To whom it may concern,
Sliema Local Council is putting forward the following considerations in regard to PA/01191/05 – Townsquare development.
1. In view of material changes to the proposal the tas-Sliema Local Council wishes to register as an objector;
2. The Council acknowledges that such a prime site has to be developed and acknowledges the trade-off between open spaces and building heights. It congratulates the developer for efforts to bring back Villa Drago to its former glory and to protect the mature trees in the Villa Drago soft areas. The Council encourages the Developer to maximise the planting of trees in the public open spaces as a mitigation from the urban sprawl being created by the development;
3. The Local Council notes that the original plans for the highrise tower have been changed more than once, and the tower is now proposed to be 38 storeys high. EIA studies commissioned by the developer in 2010 (when the proposal was for 23 storeys) acknowledge that the project will increase the shadowing on the public open spaces along the Qui-Si-Sana sea-front. “The scheme will extend this impact further over the sea. It will also impact additional areas of the rocky foreshore at noon insofar as there will no longer be patches of sunshine.” (p.11) The proposed highrise development requires an updated wind impact assessment and a shading assessment. These studies should also take into consideration the upcoming proposal for a 40-storey tower a few metres away, which is currently being screened by MEPA.
4. The EPS conducted by the developer found that the number of daily car traffic will increase from 23,386 to 27,627, an 18% increase which is based on a flawed study. An updated Traffic Impact Statement needs to be conducted - the A Planning Policy Guide on the Use and Applicability of the Floor Area Ratio (FAR) states that a tall building needs to ‘embrace principles of sustainability’ (5.6). One major aspect of sustainability is traffic management. The EPS conducted by the developer to monitor on-site car emissions and dust particles was undertaken for a period of only six weeks between the 9th of August and the 20th of September of 2011. During the same period an automatic traffic counter was installed that collected data on the volume, speed and classification of passing traffic. Traffic varies according to the time of the year. The summer period chosen would not have accounted for the traffic congestion resulting from schools, which is significant. Another major cause of traffic at the Qui-Si-Sana Seafront was omitted in that the Tigne Car Park entrance from Qui-Si-Sana Sea Front was opened a month after the traffic counter stopped counting, ie on the 26th of October, 2011. There are other traffic variables which were not assessed in the EPS such as the opening of a popular beach club, the increased popularity of the shopping mall and the coming onto the market of various apartments. Furthermore the drafters of the EPS state that there is no mathematical basis for the conversion to AADT, therefore how could projections be made for 2017 and beyond?;
5. A ‘Green Travel Plan’ needs to be submitted in conformity with the A Planning Policy Guide on the Use and Applicability of the Floor Area Ratio (FAR). Has a Green Travel Plan been submitted?;
6. A new EPS needs to be submitted in view of the proposed development at Fort Cambridge. The A Planning Policy Guide on the Use and Applicability of the Floor Area Ratio (FAR) states ‘Where there are concurrent proposals for other tall buildings, or where others are likely to follow, the implications of these should be addressed as well’ (6.6). The Fort Cambridge development is not contemplated in the 2011 EPS;
7. The need for more assessments, particularly the Social Impact Assessment - the 2011 EPS does not fully address the requirement to provide an Urban Design Study, the Visual Impact Assessment, the Transport Assessment, the Social Impact Assessment and the Design Statement in view that it predates the 2014 A Planning Policy Guide on the Use and Applicability of the Floor Area Ratio (FAR). The EPS now needs to come in line with this 2014 policy;
8. While not referring in particular to this Townsquare development, the Council alerts Government with the help of the Planning Authority and Environment Authority, of the need to monitor the risk of a construction bubble in order to avoid a situation similar to the crisis which happened in Spain.
9. The Council was susprised to learn from Transport Malta that there is no plan to have a Sliema Transport Plan. The Council invites Government to study a traffic management plan for the whole Tigne peninsula and the rest of Sliema with the possibility of looking at new solutions for Malta, such as a metro.
B.Com (Hons.) Pub. Pol. (First Class), M.Sc PPM (Lond.)
Tas-Sliema Local Council