Wednesday, February 21, 2018

40-storey highrise public consultation: Civil Society Network feedback

Text below represents the official feedback of Civil Society Network to the Environment Resources Authority for public consultation which closes on 23 February.
Public Consultation - 40 storey Highrise (Fort Cambridge) PA 02906/16 - Site at, Triq Tigne c/w, Triq Il- Ponta Ta' Dragut, Sliema, #Malta
To: eia.malta@era.org.mt - EIA Team, Environment & Resources Authority
From: Civil Society Network
Copied to Press
1. A social impact assessment is required. The International Association for Impact Assessment produced guidelines for social impact assessments suggest that an SIA is the process of analysing, monitoring and managing the intended and unintended social consequences, both positive and negative, of planned interventions and any social change processes invoked by those interventions. Social impacts under assessment should include all those things relevant to people’s everyday life. This may include one’s culture, community, political context, environment, health, well-being, personal and property rights as well as fears and aspirations. The SIA should not be a one-off exercise and should include both quantitative and qualitative research methods. It should include the consideration of reasonable alternatives to development proposals as well as comparative analysis of similar development proposals and related good or bad practices. Analytic indicators should be provided and the entire process should be subject to peer review by independent experts in the field.
2. An impact assessment of dust and other
pollution is required
3. A sewage impact assessment is required.
4. Direct Shading Analysis: All EPS models show that Tigne Street will be in perpetual darkness. Regulations 2016 / L.N. 227 of 2016 state that "In streets or open spaces which are wider than three meters but less than or equal to fifteen metres, the overall height of the façade should not exceed three times the width of the street..." The average width of Triq Tigne in relation to the development site is 12.7m to 15m. Therefore, in line with L.N. 277/16, the maximum height onto the street is to be three times as much, which amounts to 45m: proposed tower block is of 136m. Additional floors are only permitted if " adequate setbacks from the building alignment of the façade are introduced."
3. There are no photomontages for streets near to this major development.
4. There are no mitigation measures against various adverse impacts in 'summary of impacts: Volume 4'.
5. A realistic, more accurate and comprehensive traffic impact assessment is required, which includes hourly flows and which shows how traffic will be managed in view of over capacity and spillover effects. Mitigation measures and green travel plan are imperative.
6. We note that Fort Cambridge Development Brief states as follows:
3.9 This would imply that any future use would need to be examined in the light of the Structure Plan and the emerging North Harbours Local Plan and its strategy and plans for theTigne’ Peninsula area and Sliema in general. However, in case of incompatibility between this development brief and any emergent plan or policy, the provisions of this development brief shall prevail.
7. We request Grade 1 scheduling of the Officers' Quarters.

No comments:

Post a Comment