Dear Sylvana,

Your response to my contribution on MEPA'S Interim Retail Planning Guidelines was interesting in what it said as much as in what it did not say...

But first I have to tell you about my rules. I do not write in the press to push forward applications made on behalf of my clients. I write about principles - not the particular case. I do use actual applications to give examples of how MEPA's policies are confusing people, but I purposely camouflage the details on the cases that I use as a starting point for my arguments. I do this for two reasons: I do not mix my professional practice with my contributions in the press and I want to avoid provoking public debate on particular applications, more so as this sort of thing gives MEPA the chance to come up with innumerable red herrings.

These are, of course my rules. In your case, these rules do not apply. In any case, MEPA is notorious for changing the rules as it goes along!

Having cleared the air on this point, I dare say, dear Sylvana, that you missed the main thrust of my article: that in the draft Local Plans, differentiation between shops inside and outside town centres is based solely on size, while the Interim Guidelines introduced a totally different concept - the difference resulting from whether shops sell convenience or comparison goods. In other words, MEPA changed the goalposts before the Local Plans were even approved.

Are you sure that during the public consultations, this change in the goalposts was thoroughly discussed? Are you sure that the public has understood the difference between neighbourhood centres and primary, secondary and tertiary town centres? Do we really need this hierarchy of town centres to regulate retail services in this miniscule country? Do we need to pretend that every town in this country is a burgeoning metropolis? Do we need so many pen-pushers justifying their existence by dishing out a never-ending plethora of policies that only serve to confuse people? Can we ignore the fact that all this is leading to a new planning 'system' in which the number of policies is inversely proportional to the area of land that is being regulated? Isn't this going over the top?

And why did you ignore my reference to consultation - if any - with local councils?

Surely you are aware of the classification of commercial and industrial uses, particularly of Class 4 shops. Are you sure that the division of shops between those selling convenience and comparison goods is not in conflict with this classification? Had not MEPA decreed that the trading licence of a shop can be changed from one selling a type of goods to another without the need for a MEPA permit, so long as the outlet remains within the same classification?

What is going to happen with that policy? Can someone get a MEPA permit for a shop selling convenience goods outside a town centre and then switch it to one selling comparison goods without any reference to MEPA, since the classification of the shop remains the same? Is this not a case of confusion being caused by MEPA's conflicting policies?

Is it not true that hairdressing salons are nowhere found in the Interim Planning Guidelines and that in their case, MEPA case officers are applying these guidelines by default?

Strangely you say nothing about pharmacies. Is not true that the Interim Planning Guidelines are in conflict with official Government policy on the issue of permits for pharmacies? Incidentally, a colleague of mine pointed out that these guidelines allow for a tobacconist in every corner, but restrict pharmacies to town centres, leading one to suspect that this could also be in conflict with Government's policy on smoking! But you might think this is 'ridiculous'...

Now, I come to the cherry on the cake. For MEPA, if a married woman who is refused a permit to change the use of a garage to a hairdressing salon concludes that MEPA is hindering her getting back in the workforce, she is being 'ridiculous'!

This is, of course, the height of arrogance because it shows that MEPA is not ready to try to look at things from the other side's point of view. If you had said that you appreciate this woman's frustration and disappointment but MEPA's policies are thought out for the common good, I would have accepted this as a reasonably decent answer - even though I do not agree with it in this case.

Instead you choose to be indecent, reflecting the mentality of the 'we-know-it-all' boffins who have hijacked MEPA and use it to pursue their own personal agenda; forsaking that most useful of planning tools - common sense; shunning compromise; and refusing to bother checking how and why MEPA was set up. In short, MEPA has lost the plot.

Now picture hundreds, if not thousands, of people who think that MEPA is unjustly hindering their plans for their future, irrespective of whether they are right or wrong. According to MEPA's boffins they are all 'ridiculous'!

I know for a fact that many people vote one way or another for what I think are the most 'ridiculous' reasons. What I think, however, is irrelevant. What they think matters. And dismissing their point of view as 'ridiculous' is not on.

Here we have a recipe for disaster that no number of ministerial audits can avoid, because audits can never bring about the change in mentality that is needed at MEPA.

Dear Sylvana, I've given up on dialogue with MEPA, more so now that I am classified as another one of those mere mortals with 'ridiculous' arguments - even though I cannot fathom whether my ridiculousness is one of a primary, secondary or tertiary level. Perhaps yet another MEPA policy paper will elucidate this point...

So, dear Sylvana, you'll hear from me again ranting in the press, now and again about one MEPA thing or another - at my pace, of course.

Yours in ridicule,
Michael

micfal@maltanet.net

Note: This contribution was written as a reaction to the response to my previous article 'Out of Sync' (January 2) published last Sunday under the name of Sylvana Debono, MEPA's PRO.