Ftit tal-ġranet ilu ippublikajt l-oġġezzjoni li għamilt għall-iżvilupp ta' Torri ta' 31 sular minflok bini storiku fis-sit ta' Fort Cambridge f'Tas-Sliema. L-oġġezzjoni u informazzjoni dwar dan l-iżvilupp jinstab f'dan il-link:
https://mikes-beat.blogspot.com/2020/04/31-storey-highrise-proposed-in-sliema.html
Il-Kunsill Lokali ta' tas-Sliema, Flimkien Għall-Ambjent Aħjar, Futur Ambjent Wieħed u Moviment Graffitti issottomettew oġġezzjonijiet, li qed jiġu ppublikati fuq din il-paġna.
Nixtieq nappellalek biex tibgħat email lill-Awtorita' ta' l-Ippjanar biex iżżid il-vuċi tiegħek sabiex dan l-iżvilupp ma jiġix approvat. Ir-residenti ta' Tas-Sliema jixirqilna aħjar. Malta ma jistħoqqiliex iktar soffokazzjoni.
Inti tista' tibgħat l-oġġezzjoni tiegħek lill-Awtorita' ta' l-Ippjanar sal-Ġimgħa 8 ta' Mejju, permezz ta' email lil representations@pa.org.mt u b' 𝗣𝗔 𝟮𝟵𝟬𝟲/𝟭𝟲 fis-suġġett. Tista tuża kliem minn dawn l-oġġgezzjonijiet:
1. Flimkien Għal Ambjent Aħjar
2. Futur Ambjent Wieħed
3. Moviment Graffitti
4. Kunsill Lokali tas-Sliema
1. Astrid Vella ta' Flimkien Għal Ambjent Aħjar ippublikat oġġezzjoni li jista' jinstab minn dan il-Link:
https://www.facebook.com/photo/?fbid=10220366841894523&set=a.1275473000305
To: representations@pa.org.mt
Subject: 𝗥𝗲𝗽𝗿𝗲𝘀𝗲𝗻𝘁𝗮𝘁𝗶𝗼𝗻 𝗿𝗲 𝗣𝗔 𝟮𝟵𝟬𝟲/𝟭𝟲
I wish to object to this application on the following grounds:
- 𝗡𝗲𝗴𝗮𝘁𝗶𝘃𝗲 𝘃𝗶𝘀𝘂𝗮𝗹 𝗶𝗺𝗽𝗮𝗰𝘁 𝗮𝗻𝗱 𝗮𝗲𝘀𝘁𝗵𝗲𝘁𝗶𝗰 𝗶𝗺𝗽𝗮𝗰𝘁: The highrise building is incongruous and disproportionate, overshadowing the barracks and impacting the Valletta UNESCO World Heritage Site. This project is in breach of the Hotels Height Adjustment Limitation Policy which states that, "Proposals should be sited where visual impact within their context and on sensitive historic environments and their settings such as World Heritage Sites, conservation areas and scheduled buildings is minimised”
The photomontages all lack contrast, no sunrise/sunset and no photomontages have been provided for the narrow streets near this major development.
- 𝗕𝗿𝗲𝗮𝗰𝗵 𝗼𝗳 𝗟𝗼𝗰𝗮𝗹 𝗣𝗹𝗮𝗻: The tower will dwarf the surrounding buildings and adversely affect views from all points, particularly of Valletta's UNESCO WHS skyline. This contravenes North Harbour Local Pan Policy NHSJ15 – sections ii, iii and v a. “The proposed development is not likely to create significant adverse impacts on the local amenity”. b. The scale of the proposed development is [to be] consistent with the building height limitation and the character of the area c. The proposal will not compromise existing and future proposals for traffic management in the area as established in Policies NHSJ01 and NHSJ05 4.
- 𝗕𝗿𝗲𝗮𝗰𝗵 𝗼𝗳 𝗦𝗣𝗘𝗗 𝗽𝗼𝗹𝗶𝗰𝗶𝗲𝘀: a. 3.4.2.6 the second Urban Objective of the SPED requires a commitment “To improve the townscape and environment in historic cores and their setting with a presumption against demolition of property worthy of conservation…” the Grand and Marsamxett Harbours are designated Areas of High Landscape Value (AHLV). Third subsequent Urban Objective refers to: 1. protection and enhancement of the character and amenity of distinct urban areas.
Proposal is in breach of SPED Thematic Objective 7 as it envisages the excavation of 28,000 cubic metres of material. This is a wasteful process, especially at the present time when landfills are reaching capacity. It is also in breach of SPED Thematic Objective 7.9 which states: Thematic Objective 7: To promote the efficient use of resources including local stone, water and soil, and manage waste in a manner that safeguards natural processes, and minimises impacts on cultural heritage, landscape and human health by 9. Controlling demolition of buildings and structures and excavation of sites.
- 𝗧𝗿𝗮𝗻𝘀𝗽𝗼𝗿𝘁 𝗜𝗺𝗽𝗮𝗰𝘁 𝗔𝘀𝘀𝗲𝘀𝘀𝗺𝗲𝗻𝘁 carried out in 2015 is obsolete and there aren't sufficient mitigation measures for the traffic to be generated by the project and the loss of onstreet parking. Censu Scerri and Tigne Streets will be gridlocked by traffic for this project and TownSquare.
- 𝗟𝗮𝗰𝗸 𝗼𝗳 𝗦𝗼𝗰𝗶𝗮𝗹 𝗜𝗺𝗽𝗮𝗰𝘁 𝗔𝘀𝘀𝗲𝘀𝘀𝗺𝗲𝗻𝘁, essential to analyse, monitor and manage the social consequences of such a major development.
- 𝗕𝗿𝗲𝗮𝗰𝗵 𝗼𝗳 𝗟𝗲𝗴𝗮𝗹 𝗡𝗼𝘁𝗶𝗰𝗲 𝟮𝟮𝟳/𝟭𝟲 as the road height to width ratio is being violated and there is no justification for this. The maximum permissible height is 45m, and the proposal is for a 136m high block.
- 𝗘𝘅𝗰𝗲𝘀𝘀𝗶𝘃𝗲 𝘀𝗵𝗮𝗱𝗼𝘄𝗶𝗻𝗴: Microclimate Impact of Overshadowing; The over-shading analysis shows that Triq Tigne will be in permanent deep shade as a result of this development, becoming an urban canyon. The grave implications of this warrant a case study on this street.
- 𝗡𝗲𝗴𝗮𝘁𝗶𝘃𝗲 𝗛𝗲𝗿𝗶𝘁𝗮𝗴𝗲 𝗜𝗺𝗽𝗮𝗰𝘁𝘀: The proposal envisages the near total demolition of the barracks with a facade being retained. This extremely damaging example of facadism completely disregards the site and context and lacks an assessment of the internal features. The Superintendent of Cultural Heritage has stated that this is a major adverse impact. This also disregards the requests for Scheduling of the barracks. the Environment Impact Assessment had recommended Grade 2 scheduling for the buildings, a status which normally precludes substantial changes.
- 𝗘𝗻𝘃𝗶𝗿𝗼𝗻𝗺𝗲𝗻𝘁𝗮𝗹 𝗜𝗺𝗽𝗮𝗰𝘁: Actual possible wind velocities are not being provided in the study and do not take into account other high-rise projects in the area, inc the forthcoming Fortina project. Air pollution study based on 2015 Traffic Impact Assessment is obsolete as that study did not take into account traffic to be generated by other major developments.
- 𝗖𝗼𝗺𝗽𝗹𝗲𝘁𝗲 𝗱𝗲𝗽𝗮𝗿𝘁𝘂𝗿𝗲 𝗳𝗿𝗼𝗺 𝘁𝗵𝗲 𝗙𝗼𝗿𝘁 𝗖𝗮𝗺𝗯𝗿𝗶𝗱𝗴𝗲 𝗗𝗲𝘃𝗲𝗹𝗼𝗽𝗺𝗲𝗻𝘁 𝗕𝗿𝗶𝗲𝗳 regarding Building Heights and residential amenity. The 2007 development brief for the land on which Fort Cambridge was, had excluded development on the historical barracks.
𝘐𝘯 𝘷𝘪𝘦𝘸 𝘰𝘧 𝘵𝘩𝘦 𝘢𝘣𝘰𝘷𝘦, 𝘐 𝘢𝘴𝘬 𝘵𝘩𝘢𝘵 𝘵𝘩𝘪𝘴 𝘥𝘦𝘷𝘦𝘭𝘰𝘱𝘮𝘦𝘯𝘵 𝘪𝘴 𝘳𝘦𝘧𝘶𝘴𝘦𝘥. 𝘐 𝘳𝘦𝘴𝘦𝘳𝘷𝘦 𝘵𝘩𝘦 𝘳𝘪𝘨𝘩𝘵 𝘵𝘰 𝘮𝘢𝘬𝘦 𝘧𝘶𝘳𝘵𝘩𝘦𝘳 𝘴𝘶𝘣𝘮𝘪𝘴𝘴𝘪𝘰𝘯𝘴 𝘢𝘯𝘥 𝘵𝘰 𝘣𝘦 𝘪𝘯𝘧𝘰𝘳𝘮𝘦𝘥 𝘰𝘧 𝘢𝘭𝘭 𝘮𝘦𝘦𝘵𝘪𝘯𝘨𝘴 𝘢𝘯𝘥 𝘵𝘰 𝘣𝘦 𝘱𝘳𝘦𝘴𝘦𝘯𝘵 𝘵𝘩𝘦𝘳𝘦𝘢𝘵
2. Claire Bonello f'isem Futur Ambjent Wieħed, issottomettiet din l-oġġezzjoni:
PA 2906/16
I am filing this objection to this application on behalf of FUTUR AMBJENT WIEHED and on my own behalf on the following grounds
- Negative visual impact and aesthetic impact - breach of the Hotels Height Adjustment Limitation Policy
The highrise building is incongruous, it overshadows the barracks, has a negative visual effect from the Valletta side. It is large and out of context. Exaggerated size does not make it iconic - simply another bulky building.
This is in breach of the Hotels Height Adjustment Limitation Policy which states that," Proposals should be sited where visual impact within their context and on sensitive historic environments and their settings such as World Heritage Sites, conservation areas and scheduled buildings is minimised, and should retain and enhance key strategic, long distant views and important vistas at a national and at the local level. An acceptance of a particular height of one hotel does not imply that all other hotels in the locality or elsewhere should be at least as high as the one granted consent."
- Breach of Local Plan
The tower will dwarf the surrounding buildings. The building adversely affects views from all points, particularly from Valletta, breaking and intruding into the skyline. This contravenes North Harbour Local Pan Policy NHSJ15 –
sections ii, iii and v
a. The proposed development is not likely to create significant adverse impacts on the local amenity.
b. The scale of the proposed development is consistent with the building height limitation and the character of the area
c. The proposal will not compromise existing and future proposals for traffic management in the area as established in Policies NHSJ01 and NHSJ05 4.
- Breach of SPED policies namely: a. 3.4.2.6 In addition to this, the second Urban Objective of the SPED submits a commitment “To improve the townscape and environment in historic cores and their setting with a presumption against demolition of property worthy of conservation…” Third subsequent third Urban Objective then refers to the 1 protection and enhancement of the character and amenity of distinct urban areas . c. Reference is also made to the excerpt from GN133/2001 which refers to the designation of the fortifications of the Grand and Marsamxett harbours, an Area of High Landscape Value (AHLV)
- The Transport Impact Assessment carried out is obsolete and there aren't sufficent mitigation measures for the traffic generated by the scheme and the loss of onsite parking.
- The proposed development is in breach of Legal Notice 227 of 2016 insofar as the road height to width ratio is not being observed and there is no justification for this.
- Excessive shadowing - Microclimate
Impact of Overshadowing; The extracts of the over-shading analysis show that Triq Tigne will have ZERO direct sunlight as a result of this development. A case study on this street should be included to confirm what has been noted due to its grave implications. Furthermore, the case studies provided show a loss of sunlight as a result of the project as a value in itself, for example 40mins for case study B. What is not mentioned is how much the 40mins is of, that is whether it is 40mins of 2hrs of 40mins of 45mins. The over-shadowing caused by the development should be assessed as a fraction of how much sunlight the site over which a shadow is being cast actually gets. Without this information the values provided cannot be interpreted to fully assess the extent of impact the development will have on the surrounding properties' accessibility to adequate natural light.
If the height has been reduced from the date of compilation of the shadowing studies, an updated report has to be made available
- Negative Heritage Impacts
The proposal envisages the near total demolition of the barracks with a facade being retained. There is no study or assessment of the internal features. This is an example of facadism which completely disregards the site and context. The Superintendent of Cultural Heritage has stated that this is a major adverse impact. This also disregards the requests for Scheduling of the barracks.
- Disregard of the Fort Cambridge Development Brief
The proposed development is in breach of the Fort Cambridge Development Brief regarding Building Heights (below) and residential amenity.
Proposal is in breach of SPED Thematic Objective 7
The proposal envisages the excavation of 28,000 cubic metres of material. This is a wasteful process, especially at the present time when landfills are reaching capacity. It is also in breach of SPED Thematic Objective 7.9 which states the following:
Thematic Objective 7: To promote the efficient use of resources including local
stone, water and soil, and manage waste in a manner that safeguards natural
processes, and minimises impacts on cultural heritage, landscape and human
health by
9. Controlling demolition of buildings and structures and excavation of sites
stone, water and soil, and manage waste in a manner that safeguards natural
processes, and minimises impacts on cultural heritage, landscape and human
health by
9. Controlling demolition of buildings and structures and excavation of sites
In view of the above, I ask that this development is refused.
I reserve the right to make further submissions and to be informed of all meetings and to be present thereat.
3. Moviment Graffitti issottometa din l-oġġezzjoni:
3. Moviment Graffitti issottometa din l-oġġezzjoni:
Moviment
Graffitti would like to object to PA/02906/16 for the following reasons:
Retention
of Historic Facades: The 31-storey tower will obliterate a sizeable part of the
historic barracks in the area. The application is still awaiting a decision by
the Planning Authority as to whether these barracks should be granted
protection or not. The application should then not continue to go through until
the barracks are granted protection.
High-Rise
Policy: While the proposed development has been shaved down from 40-storeys to
31-storeys, the policy permitting high-rise hotels specifically bans such
developments on scheduled historical buildings. The Fort Cambridge officers’
mess was built between 1903 and 1905 and in 1915 the building was used as a
military hospital. Therefore, the building has historical value which will be
destroyed by this proposed development. Photomontages for the new development
suggest that most of the original barracks will be demolished with only parts
of the façade being retained.
Floor
Area Ratio policy: In addition, because the site of the proposed tower hotel
amounts to 2,508 sq.m, 1,770 sq.m of which will be built up, the development
cannot be approved under the Floor Area Ratio policy, a framework to allow
higher buildings only on 4,000 sq.m sites surrounded by streets on all sides;
half of which must be retained as an open space.
Scheduling
of Historic Buildings: The PA still has to decide on a request to schedule the
building by the Sliema Local council. The building’s historical importance was
recognised in studies included in the Environment Impact Assessment which
recommended Grade 2 scheduling for the buildings, a status which normally
precludes substantial changes. Therefore, the application cannot be approved
before the scheduling has taken place.
Development
Brief: The 2007 development brief for the land on which Fort Cambridge was leased
to GAP Ltd for €54 million, had excluded development on the historical
barracks. But the brief itself is legally not mentioned in the deed signed with
Gap Holdings in 2007. In 2016 former parliamentary secretary for lands Deborah
Schembri confirmed with MaltaToday that since the 2007 deed does not take into
account the development brief that guided Gap Holdings, the Government Property
Division “has to honour the original deed” – that would imply that no
renegotiation of the lease price or any changes are being considered. Thus, we
can see that there is a discrepancy here and that no development should be able
to take place that would affect the historic buildings.
