Consultation

“Sports commercialization raises concern”

Front Ħarsien ODZ has submitted its feedback on ‘A National Policy for Sport in Malta and Gozo, 2017 – 2027, MEDE’
1. The policy aims to increase public participation in sports and makes some recommendations for its commercialisation.  However many studies show that commercialization is detrimental to participation. For example, Houlihan (1997, p 177) claims that “The increasing commercialisation of sport … has often driven a wedge between elite sports and mass participation.” This conflict should be recognized and addressed at the initial stages of policy-making.
2. It is illogical to aim at making sports “self-sustainable” by promoting tourism. It is analogous to turning the Manoel into a hotel in order to promote music. If an artist rents out her studio as accommodation we cannot say she is making money through art. In the same way, by opening up the land leased to Sports Organisations to commercial activities, that is, by building hotels and shopping centres on the land that is supposed to be used for training purposes, we cannot say that we have made sports self-sufficient.
Although this might seem like a merely academic point, it is important that national policies set clear and straightforward targets and that the recommendations they propose are aimed at reaching these stated targets.
3. In their study of Sports Tourism in Malta, Weed and Bull identify several difficulties, primarily, land and water shortages (2009, 216). They also suggest that Malta might be over-reliant on tourism (2009, 209). These difficulties should also be addressed explicitly in the policy in its initial stages.
Front Harsien ODZ reiterates its view that the carrying capacity of Malta ought to be studied carefully, before tourism is promoted any further.
4. On p. 2, the list of stakeholders is incomplete. Since the policy includes changing use of public land from sports to commercial, other stakeholders include the ministry for environment, lands department, OPM, local councils and general public. Also, since the policy promotes sports tourism, the Tourism Authority ought to be consulted. Finally, academics, especially those specialised in sport, should be involved in the consultation process too.
5. On p. 28. Front Harsien ODZ objects strongly to recommendation 1(i): “Allow public land, granted for sports facilities, to be used for commercial purposes” for the following reasons:
1.       This will result in less open space, less access to public land, more traffic, and water shortages.
2.       If public land leased to Sports Organisations is not used for the purpose it was leased, then all other options ought to be considered before a decision is made regarding a new use. This could include terminating the lease and designating a wholly new purpose for the land, such as recreational public space.
3.       Front Harsien ODZ reiterate their view that a nationwide survey of land use in Malta, especially of vacant buildings, ought to be conducted before any such policies are approved, and any new facilities ought to be planned according to SPED’s sequential approach.
4.       Any such land which is Outside Development Zone must remain undeveloped.
References
Houlihan, Barrie. 1997. Sport, Policy, and Politics: A comparative analysis. London, Routledge.
Weed, Mike and Chris Bull. 2009. Sports Tourism: Participants, Policy and Providers. Second Edition. London, Elsevier.

Burmarrad Fuel Stations

A letter and joint NGO position regarding planning applications for the development of fuel stations in Burmarrad was sent to the Planning Authority and Environment and Resources Authority.

Letter to PA and ERA 17.10.2016

Position Paper – Petrol Stations Burmarrad

UPDATED: Paceville Master Plan: Front’s reaction

Paceville Master Plan: Front’s reaction

Front Ħarsien ODZ notes that a masterplan has been prepared for Paceville. We note that proposed development also includes land reclamation for real estate/hotel purposes.  According to the plan, the development on reclaimed land near Portomaso would comprise residential units over 50 per cent of the land, hotels on 44 per cent, offices on five per cent and “other” using one per cent.

Front Ħarsien ODZ opposes land reclamation for real estate/hotel purposes. In the specific case of Paceville, our opposition also relates to the fact that a marine protected area exists close to the site identified for land reclamation.

In view of Malta’s small size and the immediate proximity of localities, it is illogical to have a master plan for one area and not master plan for areas close to it.

Therefore, Front Ħarsien ODZ calls for a national master plan that comprises ecological, marine, social, economic, traffic and waste impact assessments before development proposals such as the one in question are processed.  The national master plan should be evidence-based and should have clear indicators on Malta’s carrying capacity in relation to factors such as those mentioned above.

Front Ħarsien ODZ also calls for full transparency and therefore calls for the publication of all submissions by developers to Government and the Planning Authority

VO Act Amendment – Feedback

Feedback on the VO Act amendment as submitted by Front Ħarsien ODZ and Kollettiv Ambjent.

1.  Front Ħarsien ODZ objects to a definition of ‘public purpose’ that rests upon the Commissioner’s discretion. A more objective account of what counts as public purpose and public benefit ought to be provided.  If one is aiming at a quantitative definition, then precisely what sort of things are to be taken into consideration should be specified. If the intention is simply to exclude the promotion of private benefit as a form of social purpose, then ‘social purpose’ could be redefined in such a way, and the ‘public purpose/benefit’ clause can be omitted altogether.

2.    Front Ħarsien ODZ also objects to the new definition of ‘statutes’ as regulating the operation and management of the organisations. Some organisations work better with a more fluid structure and ad hoc, democratic decision making.

PN ODZ Proposals – Front’s Official Reaction

Front Ħarsien ODZ has taken note of the proposal by the Nationalist Party which states that ODZ projects should be subject to two-thirds majority approval in Parliament. Front is proposing the following to ensure that this proposal is consistent in principle and application.
1. The requirement of a two thirds majority for ODZ projects should be an additional safeguard in those cases where ODZ development is approved by the Planning Authority following a full and transparent planning process.
2. In case of PA refusal, this should be seen as final (apart from tribunal appeal), and no vote should be taken in parliament.
3. Under no circumstances should a 2/3 parliamentary majority be sufficient for ODZ applications to go ahead, as these should always require PA approval beforehand.
4. Under no circumstance should ODZ applications be approved by a simple parliamentary majority. Should the 2/3 majority not be reached after the 3rd vote, the application will be deemed as refused.
5. The process  should complement SPED and the Planning Authority process.
6. The Parliamentary Committee for the Environment – which also comprises civil society representatives, should take part in the parliamentary process.
7. The two thirds majority requirement should also apply to any revision in development boundaries.
8. A national consultation process should define the parameters concerning which type of ODZ projects would require such approval. For example, projects qualifying for EIA should  qualify.
9. SPED should be a more comprehensive policy document so as to avoid dubious loopholes
10.  Existing policies regulating development in the ODZ should be reformed in a way that such development is further curtailed.

Terms of Reference Proposals: ODZ Kalanka Hotel

Front’s proposals for the terms of reference for both ODZ Kalanka Hotel:

1. Impact on surrounding Area of Ecological Importance during the construction phase must be fully assessed. This would include impact of transportation of the raw materials, impact of works on site.

2.Project Development Statement estimates that project would create 4019 cubic metros of construction waste. Assessment should assess impact of excavation of geological features. Impacts of proposed excavations, site levelling and site clearance should be assessed. Studies must assess slope stability and possibility of cliff collapse especially in view of interventions on Globigerina Limestone which include the excavation of a tunnel on the beach should be assess

3.Social impact on bathers and people who frequent beach should be assessed. Impact on Public accessibility should also be assessed.

4. Impact of noise during both construction and operational phase must be assessed and compared to present noise levels.

5.Proposal is located in close proximity to the coastal water body MT 112 (Ras il- Fenek to Wied ix-Xaqqa), designated under the Water Policy Framework Regulations, 2004 (Legal Notice 194 of 2004). Any risk to this water body must be fully assessed,.

6.Photomontages from different viewpoints including from the direction of the sea, are required to assess impacts on landscape character and visual amenity.

7. Impact assessment on public access to coast.

8. Heritage appraisal of nearby structures

9.Impact assessment of accesibility to heritage structures.

10. Reversibility impact assessment

11. Estimates of services required (water, electricity, drainage, infrastructure, sanitary, etc..) and the impact of this at local, regional and national levels.

12. Waste generation and the cost of attending to this.

13. Impact assessment of visual and aesthetic factors (including short, medium and long distance views).

14. Ecological design factors

15. Impact assessment of water usage

16. Impact assessment of precedence setting in terms of further development on ODZ land.

Areas Of Containment Supplementary Planning Guidance (2012) Withdrawal Of Guidance Document – Feedback

1. Front Harsien ODZ objects to proposed legislation. Applications on AOCs should not be determined by an outline permits but by local plan revision.

2. In view of limited ODZ space, AOC should address national priorities and their use should be determined following public consultation and a transparent process. Applications should only be presented after such a process.

3. AOC should address collective needs of Maltese society and not of individual owners.

4. ODZ exceptions should not be extended from current state of affairs.

5. Local plans should not be relagated in importance.

6. SPED sequential approach should be followed.