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CIR 06/25 | Sanitary Regulation tolerances in Minor Amendment Applications

1. Purpose

This Circular serves to notify members of an important procedural update communicated to the Council of the Kamra tal-Periti by the Executive Chairperson of the Planning Authority. This update forms part of broader discussions on regulatory efficiency and the streamlining of policies and regulations currently being held between the Kamra tal-Periti (KTP) and the Planning Authority (PA), as well as between the National Building Council (NBC) and the PA.

 

This Circular is to be read alongside Directive DIR 05/25 on the reporting of measurements in compliance checks.

 

2. Procedural Update on Tolerances in Sanitary Regulations

The Planning Authority has adopted a new internal procedure concerning the application of the Development Planning (Health and Sanitary) Regulations (S.L. 552.22).

  • Under regulation 4, the Planning Authority may, at its discretion, permit dimensions that are lower than those stipulated, provided that compensatory measures are in place which achieve an equivalent sanitary outcome.
  • Examples of compensatory measures include the provision of a larger external aperture in lieu of a smaller aperture originally specified.
  • This internal procedure applies only in the processing of minor amendment applications – that is, applications filed by periti to amend a planning permit so as to reflect the as-built situation.
  • As part of this procedure:
    • Discrepancies of up to 2cm may be processed directly by planning officers.
    • Discrepancies greater than 2cm will be escalated and decided upon at Director grade or higher.

 

3. Important Clarifications

Periti are reminded of two key points:

  1. This tolerance procedure applies exclusively to the sanitary regulations contained within S.L. 552.22, and only within the specific context of minor amendment applications. It does not extend to other planning regulations, policies, or application types.
  2. Proposed drawings submitted with planning applications must continue to conform fully with the prescribed regulations. The discretion allowed under this internal procedure relates solely to the assessment of as-built minor amendment applications and does not in any way diminish the requirement for conformity at the original application stage.

 

Conclusion

Members are to take careful note of this update in their professional practice. The Kamra will continue to engage with the Planning Authority and the NBC to ensure that these procedures are applied consistently, transparently, and fairly across all cases, and that further progress is made in streamlining and improving the regulatory process.

 

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CIR 04/25 | Commencement of Works, References for Contractors, and Design of Lift Shafts

The Council of the Kamra tal-Periti would like to bring to your attention the following updates.

 

1. Commencement of Works

Following a successful testing period, the BCA has fully transitioned to the digital site management responsibility form, which is accessible through its dedicated portal. We are informed that the initial issue of partnerships not appearing in the drop-down lists has now been conclusively resolved.

A number of partnerships have, however, requested that a dedicated login and delegation system be created for them, similar to what is available on the PA’s planning portal. At present, partners within a partnership are required to create delegations through their personal logins. While this has no bearing on liability – since liability is derived from the form itself, which is published on eApps – the Kamra has opened discussions to explore the possibility of introducing partnership logins as well.

 

2. Reference Letters for Contractors

The Council has been informed that certain officials were rejecting reference declarations submitted by periti in support of contractors’ licence applications, on the grounds that some periti had crossed out skills they had not directly witnessed the contractor executing.

These rejections are contrary to the agreement reached with BCA senior management and the Licensing Committee last year. The matter was immediately raised with the BCA CEO, and we understand that it has now been resolved.

Periti are reminded to continue following the guidance set out in Circular CIR 07/24, and to report any instances of coercion or procedural irregularities in the processing of reference letters to the Council.

 

3. Design of Lift Shafts

The MCCAA, as Malta’s competent authority on lifts, has issued a circular addressed to periti in view of a recurring pattern of poor lift shaft design, which appears to have led to an over-reliance on requests for derogations. The MCCAA reminds periti that derogations are intended only for strictly exceptional circumstances where it is genuinely impossible to meet the standard refuge space requirements.

The Council strongly advises periti to incorporate lift design standards – including lift pits, headroom, noise and vibration insulation, and structural considerations – at the earliest design stages, preferably prior to the submission of a planning application.

The full MCCAA circular addressed to periti can be found below.

The Impact of Building Designs on Lift Installations

by MCCAA

 

 

 

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PR 10/25 | A Legacy of Excellence – KTP President sends open letter to the profession

Kamra tal-Periti has officially launched the 2025 edition of the Premju Emanuele Luigi Galizia, Malta’s national architecture awards. Entries are now being accepted online at www.premjugalizia.org, with a closing date of 26 September 2025.

To mark this occasion, KTP President André Pizzuto wrote an open letter to the profession highlighting the need for architects and civil engineers to adopt values grounded in rigorous attention to detail, a sense of civic duty, and a holistic view of how buildings sit within wider urban systems, inspired by Emanuele Luigi Galizia after whom the national architecture awards organised by the Kamra are named – one of Malta’s most significant 19th-century architects and civil engineers.

The Premju Galizia recognises excellence in architecture, urban design, engineering and conservation within the built environment across Malta and Gozo. The awards foreground multidisciplinary teamwork, encouraging submissions from full project teams rather than individuals.

Clients, architects, engineers, designers and specialists all share in the recognition. In his letter, Pizzuto outlined the values underpinning this year’s edition: “Good architecture is not only about strong design concepts, but also about effective engineering and meticulous detailing solutions, the urban forms and spatial impacts, the sensitive conservation strategies, skilled execution of works, and the stamina and financial backing of clients”.

Award categories have been strategically chosen to reflect pressing national priorities: adaptive reuse of existing buildings, density and housing, hospitality, open space design, and public projects. The programme is inspired by the legacy of Emanuele Luigi Galizia, whose values, rigour, civic commitment, and systemic thinking, remain urgently relevant today.

Shortlisted projects will be invited to present publicly during awards week in October

2025 at Villa Bighi, Kalkara.

Submissions must include the full list of team members, with their consent. Guidance, eligibility, and submission requirements can be found in detail at www.premjugalizia.org.

 

Full open letter to the profession by KTP President

 

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PR 09/25 | KTP calls for national unity around deep and meaningful planning reforms

For decades the Council of the Kamra tal-Periti has been advocating for the need to reform Malta’s planning regime. The gradual, yet inexorable, decay of our built environment and quality of life over the past four decades has seen inevitably ever-increasing dissatisfaction and anger from the general public about the planning system and the construction industry in general. This, coupled with the several major construction incidents in recent years, makes the need for deep and meaningful reform not only more pressing, but inescapable.

The Kamra has been having several discussions with various Ministers, public entities, and NGOs on the need for reform over recent months. Indeed, it was recently entrusted to embark on a three-year project of completely overhauling Malta’s building and construction regulation framework through an agreement it signed with the Building and Construction Authority.

In the past weeks, it has also been engaged in regular and fruitful discussions with the Planning Authority about the need to collaborate on developing a National Architecture Policy which would analyse and address the strategic issues facing the practice of architecture in Malta. These discussions are at an advanced stage, and it trusted a detailed announcement on this matter will be made in the weeks ahead.

The Council of the Kamra was also concurrently engaged in discussions with the PA through the National Building Council on reforms to the planning appeal process – a reform that was long overdue. The inability to suspend planning permits during the appeal phase was a preposterous situation that needed to be addressed with urgency.

The Kamra’s position has been clear from the start: all permits should be suspended during the appeal phase which, however, should be shortened and made more efficient thereby striking a balance between the opposing interests in this debate. Indeed, the Kamra’s position has consistently been that the appeal timeframes should not exceed three months before the EPRT, and a further three months before the Court of Appeal, to which the standard statutory timelines for filing and responses were to be added.

In recent weeks, Council representatives were presented with draft text related to the EPRT Act to which it gave its feedback. The Council is satisfied that most of its recommendations were included in the final Bill. Nevertheless, a number of provisions found therein were not previously discussed.

A second Bill, however, was also concurrently published with the one governing the planning appeal process. This second Bill, Bill 143, proposes amendments to the Development Planning Act. It must be stated that the Kamra was never presented with this text and was only able to review it over the past three days.

Given the nature of the proposals in both Bills and the impact they may have on people’s lives, the Council felt it was prudent to review them thoroughly and dispassionately. An analysis report about each of the Bills has been drawn up outlining the Council’s detailed technical review, together with its comments and recommendations.

The reports seek to present a balanced, objective, and constructive assessment of what is actually being proposed. The reports include proposals for amendment or outright deletion of some of the articles in the Bills. They also, however, address incorrect misinterpretations of the content of the Bills that are being reported in the media.

Indeed, it is incorrect to state that only objections filed within the 30-day representation window will be considered. The actual text is exceedingly clear that objections can be changed and extended until the two-week deadline to respond to the case officer’s report. Moreover, objectors are given the right to file further submissions if any plans are changed at the request of the Planning Board.

There are, however, aspects of Bill 143 which the Council finds objectionable. This is particularly in relation to the change in planning document hierarchy and the provisions to modify plans.

While the Kamra recognises that Malta’s planning documents are poorly crafted and grossly outdated, piecemeal revisions and the absence of broad public participation in decisions affecting the well-being of this country and its citizens is not the correct approach.

The Council of the Kamra tal-Periti calls, yet again, for the initiation of a formal process for deep and meaningful planning reform, looking at rebuilding the entire planning system from first principles, informed by contemporary and sustainable planning paradigms.

The Kamra tal-Periti is willing to step up and lead the process, as it has already been entrusted to do with other reforms. The Council believes it is in a privileged position to take on this role, given the broad confidence and trust of opposing and varying interests it enjoys.

Finally, the Council welcomes the Prime Minister’s statements that the Government will be considering feedback about the Bills and trusts that the amendments put forward by the Kamra tal-Periti will be considered and adopted.

Analysis Report

BILL 143

An Act to Amend the Development Planning Act, Cap. 552

Analysis Report

BILL 144

Environment and Planning Review Tribunal Act, 2025

 

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PR 07/25 | KTP Council conducts site inspection as part of ongoing investigation into Paceville building collapse

This morning, the Council of the Kamra tal-Periti (KTP) continued its investigation into the building collapse in Paceville that occurred on Wednesday night.

Escorted by Deputy Director of the Civil Protection Department, Perit Graham Attard, Council members were shown the emergency stabilisation works carried out under his direction in the affected area. The Council then conducted a thorough inspection of the site, including the remains of Tania Flats, to help form a collective professional opinion on the cause of the collapse and determine whether professional negligence by a warrant holder was a contributing factor.

While the investigation into the circumstances leading to the collapse is ongoing, the Council noted that there was no evidence of excavation work having been conducted on-site at any point during the project. This was corroborated by the fact that the perit in charge of the project had not sought clearance for excavation works, nor had the Building and Construction Authority (BCA) granted any authorisation for such works. As a result, geological investigations were neither technically required under Eurocodes nor legally mandated.

The Kamra tal-Periti urges all stakeholders to exercise restraint and caution when making public statements about such incidents without first-hand knowledge of the facts.

 

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PR 06/25 | KTP commends the decisive action of periti that saved 32 lives

The Council of the Kamra tal-Periti has immediately initiated an investigation upon learning of the collapse of an apartment block in Paceville last night. While the investigation is still ongoing, a clear picture of what happened is beginning to emerge.

At the onset, the Council feels it is opportune to commend the two periti who raised the alarm with the authorities leading to the evacuation of the building. Without their timely action, at least 32 lives could have been lost.

The Council must also commend the public authorities, particularly the BCA, OHSA, Perit Nadia Curmi, and the police, for taking decisive action to avert what could have been a tragedy of proportions not witnessed in living memory.

Nevertheless, the role of a number of periti directly or indirectly involved in the incident is subject of an ongoing disciplinary investigation which will ascertain if there was any professional negligence or misconduct leading to the collapse of the building last night.

This incident, however, reinforces the Kamra tal-Periti’s considered opinion that the building and construction reform, which it was recently entrusted by the Government to lead, must not be solely limited to new buildings, but must also encompass all existing buildings.

This means that a review of the existing building stock and a strategy for retrofitting, maintenance, and repair must form part of the overall exercise that is currently being undertaken. The Kamra will indeed be putting such proposals to the stakeholders being consulted about the draft building and construction regulations.

 

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PR 05/25 | KTP demands IM be subject to the same laws and oversight as other developers

The Kamra tal-Periti has reviewed media reports and footage of the scaffolding collapse in Triq Mikiel Anton Vassalli, which occurred at a construction site managed by Infrastructure Malta (IM).

It is noted with grave concern that neither the Building and Construction Agency (BCA), the Occupational Health and Safety Authority (OHSA), nor Transport Malta (TM) have taken any action to safeguard the public or workers. Furthermore, none of these entities have issued any official statements regarding this serious incident.

It is pertinent to underscore that IM is merely an agency. Unlike the Planning Authority (PA), BCA, OHSA, or TM, IM does not possess any regulatory powers. Rather, it is an entity tasked by the government with implementing planned infrastructural projects. For all intents and purposes, IM acts as a developer and should therefore be subject to the same scrutiny and enforcement measures as any other developer under the aforementioned regulatory authorities.

If there are any laws, regulations, or policies that could be construed as granting IM exemptions from regulatory oversight, these must be urgently reviewed.

The health and safety of workers on IM’s construction sites, as well as the protection of neighbouring residents, third-parties, and the general public adjacent to or passing by its projects, are no less important than those on any other site and must be afforded equal protection under the law.

 

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PR 04/25 | KTP Council suspends periti involved in the Miriam Pace tragedy

The Council of the Kamra tal-Periti, given the national public interest surrounding this case, is hereby publishing its professional conduct decisions on Perit Roderick Camilleri and Perit Anthony Mangion pursuant to investigations that were opened following the collapse of a building in Triq Joseph Abela Scolaro in Ħamrun on 2nd March 2020 which led to the passing of nearby resident, Miriam Pace.

The Council’s findings are summarised below:

  • Perit Roderick Camilleri was found (i) to be in breach of Directive DIR 01/18, (ii) to be in breach of the Second Provision of the Code of Professional Conduct, (iii) to have failed to uphold professional standards and practices, and has decided to suspend his warrant for a period of twenty-eight months from the date of the publication of the decision in the Government Gazette.
  • Perit Anthony Mangion was found to have failed to comply with regulations with respect to professional standards and practices, and has decided to suspend his warrant for a period of fourteen months from the date of the publication of the decision in the Government Gazette.

 

Both decisions are subject to appeal and can only be brought into effect if and when they become res judicata.

 

BPC 2001 | Perit Roderick Camilleri

[Professional Conduct Decision]

BPC 2002 | Perit Anthony Mangion

[Professional Conduct Decision]

 

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PR 03/25 | KTP Council opens investigations into Sliema and Bulebel incidents

The Council of the Kamra tal-Periti wishes to inform the public that two days ago it opened investigations into the widely-reported incidents that occurred in Sliema and Bulebel constructions sites. This is standard procedure for the Council, which has decided to disclose the opening of these investigations due to the public interest that has arisen around these particular cases.

The purpose of the investigations is to establish whether there were any professional short-comings by warrant holders involved in the projects.

It is pertinent to underscore that the opening of an investigation should not be construed to constitute findings of malpractice.

 

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