Does the Planning Authority analyse the impacts of development? A minimalistic perspective would argue that it does. The Authority consults with stakeholders such as the Environment and Resources Authority, the Superintendence of Cultural Heritage, local councils, NGOs and the public. It appoints case officers for each application, it obliges applicants to conform to standard requirements and it duly files all necessary information.
When necessary as required by law, the authority carries out environment impact assessments and it approves experts involved in this regard.
But policymaking is not only about observing established procedures and championing them as if they are foolproof. Judging by public concern, civil society activism, political controversy and media coverage of developments, there is a growing concern on the ramifications of development in Malta.
This calls for more comprehensive tools of analysis of development proposals. I am proposing some basic indicators which can be adopted by the Planning Authority to give due importance to evidence when deciding on specific development applications.
To begin with, when the size of an application is defined, this should be based on realistic assumptions. Measurement should go beyond the area of the specific proposal. Thus, if for example a proposed development does not qualify for an environment impact assessment but is physically close to other development proposals, the cumulative impacts of the proposals should be considered holistically.
This would require more comprehensive methodologies than those currently in place. The latter are heavily tilted towards the requests of individual developers. A recent example is Malta’s rural development policy, which is resulting in approval of many individual projects which are altering Malta’s countryside.
Development proposals should include comprehensive economic impact assessments. As things stand, the authority assumes that each applicant is making a risk through his or her proposal, and that it is not the authority’s business to look further than that. But a comprehensive economic impact assessment would go beyond this and analyse, for example, the impacts of massive commercial development in a locality already characterised by ample commercial activities.
Social impact assessments should also be mainstreamed as a key feature of development proposals. These should include quantitative and qualitative surveys of residential needs and concerns, community profiles, social indicators, thorough consultation with stakeholders as well as enforceable proposals for mitigation and compensation measures.
Social impacts under analysis should also include waste management, health impacts, noise, lifestyle and cultural factors.
Traffic impact assessments should go beyond counting of cars and should give equivalent importance to parking plans, alternative means of transport, quantification of health impacts due to pollution and economic impacts of traffic congestion.
When ecological factors are concerned, seasonality is a key concern. This is due to possible impacts on flora and fauna, biodiversity, and marine habitats.
In sum, impact assessments should be continuous processes, and not one-off exercises. This requirement is ever more timely when continuous change characterises Maltese society. Reporting back to authorities, communities and other stakeholders should be a key feature in this regard.
In order to ensure reliability and validity of impact assessments, they should be compared with other assessments and actual development so as to identify good and bad practices. Independent peer-review would also help ensure that proper research methods were used to gather the required information.
To be fair to the Planning Authority, some of the proposals written in this article do form part of its decision-making process, but it is not the first time that the same authority was criticised for giving minor importance to very important evidence. This situates the whole development process into another dimension: the political.
Indeed, one may argue that even with the best available evidence possible, the institutional autonomy of the Planning Authority leaves much to be desired due to excessive political interference.
I would be the first to agree with this argument. But robust evidence on development proposals can help expose and disarm political excesses.