Ten members of the Board, namely, ERA Chairman Victor Axiak, Deputy Chair Elizabeth Ellul, Clayton Bartolo, Desiree Cassar, Timothy Gambin, Matthew Pace, Simone Mousu’, Jacqueline Gili, Ivan Tabone u Joseph Brincat decided to approve the project despite the many extremely valid objections that have been raised ever since this madness was first mentioned.
There are various points which make this approval incomprehensible:
1. The cardinal point of departure is that such a massive project infringes Policy NHPE10 and therefore cannot be approved without a Development Brief.
a. The Development Brief goes part and parcel with the public consultation that should have been done before the project was even recommended;
b. Moreover, the project has been approved without the National Masterplan – or even the Paceville plan that was supposed to be done by April 2017 and which has been abandoned by the government.
2. There are the following major infringements which are being listed below:
a. The visual impact which is excessive and goes against normal practices:
i. The massive building is being constructed on a promontory of land and runs counter to the Maltese environment, including the sky-line;
ii. It also goes against the Paceville Policy NHP V04 (iii) which states “consistent with the building height limitation and the character of the area”;
iii. There are no tall buildings in the area. There are only hotels and restaurants;
iv. FAR Policy 2.4 and 5.6 call for the evaluation of the proposed building with the topography and skyline and require that the proposed building must make a positive contribution to the urban area and skyline;
v. FAR policy 7.1 states that buildings should be ‘areas generally not visually prominent’;
b. The building does not follow the Floor Area Ratio Policy:
i. Para. 5.12 of the Floor Area Ratio policy states: “Tall building schemes should create high quality, public open space within the site through proper site layout and arrangements. The development should promote consolidated outdoor public spaces that are safe and attractive for all, and which meet the needs of both the users of the building and the wider neighbourhood.” Small disjointed areas cannot be considered as public spaces. Their purpose is to serve private interests and not the public.
ii. The Floor Area Ratio requires that 50% of the site has to remain ‘public open space’. Roofed over space is not considered as public space.
c. The building is incompatible with the Height Limitation Adjustment Policy:
i. Hotels usually keep airspace as potential for growth. The proposal uses this space to increase the number of luxury apartments.
d. The transport infrastructure is inadequate:
i. Traffic in the area is already difficult and there are no approved tangible plans to improve it.
ii. On principle, first there has to be access by road before a project is built.
1. There is no guarantee that the road infrastructure – including the tunnel – is built;
2. There is no pending application for the above;
3. There have been no monies voted for the roads project
4. Besides all the above, even if the tunnel is built, congestion will still increase as will air and noise pollution.
e. There will be the negative effect of overshadowing on the neighbouring buildings, public garden, hotels and the seashore:
i. Para 5.15 of the FAR policy states that “The siting and design of tall buildings should consider the effects on the microclimate and seek to reduce overshadowing ….”.
f. The demolition of the ITS building:
i. This infringes SPED on scheduled buildings.
g. Many empty promises regarding consultation and services have been made.
i. None are credible, because there have been various changes in the application over the past months;
ii. It is well known from experience that monitoring and enforcement are extremely weak;
iii. The land transfer is dubious and is being investigated by the Auditor General.
Partit Demokratiku condemns the government that, while rightly expecting ordinary citizens to abide by the law, through its executive decisions and via the government-controlled PA, publicly flaunts the letter and the spirit of the law by aiding and abetting environmental degradation for the benefit of big businesses.
Partit Demokratiku fully supports any appeal process that NGOs and civil society decide upon and puts its limited resources and unlimited love for our country at their disposal, while expecting the PN to formally support the NGOs in their appeal if it really means what it says.