The followup to the 7th September Protest

Contents

Introduction…………………………………………………………………………………………………………. 3

The Proposals…………………………………………………………………………………………………………. 5

Section 1 – Policies………………………………………………………………………………………………. 5

Section 2 – Authorities Responsible for the Environment and Planning…………….. 11

Section 3 – Large-Scale Projects………………………………………………………………………. 15

Section 4 – The Regulation of the Construction Industry……………………………………. 16

Section 5 – Roads and Transportation………………………………………………………………… 19

Section 6 – Respect for our Planet, our Country, and Ourselves……………………….. 21

Conclusion…………………………………………………………………………………………………………. 23

Introduction

The well-attended protest named Iż-Żejjed Kollu Żejjed (Enough is Enough) was held in Valletta on the 7th September, eve of Victory Day, culminating in a series of speeches from activists and residents from all over Malta in front of the House of Parliament.

The choice of bringing people together in front of Parliament on the eve of a public holiday was far from casual: Iż-Żejjed Kollu Żejjed provided a much-needed space for many citizens who have grown disillusioned about politicians’ will to do something about the tsunami of excessive construction that has drowned our islands. We, together with thousands of citizens, understand that governments prioritise the economy; we feel, however, that the economy should not depend on a single sector (ie construction) while coming at a very high cost to residents, taxpayers and citizens across the islands.

This high cost is quantifiable in pressure on the environment and open spaces, pressure on resources such as space and sunlight, air quality, pressure on the road network, pressure on our biodiversity, and in some tragic cases, it has left people homeless, having to bear the psychological and financial burden of the ill deeds of the construction lobby.

In addition, the mass of protestors in Valletta was vociferous against the flagrant abuse in construction permitted by porous institutions such as the Planning Authority and the Building Regulations Office, which are often understood and seen as subservient to the Malta Developers Association and its satellites, as well as large business groups and conglomerates who often behave like they rule the island.

The crowd at Iż-Żejjed Kollu Żejjed was also making its voice heard because it has had enough of a situation where the country, its institutions and democratically-elected representatives are enslaved by these unelected groups.

However, we believe that this protest is not an end in itself or a mere show of force. In the run-up to and in the weeks following the 7^th September, we have consulted with other NGOs and resident groups on a set of proposals that can directly improve the quality of life of thousands of Maltese citizens. The proposals in this document are the direct result of those consultations, including technical and legal advice, and of a public forum held in the last week of August whereby we invited citizens to submit their ideas on how to make our everyday lives easier.

None of these proposals is a burden on the economy; we believe that the 125 proposals contained in this document will constitute a step forward for both residents and construction industry, resulting in a cleaner, more transparent and serious way of doing things.

Some of these proposals delve into the composition of the much-maligned Planning Authority and its boards, methods of reducing the congestion caused by construction works, the introduction of measures to safeguard residents from nearby works, and a more environmentally conscious way of drafting policies for the present and the future of our islands.

In line with our six main areas of focus, we are thus presenting a set of proposals for each area, with the signed endorsement of a number of groups who have participated throughout this process.

The Proposals

Section 1 – Policies

Protest Demand I

Most planning policies are designed around the interests of the few, instead of public wellbeing and environmental protection. As a consequence of this, our country has been besieged by senseless development which is destroying the natural environment and ruining our quality of life at an alarming rate.

In this regard, we call for:

General Provisions

The introduction of open spaces in our towns and villages in areas where they are accessible and enjoyable to everyone. The consistent disregard for obligations, already existing within the current policies, regarding open spaces should stop and these policies should be properly enforced;
The grading of definitions such as “dilapidated”, “derelict” and other common descriptions used in PA applications, so as to create more transparency in the planning process;
Environmental Impact Assessments and Social Impact Assessments to be mandatorily commissioned by the Planning Authority, and not by the developer as in current practice, with the latter remaining responsible for the funding of these studies;
The setting up of a public registry of consultants, as currently provided by law, responsible for the carrying out of the above-mentioned EIAs and SIAs. Consultants should be graded according to the accuracy of their studies, and those found submitting incorrect or misleading information should be disqualified from drafting similar studies; in situations where conflicts of interest arise, harsh penalties should be applicable;
The introduction of a moratorium on areas earmarked for rationalisation in 2006 until a set of comprehensive masterplans are in place so as to guarantee quality urban areas;
The revocation of a clause in the Development Planning Act which states that, when determining whether to approve an application, the Planning Board shall have regard for “surrounding legal commitments.” This clause empowers the planning board to disregard policy and approve applications in an ad-hoc and arbitrary manner, thus defeating the purpose of the planning system;
The facility for registered objectors to ask for the determination of a permit to be suspended while a policy is being reviewed;
A change in praxis whereby no reply from an external consultee should not be construed to mean ‘no objection’;
The removal of Outline Development Permits from their status as a legitimate type of development permission, since this allows planning policy to be circumvented;
Stringent provisions to ensure that that the rule regarding the restriction of deferrals, before an application is determined, to no more than one, is respected in practice;
The development of policies through meaningful public participation which goes way beyond the simple submission of online feedback by the general public;
The removal of illegal developments instead of their sanctioning. The above notwithstanding, the Planning Board should not have any discretion on whether to dismiss an application when an enforcement notice is present on the site and the applicant has no intention to rectify the illegality; in this case, the application should be simply dismissed. The sanctioning of illegal developments in ODZ areas should also be banned;
The introduction of time-limits within which an enforcement order is to be issued following a complaint and/or dismissal of appeal. There should also be time-limits within which direct action for the removal of illegality must be taken;
The removal of illegal developments prior to the submission of any development application;
Any PA permit should only be valid for a maximum of five years. Applications for the renewal of elapsed permits should not be accepted.
ODZ policies to apply to the marine area around Malta including the presumption against any residential and commercial developments on reclaimed areas.

Rural Policy

An immediate revision of Rural Policy, without unnecessary delays, with applications to be decided under this policy frozen until the new policy is introduced. The new policy should:
1. Amend current provisions on redevelopment and change of use of existing buildings ODZ, in a way that such redevelopment is only allowed if the applicant can prove that the building is covered by a development permit. The policy should also ensure that the building will be used for genuine agricultural purposes;
2. Prohibit any extension to an existing ODZ dwelling;

Prohibit the construction of swimming pools in ODZ;

Prohibit new boutique wineries on ODZ;
Prohibit ODZ animal enclosures for research, educational, sport, leisure and exhibition purposes;
Restrict new dwellings to within the curtilage of farms or around their boundary to a floor space of no more than 150sqm and limited and to one dwelling per farm, whilst completely prohibiting development in sensitive sites;

Restrict the size of the stores, with respect to the square meterage of actually farmed land, to avoid the construction of excessively large stores;
Restrict construction done under the pretext of agro-tourism, so that any redevelopment maintains the same footprint and floor space of existing structures. No new service roads should be built to accommodate redevelopment;

Define the term “national importance” so that this is limited to wholly public projects which serve a public interest;
Policies regulating the reconstruction of rural buildings should be limited to buildings covered by a legal permit, which have collapsed in past 5 years, and should be limited to the current footprint and floorspace of the building prior to its collapse, as documented in the most recent aerial photography;

Urban Conservation Areas

Better and irrevocable protection of UCAs, with special regard to vernacular & scheduled buildings;
The extension of the general presumption against demolition of scheduled and vernacular buildings to include buildings of heritage value which contribute to the character of an area;
The full protection of gardens located in UCAs and the designation of more green enclaves within village and town centres. The owners of such gardens should be incentivised to open these areas for the enjoyment of the public.

SPED Policy

An update of the SPED policy whereby a number of loopholes, including but not limited to the following, are removed:
1. Re/development in ODZ areas such as the construction of villas under the pretext of agrotourism and the transformation of ODZ areas into Areas of Containment;
2. The promotion of private beach facilities;

The creation of additional yacht marinas without restriction in the size and location of such facilities;

The basis for various mega-projects in Gozo;
The broad meaning of the term “national importance”, which should be limited to public projects that serve a public interest;
The removal of point 1 within Urban Objective 3 that may reopen the rationalisation exercise.

To commence work on a new policy replacing SPED, with a long-term view up to 2050, which encompasses Malta’s various commitments such as but not limited to the UN SDGs, and establish stepped targets on how to achieve these at a spatial level;
The establishment of milestone dates for phased implementation of the SPED directions with a clear strategy for the future.

DC2015 Policy

The improving of the “context driven approach”, with reference to the DC2015 policy:
1. Extent of Commitment: the definition of legal commitment must be reconsidered such that it only recognises existing legal developments that are in line with current applicable policies. Anything counter to this effectively renders the whole planning system superfluous;
2. Transition Design Solutions: the rewording of this policy to avoid creative interpretations thereof, particularly in the case of UCA building heights in zones bordering non-UCAs in order to ensure that building heights conform to UCA regulations.
Amendments to the transitional design policies section within DC15, thus removing the possibility of further buildings outside of development zones under the pretext of “transitional solutions”;
The immediate revision of the building heights policy as introduced by Annex 2 of DC15 to halt the building of 5/6 floors in certain areas that are, or will be, impacted in a negative way after taking into account their social, environmental and heritage context;
Heritage buildings to be considered as such and not as infill plots, therefore prohibiting their increase in height to the height of adjacent buildings.

Tall Buildings

The revocation of the policy which allows developers to build twice the height stipulated in local plans provided that they create more open spaces, at least until a clear definition of “open spaces” is given. Such open spaces should consist of facilities available to the public (e.g. gardens), and not of private spaces used as outside catering establishments;
The revocation of the Height Limitation Adjustment Policy for Hotels, while applications for the construction of tall buildings should be processed exclusively by the FAR policy;
The revocation of the Height Limitation Adjustment Policy for old people’s homes and the zoning of areas dedicated to this public purpose;
The retention of industrial areas for industrial uses to avoid their sprawl in other zones (e.g. residential areas);
The introduction of minimum site area for high-rise development in high-rise areas, without exceptions;
The removal of any possibility for high-rise developments in medium-rise areas;
The requirements of the FAR policy should be enforced and not approached in a piecemeal fashion or on a case-by-case basis.

Scheduling

The protection, in their entirety, of Grade 2 scheduled buildings without the possibility for developers to demolish protected buildings while retaining the facade.
The PA’s Executive Council should not be the Board deciding on the scheduling or de-scheduling of heritage;
Local councils to be given the power to commence the scheduling of buildings in their locality. Upon request by a Local Council, the PA should be obliged to start assessing the application for scheduling in a transparent manner;
A new scheduling procedure to apply to particular landscapes, landmarks (including trees and walls) streetscapes and neighbourhoods which are rooted in collective memories;
Malta to fully ratify the European Landscape Convention and commence detailed studies of micro landscapes and streetscapes that require protection, with such a process involving social scientists;
The process of the de-scheduling of properties and other landmarks to be transparent and standardised, published duly on the government gazette, websites and other forms of media forms, whilst allowing the public to make formal representations;
Scheduling orders should not be suspended until the decision on an appeal is taken, but de-scheduling should be suspended until the appeal is decided.

Solar Rights

The compensation of residents for the loss of sunlight in their homes by giving them the legal right to install photovoltaic panels even if these residents do not have ownership of the airspace. In instances where the level of shading exceeds a level pre-established by a competent authority, and that this issue cannot be rectified by the repositioning of the solar energy system on the same roof, the developer should be obliged to compensate the owner of the solar energy system. A percentage and monetary value should be assigned, at which the effect on a solar energy system would be deemed to be ‘significant’ and which would require compensation by the developer of the adjacent property. Such values may be calculated on a case-by-case basis according to the surface area and generation of energy of the solar energy system concerned;

Residents may also be compensated from a national renewable resources fund, funded by development contributions.

Section 2 – Authorities Responsible for the Environment and Planning

Protest Demand II:

The authorities entrusted with safeguarding the environment and planning are run with a blatant lack of transparency, responsibility and independence. It is clear that most of the decisions taken by these authorities – decisions that impact us strongly and directly – have already been taken behind the scenes, away from the public eye. It is unacceptable that certain groups with economic and/or political clout are allowed to ruin our lives and environment by pulling the authorities’ strings for their own benefit.

In this regard, we call for:

Composition of the Executive Council

The inclusion of an NGO representative on the PA’s Executive Council to ensure transparency and adherence to the Authority’s mission statement.

Composition of the Planning Board

The Planning Board should be comprised of a total of 13 members, subdivided as follows:

One representative nominated by the Government;
One representative nominated by the Opposition;
Two members from the ERA;
One representative from the Superintendence of Cultural Heritage:
Two representatives nominated by non-governmental organisations;
One representative for each Local Council affected by the application in question;
Five members appointed following a rigorous process as follows:
- Parliament issues a set of criteria for the eligibility of these members, including experience in the field and their understanding of policies;
- A consultation process is issued whereby nominations of persons to sit on the board are received;
- A Parliamentary committee assesses the nominees and their eligibility in an open sitting;
- The eligible members will be interviewed by a parliamentary committee in an open sitting;
- Five candidates will be shortlisted after this parliamentary interview;
- The shortlist will be submitted to a parliamentary vote where nominees will require a 2/3 majority to be approved. One of these five members will be nominated as a Chairperson. If parliament fails to elect the board members via the 2/3 majority method, the whole process will be repeated with a simple majority vote;
- This board is chosen every 5 years.

The possibility for Authorities to send replacement members to Planning Board meetings whenever the corresponding appointee is unable to attend;
PA Board members should be held personally responsible for their conduct, especially in terms of breaching policies, their own code of ethics, deciding against the common interest, conflict of interest, undue influence and other improper behaviour. The public should have recourse to a legal system where these members can be personally sued for their misdeeds;
Decisions relating to conflicts of interest to be taken by an independent ethics board appointed by the President of the Republic and should not be at the discretion of a Minister;
Meetings involving planning control applications and meetings between the Executive Chairperson and the Planning Board should be open to the public to guarantee transparency in the functioning of the Planning Authority;
The creation of a board for building standards and aesthetic standards.

Composition of the Planning Commissions

The ERA to be represented on the Planning Commission by a member for each of the Commission’s divisions: one for the regularisation of applications, one for the handling of Development Zone applications and another for the handling of ODZ applications. These divisions should not hear cases from one area exclusively, and should be assigned by lot;
The ERA to present a report on all applications presented in ODZ. In the case the Planning Commission intends to overturn the ERA report, it should postpone taking a decision until the following sitting. The Superintendence for Cultural Heritage should have similar powers with regards to applications in UCAs or abutting on UCAs;
Planning Commission and EPRT members should be appointed on a full time basis and chosen via the procedure in point 45, including a Parliamentary grilling;
Local Councils to be granted a vote on EPC boards whenever they request to participate in proceedings.

EPRT Appeals

The capping of appeal fees at a maximum of €500 for all registered objectors for all projects;
The suspension of a permit should be automatic until the appeal is final.
The granting of 15 days to registered objectors to register themselves as interested third parties in appeal proceedings filed by the applicant.

Submission of Development Applications

The creation and mandatory use of a standard template for PA application wording to provide more complete details, more clarity and ease of comprehension in the summary application;
A ban on the practice of splitting a single project into numerous, smaller applications to evade a holistic assessment of the project;
Permit conditions and plans to be entrenched for a 10 year period from the issue of a permit. During this period, no planning applications can be presented to modify any of the conditions and plans approved;
The inclusion, upon presentation of fresh development plans during the period between the submission of an application and its hearing, of a description of all the changes carried out by an applicant from the previous set of plans, in a clear manner and using language accessible to everyone. Moreover, as already required by law, fresh plans can only be submitted up to no less than 15 working days before the permit hearing. The public should always, without fail, be notified and allowed to make additional submissions on the final plans during those fifteen days;
The restriction in the definition of material change in order to avoid abuse through the use of minor amendment procedures;

Information

Correspondence, emails, formal and informal meeting minutes and any other information including submitted designs to be made publicly available at all times, free of charge;
Renders and photomontages to become a requirement for all applications, and these should conform to PA’s Best Practice Guides;
All information related to planning should be easily accessible throughout all stages of the application, including those deemed as “incomplete”, from presentation to the final stages.

General Provisions

Stringent provisions to ensure the respect of rules determining whether an application should be heard by the Planning Commission or the Planning Board, to prevent such decisions from being taken in an ad-hoc or non-transparent manner.
A detailed reason must be given for the refusal, by the Commission or the Board, of ERA objections. The ERA should present a final report on all applications.

Section 3 – Large-Scale Projects

Protest Demand III:

Communities around Malta and Gozo are under attack from proposals for massive developments that have no respect for either residents or the environment. These large projects are having a devastating impact on our quality of life, since they lead to a massive increase in congestion, pollution and noise, as well as usurping the air, light and space from our neighbourhoods. The proliferation of these enormous projects, such as the dB Group’s project on the site of the former ITS, is being carried out without a holistic plan or evaluation of the cumulative impact which these towers and globs of building will have on people and the natural environment.

In this regard, we call for:

General Provisions

The investigation by competent authorities, such as but not limited to, the FIAU, of the source of wealth of developer/s proposing massive construction projects of a size of and above 2000 square meters;
A moratorium on large-scale projects until both a national and localised masterplans are enacted;
A detailed urban design study or character appraisal of the locations chosen for high-rises;
The identification of detailed boundaries or specific areas within the appropriate localities and an assessment of a maximum capacity limit within these areas;
The specification of suitable maximum heights for the different areas;
The reversal of the Height Limitation Adjustment Policy for Hotels, while the construction of tall buildings should be handled exclusively through the Floor Area Ratio policy;
Local Councils affected by major private projects falling under Schedule 1 should have the power to impose a condition on a permit to the effect that the development must be approved by a referendum of citizens registered in a given locality, which is to be held within 30 days of the permit being approved by the Planning Board.

Section 4 – The Regulation of the Construction Industry

Protest Demand IV

Dust, danger, noise, broken pavements, illegal dumping of waste – this is a daily reality for thousands of people in our country, and all this because of the lack of control over the construction sector. In a few months we’ve seen buildings crumble and numerous workers dying in various construction sites. The response to all this has been completely inadequate. Residents are still carrying the responsibility, the psychological and financial burdens (as well as effects on their health) to ensure they won’t be buried alive because of construction works next door. This is a ridiculous and unacceptable situation, just like the lack of systematic and persistent lack of enforcement.

In this regard, we call for:

General Provisions

The introduction of a tax on incomplete building projects;
The revocation of the agreement of October 2018 between the MDA and TM whereby construction works involving heavy vehicles in secondary roads are allowed to commence at 7.30am.

Contractors’ Registration

The regulation and registration of contractors. A contractors’ register must be created with criteria for the licensing and classification of each contractor, while developers must enter into a formal contract with building contractors in order to ensure accountability.
The creation of a government-run registry of developers and contractors effectively revoking the agreement between the MDA and the BRO for the administration of this registry;
The creation of a public complaints system and a register of these complaints that ensures transparency, whereby proven repeated complaints should lead to the blacklisting of contractor/developer by the use of a points system.

Issuing of Permits

A consideration of the number of construction permits issued in a specific area by the PA. Where these involve the use of heavy vehicles and machinery for purposes including but not limited to demolition and excavation works, a delay of the commencement of works by a suitable period of time should be imposed so as not to inconvenience residents with an excessive amount of construction work in their area;
A limit on the number of road closures and parking slots stolen from residents.

Health and Safety

A set of laws that impose decent standards to safeguard the residents’ health and safety in areas close to construction sites;
A serious enforcement of the laws regulating construction, to give, without exception, protection and dignity to workers and residents alike;
The amendment of the law to allow no more than 8 hours of construction work during the day, commencing from no earlier than 8am;
Repair works to pavements to be rebuilt or fixed at the developer’s expense if a developer damages the pavement during construction works;
The placing on developers and contractors of the responsibility for any accidents that may happen while construction works are taking place;
A change in the framework whereby affected residents are made to pay costs for legal, psychological and logistical support if accidents happen to their detriment;
An ongoing audit of all construction sites in activity;
Risk assessments to be carried out when handling construction waste so as to minimise particulate matter emissions;
Any costs incurred by residents in ensuring their own safety should be billed to the developer;
Developers should, without fail, provide accommodation of a decent standard to families and residents who lose their property as a result of construction accidents, and at their own cost.

Workers’ Rights

The provision of adequate resources to the Occupational Health and Safety Authority (OHSA) and to the Department of Industrial and Employment Relations (DIER) to ensure that construction workers are not exploited. The exploitation of workers should be heavily penalised and contractors who exploit workers should have their license to operate withdrawn;
Employers in the construction industry to be legally obliged to pay accident insurance for their workers. This measure:

ensures that workers who suffer injuries receive compensation in a speedy manner;
puts the responsibility on contractors and developers to uphold health and safety standards, since insurance companies will not accept to pay claim settlements for sites that do not conform with these standards.

Section 5 – Roads and Transportation

Protest Demand V

Our country is besieged by a frenzy of tree-cutting and the destruction of agricultural land sacrificed to road widening and construction. We’ve been told these should reduce traffic and travelling distances; however, studies worldwide have shown that road construction and widening do not solve the traffic issue. The studies carried out by the Maltese authorities confirm this clearly: no new road will save the country from gridlock, unless there’s a shift to alternative means of transport. In spite of these studies, we face a lack of serious investment in these alternatives, such as efficient public transport and infrastructure for cyclists. In the meantime, millions are being spent on new roads that will not solve the issue.

In this regard, we call for:

Public Transport

The introduction of a free and efficient transport system through sustained investment in the public transport service, which aims to operate as a service for the common wellbeing instead of turning a profit;
Shorter, more frequent, bus routes including the use of smaller buses, to assure the public that no bus trips are missed under any circumstance;
The introduction of additional routes and night routes to encourage bus use;
The introduction of efficient and frequent marine public transport from busy locations, offering stops along the route. Such routes should exclude bathing areas.;
The introduction of more bus lanes to ensure that public transportation is not caught in traffic congestion.

Commuting

The introduction of a Differentiated Car Pooling Strategy for employees of both public and private sector;
The provision of pooled transport to staff of private and public sector entities;
The introduction of schemes to encourage employee-friendly measures such as flexible hours and teleworking which would reduce commuting, and therefore pressure on the road network system;
Enforcement on school transport vans and buses so that children are picked up for school at a decent hour of the day;
The removal of road license fees for motorbikes;
The lowering of the minimum age for driving a scooter (max capacity: 150cc) to 16 years of age.

Roads

The design and implementation of pedestrianised areas, one-way village roads dedicated only to buses, bikes and motorbikes in all towns and villages of Malta and Gozo;
The creation of accessible bike lanes, rebates for e-bicycles and feasible pedestrian lanes;
Better and more widespread enforcement including harsher penalties for drivers who do not abide with the law.
The repealing of the Development Notification Procedure allowing Infrastructure Malta to substitute this instead of going through the full standard planning application process.

Section 6 – Respect for our Planet, our Country, and Ourselves

Protest Demand VI

Malta’s natural resources are considered only in so far as they can turn a profit. Our country is the most built up country in the European Union with 33% of the land built up. This puts our natural habitats and biodiversity under immense pressure. Our water and air are polluted without a thought, land is taken up in ever-increasing amounts, ecosystems that flourished for generations are covered in concrete, and wildlife populations are collapsing at an accelerating rate. This short-sightedness is now affecting our health. Close to 600 peope die every year due to air pollution. There are 5 new cases of chronic asthma every single day. Our mental health is suffering, with stress and anxiety at record highs. The mantra of “money in your pocket” is ringing hollow as we see loved ones suffer, as we travel further afield to be able to unwind, and as evidence mounts that our actions are causing catastrophic changes to our planet’s natural and ecological systems.

In this regard, we call for:

General Provisions

The immediate halting of the transfer of public land and sea to private interests, giving immediate priority to the return of public land for the creation of public open spaces;
The granting of the highest protection to agricultural land so that this may be considered as non-developable under almost any circumstance. This measure would ease pressure on farmers who are being driven out of their lands from landowners who view agricultural land as a means of making a higher profit through development. Farmers should also be given all the social and economic support to continue cultivating this land, thus preventing the fall into disuse of such agricultural land, which in turn then falls prey to development and speculation;
The mandatory introduction of laws whereby buildings are built in an energy efficient manner;
The introduction of a tax on excavation based on volume, payable upon presentation of the application to the PA;
The introduction of environmental wardens;
A bigger consideration of flora and fauna in the drafting of environmental policies;
The immediate commissioning of an independent study on air quality;
The construction of rainwater storage projects to reduce water usage;
The prohibiting of tarmacking or concreting or use of any other building material on country lanes and roads so as to preserve biodiversity;
Obligations on developers and businesses to contribute to society, for example via an Environmental Causes Fund to fund environment-related projects;
A change in mentality whereby developers should re-design their developments according to green principles such as water management, green infrastructure, and the reduction of greenhouse gases. These standards should be enforced without exception, and substantial fines should be handed out so that penalties act as a deterrent. In this regard, developers committing repeated offenses should see their fines increased and run the risk of having their assets frozen and being blacklisted from public contracts. This register of non-conforming developers should be made public.

Waste

The separation of construction waste so as to encourage the recycling of material when possible;
The setting up of stone depots to recycle Maltese limestone;
Government incentives to use recycled material in construction, such as recycled concrete. Moreover, government should use recycled materials in its infrastructural projects, hence increasing demands for such materials;
Better enforcement and heavier fines for the illegal dumping of construction waste including that resulting from excavation works (topsoil, softstone, hardstone), road building works (asphalt, concrete, stone blocks, gravel) and from building waste (including mixed mineral waste, iron, wood, glass, textiles, gypsum, ceramics, plastics and others) in valleys, garigue, etc to protect the national biodiversity;
Taxation on the extraction of stone and a significant increase in taxation on the dumping of construction waste, with an end to any form of government contribution or taxpayers’ subsidy on construction waste.

Land Reclamation

An end to proposals for land reclamation projects as a solution for construction waste, particularly in view of the following:
1. The Posidonia Oceanica meadows (seagrass) which lie over large tracts of seabed at various depths around the coastline amongst other protected marine habitats;
2. Land reclamation could discourage the reuse and recycling of waste;

Such projects will result in the generation of more construction waste, feeding further into a vicious cycle of demand for these projects.