MEPA Reform - Issues

Mepa Reform Process: Issues & Concerns
Submission Requirements

The following text is based on comments submitted by one or more periti. If KTP has managed to make any progress with MEPA in resolving this issue, this will be documented in italics below.

Issue no 001
Excessive information is being requested on the drawings which are making serious time demands on drafting and consequently added costs to both architects and applicants. A particular instance is that of the requirement to dimensioning of all rooms, yards, shafts, etc. What is the significance of such a requirement? There is such a thing as a scale rule and dimensions can be scaled off from the plans. This requirement should be dispensed with except maybe for basic things such as side curtilage, setbacks of penthouses, length and width of yards and ventilation shafts.

This matter has already been brought to the attention of MEPA by the KTP and a response from MEPA is awaited.

Issue no 002
Excessive information is being requested on the drawings which are making serious time demands on drafting and consequently added costs to both architects and applicants. As an example, for a minor change of use application the amount of information requested is exorbitant - whole elevations, sections including those of third parties which may not be accessible. How much is one going to charge for such a minor application which takes 3 days of drafting????

This matter has already been brought to the attention of MEPA by the KTP and a response from MEPA is awaited.

Issue no 003
The main problem is not the e-apps system which albeit for minor teething problems is innovative and works well but the draconian and excessive information required in the submissions. Furthermore, the vetting officers are being fundamentalist and not practical in their interpretation. The submission requirements should be simplified both in terms of the quantity of information required and the level of detail such as the requirement for internal dimensions, areas, etc.

Issue no 004
Unreasonable requests are being made in the submission of information, such as for example in the submission of photographs.

Here a fundamentalist approach is being followed. Instances have occurred where a car parked outside the site have rendered the photograph to be considered obstructed and not acceptable by MEPA. What are we supposed to do, WAIT and CAMP OUTSIDE until all cars have left if one is lucky; also petty things like sending it back because the photograph was orientated horizontal rather than vertical, or not marking it exactly on the site plan.

This matter has already been brought to MEPA's attention at one of the meetings with KTP and a respponse is awaited from the former.

Issue no 005
The whole submission process has become far more time-consuming and expensive for the applicant. In this day and age the move is to simplify procedures and not to make them more bureaucratic. But MEPA seems to be going against the grain.

Issue no 006
The list of pre-submission requirements is excessive and its interpretation by some vetters makes it even worse. A perit has been forced to write a proposal description half a page long for an application to curtail a screen wall. It still has not been accepted - perhaps it is too brief.

Issue no 007
Submitted 06.02.2011
On a particular submission which was an amended development application, and there were no changes to the façade, the Perit was requested to re-submit elevations with all relevant dimensions and requirements when the elevations were not being changed. Why is this so?

Issue no 008
Submitted 06.02.2011
MEPA's Circular to Periti 04/10 para 3 states that a scan of previous permit is only being requested for development permissions applied for prior to 2007. Since the previous permit on our site was dated 2009, this was not submitted. However the application was still rendered invalid until we submitted a scan of the 2009 permit.

Issue no 009
Submitted 06.02.2011
Vetting officers are insisting for a copy of the building permit for post 1967 developments. Unfortunately these are sometimes very difficult to find (especially for pre-MEPA developments) as MEPA itself does not have proper records for developments between 1967 & 1992. Sometimes we find a file number at the plotting section and after waiting for a week you have a simple answer saying "File not found"!

MEPA is assuming that the building was constructed without a permit if a file is not presented. Is this fair???

Issue no 010
Submitted 06.02.2011
Within MEPA itself there is a great concern with the “correctness” of the applications, and whether all t’s are crossed and i’s dotted, without any thought being given of what all these t’s and i’s actually mean. For example, a particular application was sent back, because there was no elevation of an underground car-park. Presumably the vetting person had a check-list which asked for an elevation, and once this was not there – irrespective of whether the elevation was relevant or not – he sent it back.

This issue has already been brought to the attention of MEPA and although MEPA regretted that this has happened, KTP expects that all employees of MEPA are instructed accordingly.

Issue no 011
Submitted 06.02.2011
The fact that the Perit is requested to obtain clearances from different Government Departments and Authorities (sometimes as many as four in number) is contrary to the one stop shop which MEPA should be. The individual Perit has no weight in order to request a Government Department to give clearance within any sort of time frame. MEPA is shedding its responsibility and placing it on the Perit.

Although MEPA has already made it clear that Consultees (Government Departments and Authorities) are bound by a fixed time frame to give their reaction and if such reaction is not received within this time frame, then it is considered that a "no objection" has been received, KTP has forwarded this complaint again to MEPA for an additional comments they might have.

Issue no 012
Submitted 06.02.2011
There is huge inconsistency between vetting officers on the requirements, especially with regards to the colour coding (i.e. the use of the green and blue colours!). The vetting officers seem to have a checklist and they are applying this checklist to all applications irrelevant of the nature of the application.

A Perit who submitted an application to open a window on a façade asks why the vetting officer insisted that he wants the dimensions and areas of all the rooms, a longitudinal and transverse section of the whole building, etc, etc?? The Perit remarked that it took us more time to produce the drawings than to eventually open the window on site!

Issue no 013
Submitted on 06.02.2011
A Perit remarked that an application to open two doors between two properties to combine the units into 1 unit in a listed building entailed the drawing up of plans, elevations (totally irrelevant), sections (totally irrelevant), method statement, further photographic evidence, etc. The Perit added that this job, which under normal circumstances would have cost the client some €100 to implement, took some 45 man hours for just the preparation of the application. Something is not right here.

Issue no 014
Submitted 06.02.2011
It is not necessary to have to submit elevations and sections through facade when the proposed development does not involve the facade. Drawing the facade should not be deemed as necessary for such cases but a photo of the facade should be enough.

Issue no 015
Submitted on 06.02.2011
A Perit reports that an application submitted at the end of November 2010, took the vetting officer a good 25 days to request further information required for validation; what’s worse is that each time the requested information was uploaded onto e-APPS, the vetting officer requested even more information – meaning more site visits and waste of time.

It is regretted that such instances are happening and the matter has been brought to the attention of MEPA for a reaction.

Issue no 016
Submission 06.02.2011
A number of Periti have remarked that showing demolition (yellow) on the proposed plans sometimes gets confusing and opine that demolition (yellow) should be shown on existing plans and construction (red) on the proposed plans.

The issue regarding the different colours to be shown on drawings seems to be very confusing and the matter has already been taken up with MEPA.

Issue no 017
Submitted 06.02.2011
Comments recived from a number of Periti state that the requirement to indicate the thickness of party walls is sometimes not easy since this may entail accessing neighbouring properties. The same Periti state that the issue of party walls is a civil issue and should not be considered as essential from a planning point of view.

Issue no 018
Submitted on 06.02.2011
The courses (filati) ruler was abolished by DC 2007 when specifications were written in metric dimensions. The re-introduction of this ruler is a step backwards. Otherwise, an official course height should be stated by MEPA.