Friends of the Earth Malta (FoEM) is thankful for the opportunity to provide feedback on the Grand Harbour Revival Plan, and are encouraged to see a number of important considerations already discussed in the plan, such as concerns around gentrification, the importance of climate resilient design, and the necessity of securing public access to the waterfront and proposed park. We believe the plan can do more to protect and bring back nature into this urban and industrial landscape, and can be an opportunity to provide safe, direct and attractive connectivity for walking, cycling and public transport through this key node in Malta’s transport network and urban area. 

On public access and local communities:

• Ensure that the revival plan and consultation exercise truly takes on board the needs and wishes of the communities living in the localities adjacent to the harbour, and of others living and working in the vicinity. Include mechanisms and safeguards to ensure the project does not lead to gentrification and pushes out the Maltese and migrant communities living in Marsa, but works with them to create positive projects and impacts in their locality. Ensure that proposed residential dwelling units have rent control, social housing units, or are set up as a housing cooperative, to enable people of different income levels to live / remain living there. 
• As stated in the plan, any development should take into consideration Malta’s heritage. Renovations should be respectful and reflective of Malta’s long history, with any structures being culturally appropriate. We agree that no high-rise buildings should be allowed.
• We say no to a “people’s marina” – Access to the shore and harbour should be available to all and is enshrined in the Public Domain Act as a space which should be public and non-commercialised, a marina defacto removes that right by privatising the seascape and removing the ability to enjoy the waterside, and see and admire the view of the harbour and water freely. Create a landing site for a public ferry instead, as well as a landing site for local dgħajjes, so anyone can access the site via the water, also reducing dependency on land-based transport.

On climate, energy and mobility:

• The waterfront and park should be designed as completely car-free spaces, where people, including families with children and elderly can walk, play and relax in peace. Parking should be strictly limited, not encouraged, to restrict the number of people coming by car. Instead, there should be an attractive and accessible public transport hub for people to access the waterfront, as well as access points by ferry, and safe and connected infrastructure for walking and cycling to link to neighbouring localities, such as Paola, Qormi and Floriana/Valletta.
• Create climate resilient infrastructure, with space for excess water, shading with trees, green infrastructure and shade structures to protect from strong sun and heat, and protection from wave action and flooding.
• In any open industrial space and on rooftops of existing or new buildings, prioritise the installation of renewable energy. To benefit the community, these sites should be made available for renewable energy projects of a cooperative nature – community energy. 
• Ensure that any new buildings are built to the highest energy efficiency standards, ideally following passive building guidelines to reduce energy consumption. Ensure that all new buildings are equipped with renewable energy (i.e. solar PV) and technology such as heat pumps. 
• Install proper and transparent air quality monitoring in active harbour and ports, particularly downwind from the prevailing wind direction. Have at least one fixed air pollution monitoring station in the Grand Harbour. 
• Ensure that by 2030 all cruise liners visiting Malta’s Grand Harbour connect to shore-to-ship infrastructure. Develop and implement a clear national roadmap leading to 2030 which sets out the progressive rollout and utilisation of ship-to-shore power infrastructure, with timelines for implementation, targets for utilisation and the categories of vessels expected to connect. 
• Create a bridge connection for pedestrians and cyclists between Kordin Hill and Marsa/Floriana, connecting to the C-SAM and Vjal Kulħadd projects currently being implemented in Floriana and surrounding areas, and creating a safe and sheltered route for micromobility away from the Marsa bypass and flyovers.

On zero waste and plastic free policies:

• Waste bins for proper separation should be made available at convenient locations. They should clearly identify which waste to dispose of in each bin, via signage in multiple languages and color coding. Bins should be monitored, and emptied regularly especially in warm summer months, with fines for littering strictly enforced.
• Shops and food stands should be required to provide recyclable or biodegradable containers and take-away items, including bags, boxes, cutlery, etc. Reusable tableware should be prioritised.
• Benches and other infrastructure should prioritise use of recycled materials such as reclaimed wood and stone, and minimize plastic.

On nature and ecology:

• The document seems to lack any mention of biodiversity or of measures to protect and enhance it.
• Friends of the Earth Malta would like to encourage focusing on rewilding initiatives in proposed green areas as much as possible to make up for all the natural habitats that have been lost. Rewilding aims to  support nature-driven processes and any park in this overurbanised area should seek to encourage a rich biodiversity while ensuring the protection of any current species that have already adapted to urban areas (such as bats, reptiles and the national bird, il-merill)
• Parks should not be manicured spaces where spontaneous plants are ripped as soon as they sprout – they should not be standard formal garden areas with desert soil but should bring back nature and allow whatever healthy ecosystems are present already on site to continue flourishing  without being tarmacked over. What people lack in these urban areas is nature in its simplest, yet most complex form. 
• Due to lack of foraging areas for many pollinators these spaces should encourage and support pollinators by selecting appropriate plants, shrubs and trees which flower at different times of year to provide food even in the dry season. For reference we recommend using this manual, which although created for schools can be applied to larger areas and includes a whole annex of indigenous pollinator plants: Lets Make a Wildlife Garden – Friends Of the Earth Malta
• When restoring historic structures and bastion walls ensure that biodiversity is not endangered or completely removed. These areas are especially rich in protected species which use abandoned areas and bastions for breeding purposes as well as for roosting. This includes, but is not limited to, various Bat species (all of which are legally protected) as well as birds such as the Blue Rock Thrush. Ecological surveys in both seasons need to be carried out to ensure no nests or roosts are cemented in as has happened many times in the past. Experts can be called in to relocate these as necessary. The Grand Harbour area is the only known European station for the protected reptile Hemorrhois algirus – the Algerian Whip Snake. It is one of the rarest snakes in Malta but has been observed by FoEM staff entering cracks in bastions in Floriana. 
• Choose plants which are climate resilient and do not require much water – refer to above Wildlife Garden manual as well as ERA’s own guidelines: Guidelines on trees, shrubs and plants for planting and landscaping in the Maltese Islands – ERA 
• Select trees that create layers and shade – this should not be a regimented planting area. It could include fruit trees which can be occasionally foraged in community events (fig trees, mulberry, hawthorn, almond, pomegranate, jujube, strawberry Tree, myrtle, olive as well as some cultivated varieties which fare well in our climate and do not require much care). 
• We strongly recommend that mature trees which have already established shade and are not invasive to be retained and supplemented with appropriate native species. 
• No herbicides or pesticides of any type should be used.
• FoEM has long been receiving requests for more community gardens. This could be an ideal initiative to bring communities together while reclaiming some abandoned spaces.

On noise and light pollution:

• Lighting should favor use of soft-light that is efficient in terms of energy usage or solar powered, or no light at all where not necessary.
• Strict measures should be taken to minimise any light pollution on site. Lighting should be minimal. For guidelines please follow the Light Pollution Awareness Group’s recommendations L.P.A.G. – Guidelines for the reduction of light pollution – L-Għaqda Maltija tal-Astronomija as well as ERA’s own draft Guidelines. Light pollution indexes in Malta are extremely high and it is now well documented that it has a negative effect on human physical and mental health and disrupts wildlife and ecosystems. Furthermore, dark sky heritage should be a right for all to access – we have already lost a big part of our night sky. 
• Limit Noise Pollution: noise pollution is well known to have negative health repercussions: “A special report by the Citizens Policy Department of the European Parliament has placed Malta’s noise pollution under detailed EU scrutiny, highlighting significant health impacts and calling for stronger action to address sources not covered by the EU Noise Directive. […] Noise is recognised across Europe as the second most significant environmental health risk after air pollution, and Malta’s high population density and limited mitigation options exacerbate the problem.” (Source: EU report flags Malta’s noise as major health threat ). The recent Citizens Policy Department of the European Parliament recommendations should be taken into account in addition to the ERA Noise Action Plan (NAP). 

Friends of the Earth Malta is a national environmental NGO working in the Grand Harbour area: our Green Resource Centre, with our office and community garden, is located on Xatt ic-Cangatura in Floriana. We would like to be kept informed about the plans and have useful resources and expertise on planting native pollinator-friendly (community) gardens, promoting sustainable mobility policies, renewable energy communities and implementing zero waste practices. We would be interested to join a stakeholder committee or monitoring group to follow and advise on the process.