Din l-Art Helwa comments on the draft Paceville Master Plan, sent to the Planning Authority on 23rd November 2016


  1. A master plan should primarily address the needs of the entire community for the area, harmonizing them into one vision and also providing a positive effect on the rest of the country. While Din l-Art Helwa favours the development of master plans, it holds that the draft Master Plan for Paceville has failed this basic test.
  1. Furthermore, Din l-Art Helwa strongly objects to the process that was followed in the development of this draft Master Plan. Transparency was totally absent and developers and speculators were apparently allowed to use what is supposed to be a ‘public interest’ process to further their direct financial interests. The submissions of nine developers were taken on board behind closed doors at the earliest stage of the drafting process while the interests of all the other stakeholders were ignored. Not only were the needs of the community and the common good not taken into account but the property of others was used as a ‘free’ resource to facilitate these nine developments. The potential for regeneration of the streets and existing buildings of the area was not even considered.
  1. Din l-Art Helwa also questions how Paceville was prioritised for a Master Plan exercise, at a cost footed by the taxpayer, when more important sites in Malta are clearly in dire need of regeneration. Good governance advocates that areas in need of regeneration are targeted for study before addressing commercial private interests as seems to be the prime objective of this draft Master Plan.
  1. It is therefore the considered opinion of Din l-Art Helwa that the draft Master Plan for Paceville should be withdrawn immediately. Din l-Art Helwa also calls on the Auditor General and the Ombudsman to enquire into the process followed by the Government and the new Planning Authority and determine whether the public interest has been adequately served and safeguarded.

Governance issues

  1. When drafting a master plan, the Government and Planning Authority should ensure that:
  • the public interest is paramount;
  • transparency is absolute;
  • a wide, open consultation with existing stakeholders, including residents and businesses in the area, should be carried out a priori to determine the needs and aspirations of the community;
  • detailed professional studies are carried out on all aspects related to transport and utilities;
  • consultations with the transport, land and utility operators – and the regulating entities – be carried out at the earliest stage of the drafting process;
  • all submissions and studies should be published and made available together;
  • master plans are to be developed within the national needs for increasing both housing and commercial space. To simply create more buildings without assessing the national need will lead to the creation of a development bubble;
  • master plans must also address the type of influx of residents – are these full time residents, where do these people work, what is the mix of resident vs commercial, how possible is it for the people living in these buildings to also work within walking distance? The area must be studied as a whole in order to create the right mix of residential vs commercial area and also alleviate existing transport problems rather than create new ones;
  • public land should be given back to the public as open spaces and not handed over to developers for speculative real estate projects;
  • pedestrianisation and energy efficient buildings are to be encouraged.
  1. At a strategic level, it is important that a realistic phasing of the parts of all large developments is studied taking into consideration the capacity of the island to handle such major construction, the length of time where an entire area of the island becomes a building site and the impact of this major building site upon the island including the impact upon both the local communities of the area and the commercial entities of the area.
  1. Studies are required for all large developments to measure the total amount of energy and water that such projects will require both during development and when they are finalised and then determine whether the country can indeed sustain large increases in energy and water demand.
  1. Din l-Art Helwa regrets that all of the above are missing from the draft Master Plan for Paceville.

Specific points related to the draft Paceville Master Plan

  1. The following is a non-exhaustive list of points which specifically apply to the draft Paceville Master Plan:
    1. the nine major development proposals that have been incorporated into and heavily shaped this plan have not been published;
    2. the draft fails to accurately measure the impact upon the national infrastructure;
    3. the infrastructure of the area cannot cope with an increase in population of 7,000 within a few years, as is being proposed in the draft (experts in fact claim that the increase in population will be more than 9,000);
    4. the principle of equity should prevail both for those receiving compensation as well as those who are receiving benefits and advantages, and most importantly government draconian powers, such as expropriation, should not be used in the interest of specific developers to give them a privileged status over other property owners;
    5. all infrastructural requirements should be costed and apportioned to the main beneficiaries of the project. The developers should carry the main burden of this cost and the Maltese taxpayer should not pay for the infrastructural costs which will run into €100s of millions which would otherwise be spent upon social welfare, health and pensions, as well as environmental improvements such as alternative energy solutions, protection of ground water, etc;
    6. the draft Master Plan mentions the provision of community services but does not provide any details;
    7. guarantees must be in place to ensure that all aspects of implementation are handled together in a holistic manner and that the few public benefits in the draft Master Plan do not lag behind or never materialise.
  1. A professional national risk analysis for this draft Master Plan is required which measures the following in both the short term and the long term:
    1. environmental impact;
    2. impact upon financing;
    3. impact upon provision of housing elsewhere;
    4. impact upon other regeneration projects;
    5. a development bubble;
    6. lack of adequate infrastructure;
    7. impact upon society/communities, etc.


Proposed Portomaso reclamation

  1. The proposal for land reclamation at the Portomaso site is entirely unjustified and should be eliminated altogether. This will only serve to degrade the land and marine environment while increasing traffic and other infrastructural pressure to the area. With the amount of development being proposed for the Paceville area through this draft Master Plan, the construction of further apartments or hotels through land reclamation cannot be justified. Furthermore, the seabed is part of the public domain and should be safeguarded. The proposed area for land reclamation is also in the vicinity of a Marine Protected Area.
  1. The draft Master Plan describes a high to low skyline which is then contradicted by the height of the building upon the area to be reclaimed at the Portomaso site. Din l-Art Helwa objects to this land reclamation proposal in principle but it is also concerned that skyline studies have not been given due importance.

The Cresta Quay proposal

  1. The proposed development at Cresta Quay is obviously far too close to the coastline and will only benefit the owners of the development to the detriment of everyone else.