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PR 10/18 | Feedback on White Paper – Renting as a Housing Alternative

Verzjoni bil-Malti

The Council of the Kamra tal-Periti congratulates the Hon. Parliamentary Secretary Roderick Galdes and his research team on the quality and thoroughness of the consultation process carried out regarding the White Paper titled: Renting as a Housing Alternative. This commendable effort should be set as a benchmark and a best-practice example for public consultation processes undertaken by other public entities in the future.

The White Paper is a well-researched and well-founded document. It properly identifies the problems with the rental market in Malta, and sets out a strategy to tackle these problems whilst keeping a balance between the interests of landlords and tenants. The impact of the current rental/housing crisis is clearly and frankly outlined. The White Paper argues that the causes for the rental crisis lie both in the “burgeoning economy” but also in changing household composition.

The White Paper quotes an increase in “family breakdowns” and “single individuals”, as one of the primary causes. However, the analysis of the quoted statistics shows that this trend, although significant, is of the same order of magnitude as the number of applicants under the IIP, and many orders of magnitude lower than the impact of the rapid expansion of the foreign labour market.

Nevertheless, the range of proposals outlined in the White Paper appear to have been carefully crafted to address current issues, without heavily intervening in market forces. This is commendable since heavy market intervention has proven unsuccessful in the past, in Malta and elsewhere. It remains to be seen whether the proposals will be sufficient to correct the current crisis.

The Council of the Kamra tal-Periti put forward various suggestions and observations on a number of matters in reaction to the White Paper, including on the following:

  • Rent subsidies, which the Kamra suggests should be converted to a housing allowance, similar to the British housing benefit, while however keeping in mind the risk that increasing liquidity in the rental market coupled with sustained population growth would result in further inflationary pressures;
  • The right of the landlord to withdraw from contracts in certain cases, which may give rise to abuse, since the objectives of the proposed regulation may be completely circumvented;
  • Pre-1995 leases, which are not addressed in the White Paper;
  • Affordable housing, which the White Paper terms as “the ultimate solution to the rental problem”, and the proposal for a “third sector” of housing provision, using innovative housing foundations or associations, or Public-Private Partnerships;
  • The introduction of Real Estate Investment Trusts (REITs), which the Kamra believes to be long overdue;
  • Reliance on private supply, which the White Paper declares to have “failed”, and which in the Kamra’s opinion is a result of the complete absence of the role of urban planning in addressing the housing crisis, and the absence of measures to create affordable housing through the planning gain instrument;
  • Social housing, which is sometimes confused with “affordable housing”, is a solution which the Kamra sees as a temporary solution for those citizens who require it until they are able to move on to better prospects, and the suggestion that schemes for people to buy out their allocated “social” housing should be discontinued, since this effectively diminishes Government’s social housing stock, and, as has happened in the past, effectively allows people to profit off public resources;
  • The introduction of habitability and quality standards, which the Kamra agrees should be introduced without delay since the current crisis is not only due to high rental prices, but also the poor quality of the part of the supply;
  • The importance of placing greater emphasis on the curbing of discriminatory practices against minorities and socially disadvantaged members of society, including low-income earners;
  • The compulsory registration of contracts of lease, which the Kamra supports completely; and
  • The proposed establishment of a Rent Agency, and the Kamra’s opinion that rather than establishing a new agency, the Housing Authority should be thoroughly reformed such that the regulation of the housing sector becomes its primary function.

 

The Kamra tal-Periti considers the White Paper as a positive document which, on the basis of detailed research, proposes a number of regulatory mechanisms to address the current housing crisis. The proposed mechanisms now have to be fine-tuned and embraced by the political leadership.

 

Read the full Consultation Feedback here

 

 

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PR 08/18 | Launch of the Premju Emanuele Luigi Galizia 2019

Launch of the Premju Emanuele Luigi Galizia 2019

The Kamra tal-Periti will be launching the second edition of the Premju Emanuele Luigi Galizia on Friday 5th October 2018, to coincide with World Habitat Day and World Architecture Day which will be celebrated on the 1st October, and with European Engineers Day which is celebrated on the 5th October. The award scheme will be launched during the opening of an exhibition of theses and dissertations by the latest cohort of Master graduates from the Faculty for the Built Environment. A shortlist of the submitted work will be established by the jury, and the selected students invited to present their work to the jurors during the following week. The winners will be announced during the final Awards Ceremony of the Premju Emanuele Luigi Galizia to be held in June 2019.

The exhibition of the students’ work will be open to the public during Notte Bianca on the 6th October 2018 at the University of Malta, Valletta Campus.

 

World Habitat Day, World Architecture Day and Europan Engineers Day 2018

World Habitat Day was established in 1985 by the United Nations General Assembly, and was first celebrated in 1986. The United Nations designated the first Monday of October of every year as World Habitat Day to reflect on the state of our towns and cities, and on the basic right of all to adequate shelter. It also reminds us that we all have the power and the responsibility to shape the future of our cities and towns.

This year’s theme is Municipal Solid Waste Management, a global issue that affects everyone. The amount of waste produced by individuals is growing daily and often costs local authorities a large proportion of their budget. Poor solid waste collection and disposal can lead to serious health problems from uncontrolled dump sites and waste burning. It also leads to polluted air and water.

A change in public attitudes to minimise waste and stop littering, increased recycling and reusing, sufficient funding, solid waste planning including adequate landfill sites, can help cities to improve the current state of solid waste management and save money to become ‘Waste-Wise Cities’.

In 1986, the International Union of Architects (UIA) established World Architecture Day to coincide with World Habitat Day, with the aim to draw the attention of professionals and the public to issues concerning cities and housing. The theme chosen for 2018 is “Architecture … for a Better World”.

Every 5th October, the European engineering organisations ECEC (European Council of Engineers Chambers), FEANI (European Federation of National Engineering Associations), ECCE (European Council of Civil Engineers), together with ENAEE (European Network for Accreditation of Engineering Education) celebrate European Engineers Day to draw attention to the importance of securing the availability of excellent engineering solutions in Europe. The impact of engineering is visible in every aspect of human life, through increasingly more sophisticated inventions, techniques and equipment, and this Day is a good opportunity to remind the profession of the importance of achieving excellence in their respective fields.

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PR 07/18 | KTP welcomes White Paper on Building & Construction Authority

The Kamra tal-Periti welcomes the White Paper issued for consultation by the Ministry for Transport, Infrastructure and Capital Projects for the setting up of a Building and Construction Authority. The consolidation of the various fragmented pieces of legislation, bodies and departments regulating the industry under one legislative and administrative umbrella is a positive development towards ensuring higher standards in the building and construction industry, to bring it in line with modern practice and standards, and to ensure the protection and sustainability of the significant investment made when properties are bought or rented out.

For many years now, the Kamra has struggled to impress upon the authorities the importance of separating planning development issues from those related to standards and regulations of buildings, not just at inception, but right through to end-of-life considerations. The Kamra has repeatedly called for the introduction of a full suite of building and construction regulations, backed up by a properly resourced Building Regulation Office. The principles outlined in the White Paper are aligned with the views of the Kamra tal-Periti, and, we believe, augur well for the industry. The Authority, if backed by all the necessary human, financial and technological resources, has the potential to make a significant contribution towards a better quality in our built environment. The Authority will, we believe, give additional impetus to the efforts of BICC, over the past years, to foster the right technical skills within the industry. We believe that only in this way can it be expected that every actor in the industry can take responsibility for what he or she does.

The Kamra tal-Periti will be shortly publishing a Policy Framework Document about this very subject, on which it has been working for the past months, to provide an analysis of the current situation, together with a framework for proposed reforms. It trusts that such a document will enable Government to attain the goals it has set in the White Paper, for the sake of the industry and its clients. The Kamra tal-Periti reiterates its full commitment and support to the Government in successfully implementing its vision, as expressed by the setting up of the Building & Construction Authority.

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Right of Reply | CRPD Statement

Attn: The Editors of The Malta Independent Daily & The Malta Independent Online 

Reference is made to the article carried in The Malta Independent Online on 16th July 2018 titled “70% of applications for accessibility compliance certificates rejected by the CRPD”. The Kamra tal-Periti would like to inform your readers that the statement made by the CRPD Chair, Mr Oliver Scicluna, about the role of Periti in this statistic, is not only unfounded speculation, but highly defamatory to its members, and that we demand that it is withdrawn entirely. If Mr Scicluna has any evidence of instances where a Perit has deliberately not fulfilled the Commission’s requirements to be able to charge more to change plans, he is requested to notify the Kamra about them, so it may immediately open Professional Conduct cases, as is its remit at Law.

It is pertinent to point out that in most instances, the role of the Perit ends on the completion of construction works and is thus not consulted or aware of what happens during the finishing stages, when most of the compliance failures occur. These may include failure to install the appropriate fixtures and fittings in bathrooms earmarked for disabled access, or the failure to install the appropriate platform lifts. As your readers will surely appreciate, Periti have no say on decisions made after the professional services agreed to with their clients are completed. It is only after the finishing works are terminated that issues of compliance with CRPD requirements are notified to the Perit, who is brought back in the project to rectify the mistakes carried out in his/her absence in the final stages of the project, by either amending planning permits at the request of clients or mediating on their behalf with the CRPD.

This is indeed one of the reasons why building regulations such as accessibility should be taken out of the planning process and consolidated under the Building Regulation Office.

Nevertheless, the Kamra remains open to further discussions with the CRPD on the matter.

 

 

Kamra tal-Periti
info@kamratalperiti.org
kamratalperiti.org/press

17/07/2018

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PR 06/18 | Our Legacy / Wirtna – Meeting with Partit Demokratiku

On the 18th April 2018, 22 entities active in the field of cultural heritage signed a Declaration calling for the preservation of our built heritage. The Declaration, titled “Our Legacy – Wirtna” presented the fundamental message that the manner in which we treat our heritage is the legacy we leave for future generations.

Given the significant role of the political class in upholding the principles outlined in the Declaration, meetings are being held with the political parties. The first such meeting took place on the 31st May 2018, when representatives of the Kamra tal-Periti, Din l-Art Ħelwa, Flimkien Għal Ambjent Aħjar and The Archaeological Society Malta met with Dr Anthony Buttigieg and Timothy Alden, Leader and Deputy Leader respectively of Partit Demokratiku.

A number of issues were discussed including the unsatisfactory performance of the Planning Authority and the Environment and Resources Authority, as well as the severe lack of resources of the Superintendence of Cultural Heritage and the weak legislation that governs it.

The representatives of Partit Demokratiku confirmed their agreement with the statements made in the Declaration and pledged the Party’s support by offering to act as a vehicle to communicate the message of “Our Legacy – Wirtna” through its elected MPs Dr Marlene Farrugia and Dr Godfrey Farrugia.

For further information visit: https://www.facebook.com/SafeguardingHeritageTogether/

Right to Left: Dr Anthony Buttigieg (Leader, Partit Demokratiku); Timothy Alden (Deputy Leader, Partit Demokratiku); Maria Grazia Cassar (Executive President, Din l-Art Ħelwa); Perit Tara Cassar (Flimkien Għal Ambjent Aħjar); Dr Petra Caruana Dingli (Din l-Art Ħelwa); Prof Alex Torpiano (Kamra tal-Periti).

Left to right: Dr Anthony Buttigieg (Leader, Partit Demokratiku); Timothy Alden (Deputy Leader, Partit Demokratiku); Patricia Camilleri (President, The Archaeological Society Malta); Prof Alex Torpiano (Kamra tal-Periti); Dr Petra Caruana Dingli (Din l-Art Ħelwa); Perit Tara Cassar (Flimkien Għal Ambjent Aħjar).

 

Print version EN & MT

 

Declaration EN
Declaration MT
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PR 05/18 | Commuted Parking Payment Scheme

The Planning Authority has announced radical changes in the Commuted Parking Payment Scheme (CPPS), yet again without consultation with anybody. By means of PA Circular 2/18, published on 30th May, the Planning Authority announced changes, applicable as from 1st June – that is with less than two days’ notice! These changes envisage that the amount payable to the Planning Authority, for each car space below the minimum car-parking standards (prescribed by the Planning Authority itself), increases from €1,164.89 or €2,096.44 (depending on locality) to €2,500 for each of the first two car spaces, €6,000 for each of between 3 and 9 car spaces, and to €9,000 for each of 10 or more car spaces below this minimum standard.  The Kamra tal-Periti condemns the behavior of the Planning Authority, which is arrogant enough to triple, quadruple and quintuple its revenue generating mechanisms, without deigning to even consult anybody in the industry, and without giving a decent notice to the principal actors in the industry. The Planning Authority unnecessarily created a situation where panicked developers pressured periti to submit planning applications by midnight of 31st May, jamming the PA’s servers as a result.

Apart from the way this change was introduced, the Kamra tal-Periti has strong reservations about a scheme which is disguised as planning policy intended to help alleviate traffic problems, but which is nothing more than a crude revenue-generating mechanism. After 20 years of the CPPS, does the Planning Authority have any evidence that the policy has actually helped alleviate traffic? Twenty years ago, planning thinking in Malta was that it was necessary for proposed developments to accommodate parking for private vehicles that, it was estimated, would be generated by the proposed development. This type of flawed thinking has already been abandoned in most industrialized countries.

The provision of more parking encourages the use of private vehicles as opposed to public transport, and therefore it promotes road traffic congestion; research has shown that parking provision can actually be a disincentive against public transport, especially if it were free for the users of the building. The Planning Authority should have first studied whether, rather than promoting minimum parking provision standards, it ought to establish maximum standards of affiliated parking facilities. It could also have studied how many of garages in new developments are actually being sold to buyers of apartments, rather than left vacant, and hence not contributing to the envisaged alleviation of traffic congestion.

The extraordinary increase in CPPS fees will not reduce private vehicular traffic, neither will it promote green transport practices. It will certainly encourage developers to construct ever larger under-ground car-parking facilities, involving deeper excavations, more generation of waste, and more consumption of energy to maintain adequate environmental conditions in these facilities.

Twenty years since the introduction of the CPPS, it can now be confirmed that it is a failed planning policy, as not only does it not address parking shortfall problems but is the main contributor to traffic generation, air quality deterioration, degradation of quality of life through noise and dust pollution, and a major cause of inert waste generation that ends in our country’s landfills with adverse impacts on our countryside.

The Kamra tal-Periti calls on the Planning Authority to reverse the proposed changes to its CPPS policy, and to undertake a proper study on the impact of such schemes on traffic patterns and use of public transport. The Kamra insists that planning is too important to be left solely to the Planning Authority; consultation with other actors in the industry would be beneficial to Malta, indeed it is essential. Rather than glibly referring to green travel interventions, the Planning Authority is urged to embrace the real meaning of sustainable transport policy making. The Planning Authority needs to radically review its current planning paradigms and policies, and learn from international best practice in this field to provide a more holistic and comprehensive planning system, which integrates public transport in new development schemes, and uses planning gain as a measure to subsidise public transport, and promote a much needed modal shift away from private car use.

Indeed, the Planning Authority should start fulfilling its primary role of planning rather than just focusing exclusively on development permitting.

 

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PR 02/18 | Proposed new DNO Class for Fireworks Factories

The Planning Authority has issued for public consultation a draft Legal Notice which will effectively render any illegal fireworks factories built prior to 1994 legal, without any due process, application or consultation.

The Planning Authority is proposing that such illegal development is considered as “permitted development” under the Development Notification Order (DNO) Classes, even if such constructions are in conflict with regulations and legislation.

Under the misleadling Class title of “Existing development related to Malta’s culture and tradition”, the Authority is effectively singling out one type of development, and an illegal one at that, and giving it a carte blanche approval through a legislative measure.

It is important to ask why it is necessary for these fireworks factories to be rendered legal through this Legal Notice, rather than through the appropriate planning application processes already in place; unless, of course, this is because they would not normally be permitted if the current processes are followed. If this Legal Notice is approved, these illegal developments will be rendered legal without any public consultation, and without any consultation with the relevant Authorities.

The Kamra tal-Periti strongly objects to the proposed Legal Notice, and urges Government and the Planning Authority to review its stance in favour of a more equitable and just solution.

 

The complete consultation feedback submitted by the Kamra tal-Periti to the Planning Authority can be downloaded in below.

 

Perit Simone Vella Lenicker
Vice President

 

Download KTP Consultation Reply re Fireworks Factory DNO Class Proposal
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