph, it is not reassuring to note in the introduction to the SPED that it should form “the primary basis for decisions on all development and environmental permits” and that all local plans will be “obliged to take on board the SPED.”
Well, it won’t be much of a challenge for historic areas to take on board the SPED if this new Paragraph is all they have to go on.
I have already noted elsewhere that the law requires the SPED to include policies, and explanations for each of the policies. Alan Deidun has made similar arguments in recent articles. The new Historic Cores Paragraph simply does not fit the bill, and neither does the rest of the SPED.