Alternattiva Demokratika said in a statement today that is has perused the document issued by MEPA for public consultation, which document is entitled Outside Development Zone Policy and Design Guidance.

“The document proposes the consolidation with substantial amendments of current policies applicable to agriculture buildings and the area outside the development zone. 38 different policies are proposed in the said document.”

AD said that the document makes various policy proposals on the re-use/re-development of existing structures outside the development zone as well as introduces proposals for the construction of structures which have hitherto not been permissible in terms of current land use planning policy.

AD pointed out that “the document fails to quantify and localise the areas outside the development zone where structures originally constructed for agricultural purposes and are currently not in use are situated. In particular the document does not identify whether any particular area in Malta/Gozo contains any significant number of abandoned agricultural buildings.” Specifically AD said it considers it essential that a stock take of agricultural buildings which have fallen into disuse or are abandoned should have been carried out.

“Likewise no study identifying the extent of illegal constructions outside the development zone has been made available. A Policy applicable to the Area Outside the Development Zone is of little use without such basic inputs. It would have been helpful if a clear picture as to the impacts of the decline in the pig and poultry industry were documented. If such studies have been carried out they should not have been retained for MEPA’s internal use but should have been made public in order to inform consultees as to the considerations taken into account in drafting the proposed policies.”

AD said that it “it would also have been appropriate for MEPA to justify its agri-tourism proposals. The proposal to permit the construction of ten rooms not exceeding 400 square metres in area is considered excessive. It would be pertinent to point out that in Italy where agri-tourism has been encouraged and supported by the state for at least the past 25 years the average size of an agri- tourism outlet is of ten beds which approximately translates to half the size recommended by the consultation document.”

“This is being stated as Alternattiva Demokratika considers that the re-use or re-development, including the change of use of existing agricultural buildings which are currently either under- utilised or else are abandoned is positive and should be encouraged. This should apply to the proposed uses compatible with agriculture, including agri-touristic projects. Whilst such uses were previously permissible the consultation document makes this clearer,” AD said.

Alternattiva Demokratika continued by saying that it “considers that it would have been much better if the consultation document advocated the re-use of legally existing structures prior to proposing policies encouraging new construction on green land outside the development zone. Malta cannot afford the uptake of more agricultural land for construction purposes. Nor can it afford the shifting of the speculative industries from the urban to the agricultural zones. Unfortunately this is what the consultation document encourages through its various proposals encouraging the construction of new structures Outside the Development Zone.”

AD also said that “the consultation document fails to propose policies which stem the fragmentation of agricultural holdings into smaller units. In fact through advocating additional access routes to new holdings the consultation document encourages the very opposite. If the strategic importance of agriculture to the Maltese economy is to be addressed further fragmentation of agricultural holdings has to be reversed. The consultation document goes in a completely opposite direction through encouraging and facilitating fragmentation of agricultural holdings.”

“The consultation document also fails to take up proposals made in studies carried out in previous years on the generation of electricity from agricultural waste. This is an issue which needs to be addressed urgently and this consultation document was the appropriate forum for it to be addressed. Applying the proximity principle it would have been beneficial if policies are drawn up such that animal waste is no longer transported along arterial roads but is processed as close as is possible to the area where it is generated.” AD said.

“There are various agricultural areas in both Malta and Gozo where there are concentration of animal husbandry holdings. In these areas such uses should not only be permissible but should be encouraged too. This would also result in sustainable waste management practices and would be of considerable help in reducing the excessive loads on the public sewer and the three waste water treatment plants.”

AD said that it expected that the consultation document emphasises that illegal constructions Outside the Development Zone are to be pulled down. AD “further hopes that the consultation document will not be used to justify a poliferation of workshops (sprayers, panel beaters ….) or villas outside the developement zone.”

In view of the above AD said that it “considers that the consultation document requires considerable revision if it is intended to respect the principles of sustainable devlopment.”

Photograph – Alain Salvary

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