The Sliema Tower Controversy - Michael Briguglio

In my weekly column in the Times of Malta I write about the controversy relating to the Townsquare and Fort Cambridge highrise proposals.

You can read the article here:

https://mikes-beat.blogspot.com.mt/2018/05/the-sliema-tower-controversy-michael.html

https://www.timesofmalta.com/articles/view/20180507/opinion/The-Sliema-tower-controversy-Michael-Briguglio.678426

Victory!! 38 storey tower back to the drawing board

Today the EPRT did not approve the construction of a 38-storey Gasan Townsquare tower in Sliema and developers have to resubmit plans. It had policy infringements, incomplete impact assessment studies and objections by Sliema Local Council, ENGOs, ERA and residents.

On another note we are also requesting a proper evaluation of the proposed development of the Fort Cambridge 40-storey tower just up the road in Sliema. We will keep up the struggle to defend residents' quality of life.

Planning Authority yet to decide on scheduling of Fort Cambridge officers’ mess

Malta Today's James Debono writes about Sliema Local Council's request to schedule the Fort Cambridge officers' mess, which is under consideration at the Planning Authority. Developers have proposed a 40-storey tower on site.

Read the article here:
https://www.maltatoday.com.mt/environment/townscapes/86327/scheduling_curveball_that_could_rumble_sliema_40storey_hotel#.WudLCoiFPIV

40-storey highrise public consultation: Sliema Local Council Feedback

Text below represents the official feedback of the Sliema Local Council to the Environment Resources Authority for public consultation on Fort Cambridge development which closes on 23 February. To see documents in good size, please save and enlarge.

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.

How Sliema towers will break historical skylines and views

James Debono (Malta Today) reports on how the proposed 38 and 40 storey towers in Sliema will break historic skylines and views.  Read more here.

The Fort Cambridge Highrise EIA is currently subject to public consultation until 23 February. Read more here.

The Fort Cambridge Highrise EIA

The public consultation for the 40-storey Fort Cambridge highrise proposed by GAP Developers will expire on 23 February. 

Sliema Local Council is currently looking into the Environment Impact Assessment (EIA) and had requested the Planning Authority to schedule the property in question, known as the officers' quarters. Significantly, even the same PA had proposed Grade 1 protection for this property. The Developers wish to demolish parts of it, with only parts of the facades retained to be included in the highrise. Grade 1 protection which would preclude any development which would alter its context. 

The proposed development is a few metres away from the controversial Townsquare Project which will include a 38-storey highrise if the developers (Gasan) win the current appeal at the Planning Authority.  

Journalist James Debono had analysed the Environment Impact Assessment in 2016. The EIA has not been updated since then. You may read Debono's analysis here. 

The full EIA may be read here.  

Fort Cambridge Highrise Public Consultation

A new Public Consultation - PA 02906/16 - Site at, Triq Tigne c/w, Triq Il- Ponta Ta' Dragut, Sliema, Malta – has been launched. The proposed development is just a few metres up from the Townsquare highrise development. Deadline for submissions is 23 February 2018.

The following is the link to the relevant page:

http://meae.gov.mt/en/Public_Consultations/MSDEC/Pages/Consultations/PA0290616Site%20atTriqTignecwTriqIlPontaTaDragutSliemaMalta.aspx

The Planning Authority has failed

A few days ago I was interviewed by Kevin Schembri Orland, The Malta Independent, about the Planning Authority, development and the property market. You can check it out here.

Master Plan in Reverse

Michael Briguglio

Times of Malta 10 October 2016

When it comes to big development projects, the Labour government is gambling excessively on the big developers’ card.

Rather than relying on evidence-based policymaking, the government assumes that big developers have some magic power to cater for Malta’s social, economic and environmental needs.

This is a far cry from having a national master plan which would verify opportunities, risks and alternatives. Instead, Malta is experiencing a series of development proposals which simply ignore the respective cumulative impacts on Maltese society.

Gasan’s Townsquare project in Sliema is a case in point. One of Malta’s most congested areas will have a 38-storey high-rise, 159 residential units and various commercial outlets, unless the approved project is reversed in the upcoming appeal process.

Townsquare has a shortfall of 234 parking spaces and will result in an estimated increase of 3,500 cars daily in the area. The Sliema local council has been left in the dark about a required ‘green transport plan’ and waste management, and there is no sewage impact assessment.

The project’s social impact assessment is incomplete, outdated (it was carried out almost a decade ago) and says nothing on mitigation measures.

Save for some exceptions, the assessment of the project practically ignored the 40-storey development proposal at Fort Cambridge, just a few metres up the road. Not to mention new high-rise development at The Point in Tignè.

The Planning Authority approval of high-rise at Mrieħel also has clear shortcomings. This joint project by the Gasan and Tumas groups was approved without a master plan for the area. It comprises a lack of 498 parking spaces, and will result in an estimated daily increase of 2,700 cars in the vicinity. As in the case of Townsquare, the PA decision on this project could be reversed through an upcoming appeal process.

The government assumes that big developers have some magic power to cater for Malta’s social, economic and environmental needs

In the past days Maltese society learned of further proposed mega-projects, including land reclamation and high-rise at the ex-Jerma site in Marsascala and the government-sponsored Paceville plan.

The latter is currently undergoing a public consultation process. Here, new high-rise development is being proposed in what seems to be a wish list of certain big developers.

Perhaps the most controversial project in the Paceville plan is the land reclamation project by and for the Tumas group. When the original Portomaso development was proposed, residents and other stakeholders were promised that no further development will take place, but this condition was already broken once through the approval of further development, so what the hell?

Now, what is being proposed is the reclamation of land next to a marine special area for conservation, which, incidentally, was already damaged by Portomaso development some years ago. The land reclamation will mostly comprise residential and hotel development, and a 15-storey building height of Preluna dimensions.

The Planning Authority has said the Paceville plan will be subject to a strategic environmental assessment. But this inevitably raises a question. How come strategic environmental assessments are not being carried out elsewhere? And this, in turn, raises a more pertinent question which the government refuses to reply: why is the government not carrying out a national master plan on high-rise, land reclamation and other mega projects?

Given Malta’s small size, it is only reasonable to have national studies on ecological, social, economic, traffic, waste and other impacts before accelerating the auction of development proposals.

Such studies could estimate Malta’s carrying capacity for such projects, the economic risks and opportunities of relying on such a development model, and the impact on our road arteries, which, in many instances, are already clogged.

Such studies could also show how necessary financing of public infrastructure is going to be carried out, and whether such financing is really a priority compared to other infrastructural needs in the country.

What is stopping the government from commissioning a national master plan?

Townsquare and Fort Cambridge have political implications

"Labour will lose floaters"

Sliema local councillor and sociologist Michael Briguglio takes Jacob Borg through the potential pitfalls of opting for high-rise developments in Sliema without all the necessary studies being carried out.

Times of Malta 17 June 2016

The Prime Minister risks losing the support of Sliema’s floating votes and switchers if two mega high-rise planning applications are approved for the area, Sliema councillor and sociologist Michael Briguglio warned in an interview yesterday.

Sliema residents took to the streets last week to protest against proposals for a 40-storey hotel at Fort Cambridge in Tigné and the 38-storey Townsquare Tower in Qui-Si-Sana.

A court injunction has been filed by the eNGO Flimkien għal Ambjent Aħjar to halt a decisionby the planning authority on the Townsquare project, since claims were made that certain studies related to the development had been withheld or were incomplete.

Dr Briguglio is adamant that if the Planning Authority (PA) gives the go-ahead to these proposals, it will result in Prime Minister Joseph Muscat taking a hit at the polls.

“We are talking about politics here. Development and politics go hand in hand. I know that the Prime Minister is very savvy with popular opinion. I think he knows that if the PA approved the Townsquare and Fort Cambridge developments, he is going to have a big political problem with switchers and floaters.

“I am from Sliema. I am not a Nationalist. I am in the Green Party. I speak to many people in Sliema, and there is a lot of disappointment about how the government is basically not showing enough concern for the environment and for citizens’ basic rights,” Dr Briguglio said.

He flags the lack of proper studies for the Townsquare project as being a point of major concern.

He is critical of the PA for serving as a “rubber stamp” for such developments, rather than doing its job by ensuring that all the necessary studies have taken place.

“Sliema is already very congested. The two high-rise proposals would cause traffic havoc. It seems that the government or PA is justifying the projects simply by saying that Tigné has been designated a high-rise area. The starting point should be analysing whether Tigné or other areas in Malta have the necessary infrastructure to support such high-rise developments.”

How can you accept a planning application without any analysis on sewage and drainage?

“It is a sham that the PA accepts such development applications without the necessary impact assessments having taken place.

“How can you accept a planning application without any analysis on sewage and drainage, and without a social impact study? Does this mean residents do not matter anymore? This is a sham; it goes totally against the concept of holistic and sustainable planning.

“We have an authority that seems to work to facilitate things for developers and which does not question impact assessments. Such studies are not a rubber stamp facility. One should engage with these assessments.”

Without such studies, it was impossible for stakeholders such as the local council to engage with the developers and authorities, Dr Briguglio insisted.

Transport Malta, he added, was not even capable of running a bus lane, as it was often occupied by unauthorised vehicles.

Given this, he questioned whether the transport watchdog was capable of coming up with a holistic plan to ensure Sliema did not end up in “one big traffic jam”.

The Sliema local council is a registered objector to the Townsquare project. The council is adamant that Sliema’s present infrastructure cannot support more cars.

The project’s developers were supposed to present a green transport plan but this has yet to materialise.

“Apart from the environmental issue which is very important and is of utmost concern to me, there is also a question of governance. How can we have an authority which does not do its job?

“We are not asking the authority to do anything beyond its remit, we are basically asking the authority to do its job. If the authority is not capable of doing that, we have a serious governance problem.”

The development application for the Townsquare project was originally filed in 2005. Asked if the local council has engaged with the developer, Dr Briguglio said various meetings had been held over the years.

“Several months ago we asked the developer to hold a meeting with residents so that there can be dialogue on this issue. You cannot force the developers to do something they do not want to do.

“They would be able to explain their plans in the meeting and allow residents to raise their concerns. My gut feeling is that if an open meeting was not held and a social impact assessment was not carried out, the authority and developers know there are many angry and disappointed residents,” Dr Briguglio pointed out.

Transport Malta is not even capable of running a bus lane

He was non-committal when asked about the positive impact of such a project, saying an economic impact assessment should have been carried out in order to answer that question.

He made it clear that he was not against the concept of a free market, wherein entrepreneurs take risks and reap the rewards, but added this must be done in a structured and regulated manner.

“I am in favour of the free market but I am also in favour of government regulation. The government has a responsibility to ensure the market works in a fair and sustainable manner.

“High-rises all over the place without the necessary infrastructure and demand for them can lead to sustainability problems and market problems. Some real estate experts are worried that if Malta is flooded by high-rise projects this could lead to a crash in property prices.

“Just because someone wants to invest in something does not give them an automatic right to do so.

“In the case of high-rises, even though Townsquare is private property, that does not mean that the developer can do what they want. The Tigné policy and floor area policy serve as a facility for high-rises; it does not mean high-rises have to be there.”

Echoing a concern voiced by Finance Minister Edward Scicluna, Dr Briguglio said that by relying solely on mega developments, the country risked putting all its eggs in one basket.

He pointed at the lack of progress made at Manoel Island by developer Midi, which is currently searching for a partner in order to go ahead with the €500 million development.

Manoel Island is a “mess” at the moment and should serve as a warning to other developers.

Dr Briguglio drove home the point that the Sliema local council was not opposing developments just for the sake of it.

“When the local council comments on planning applications, we are not trying to block development, we are trying to ensure that it is as sustainable and Sliema-friendly as possible.”

Though it was already too late for Sliema in certain aspects, the government was still in time to see that proper sustainable planning was placed ahead of the individual interests of big business.

Weak rock on Qui-si-Sana peninsula can be problematic for tall buildings - geologist

A protest in Qui-Si-Sana against a number of high-rise projects in the area. Photo: Mark Zammit Cordina

Ivan Martin

Times of Malta 23 June 2016

A geological study submitted as part of the Townsquare high-rise project did not flag a layer of “very weak rock” that could pose problems in supporting tall buildings, an experienced geologist has warned.

“When I say weak, I mean you can practically break the rock with your hands. It’s like chalk. This is a rock that can be problematic if tall buildings are built on it,” Peter Gatt said.

The environment planning statement compiled by environmental consultancy firm ADI as part of the application, says that the only rock types present on the Qui-Si-Sana peninsula were lower globigerina limestone, a strong rock that could support a tall structure – “in fact most of Malta’s towns are built on this rock” – and a layer of phosphate, present across most of the island.

Dr Gatt said that, besides the two layers indicated, the area included a significant amount of middle globigerina limestone, a soft rock. This was the second softest on the island, he pointed out.

You can practically break the rock with your hands. It’s like chalk

The future of the Townsquare project was meant to be decided at a Planning Authority Board hearing scheduled for today. However, the court yesterday upheld a request by residents to suspend any decision until new studies were conducted on a range of issues.

In 2005, Dr Gatt published a scientific paper on the geology of the Qui-Si-Sana area highlighting, among other things, the presence of this much weaker middle globigerina.

“Along the Qui-Si-Sana shore, there is a coastal outcrop where the middle globigerina is clearly visible on top of the phosphate level,” he said.

“What we see in these published test results is a strength of between three and five megapascal below three metres of depth, that is the strength of middle globigerina and not lower globigerina, which would come in at about 15 to 20 megapascal,” he said.The environment planning statement refers to core samples extracted from the area and tested for their tensile strength. Dr Gatt said the results of these tests also “clearly” pointed to the presence of the weaker rock.

Dr Gatt questioned why no geological logs – graphic representations of the core samples taken – had been included in the report.

A scan of the coastal area featured in the report further confounded Dr Gatt, who insisted the middle globigerina was visible at outcrops of the rock face along the Qui-Si-Sana coast.

Architects who spoke to this newspaper warned that the presence of this rock could mean that the developers would have to take a number of precautionary measures, which would include a reassessment of the foundation structures to be laid and of the excavation works to be carried out.

Questions sent to the Environment and Resources Authority yesterday had not been replied to by the time of writing.

Sliema sewage shocker: Ex-Drainage Director says that Tigne' skyscrapers can lead to major sewage problems

Residents and swimmers in Sliema have noticed that Sliema's sewage system is in a precarious situation, with flows in Fond Ghadir and Qui-si-sana beach. Sliema Local Council frequently alerts WSC to clean up such flows in Fond Ghadir, and Qui-si-sana beach was recently declared not fit for swimming by the Environment Health Directorate for a number of days due to a sewage overflow. 

As things stand, Sliema's sewage system is facing problems. What will the impact of the proposed skyscrapers in Tigne' be? WSC did not reply to the impact study on this. But the ex-Director of the Drainage Department gave his qualified opinion to Times of Malta: 

Tigné high-rise projects can lead to major sewage problems

Residents say Tigné already suffers from sewage blockages

Ivan Martin Times of Malta Wednesday, June 22, 2016 

Building a number of high-rise projects in a small area like Tigné could lead to major sewage problems if their impact is not adequately studied, according to the former director of the Drainage Department.

“Without a plan of the cumulative effects of such projects, you are shooting in the dark. On the one hand developers could get blamed for sewage problems which are not their fault. But on the other, they could be building six-star developments supported by primitive infrastructure. The result would not be good,” architect Philip Grech told the Times of Malta.

With a detailed understanding of the Sliema sewage network, Mr Grech said the greatest risk such a concentration of large developments could pose could be the creation of what is known as a point load – an excessive burden on a small section of the subterranean sewage network.

“This needs to be looked at in advance, before construction. There are mathematical models you can run based on the system and the flows expected. These could give an indication of what needs to be done,” Mr Grech said.

He was contacted yesterday after concerns were raised that the Water Services Corporation had not given its input on the impact a proposed 34-storey Townsquare tower could have on the Sliema sewage system. The corporation did not reply when asked earlier this week why no impact assessment was provided and Mr Grech said this had caught him by surprise.

“If such an assessment was not provided then it is worrying as the WSC really knows what the current system’s capacity is and if there are any problems that need addressing,” he said.

The Sliema local council and residents have meanwhile complained that the Tigné area was already suffering from sewage blockages and high-rises would likely overload the system.

Mr Grech said the last major overhaul of the Sliema sewers had been conducted back when he was responsible for the system in the early 1990s. At that time, the area was changing from one predominantly made up of two and three-storey buildings to five-floor apartment blocks. Projects earmarked for Tigné had also called for the laying of a new pipeline to handle the additional flow, he said.

Would this be enough to support the burden of all those flushes from high-rise buildings? Again, studies would give a clearer indication, Mr Grech said.

He pointed out that buildings were rarely at full occupancy, and so, while the tall buildings had the potential to add much more sewage to the system, this depended in part on the developers’ ability to attract buyers.

Drawing on his experience in the field, Mr Grech said the island’s sewage system was one of the most overlooked parts of the island’s infrastructure.

“The possible need for an upgrade does bear looking at. You could ignore the system and be fine, or you could end up with people driving to their multi­­-million euro apartment and being faced with overflows, blockages and the nasty sights and smells that come with that,” Mr Grech said.

Sliema residents will today be organising a protest at the Qui-si-Sana Gardens to voice their concerns of tall buildings being erected without adequate studies and plans.

Fort Cambridge hotel project not ‘validated’ 

The Environment Impact Statement for the Townsquare development had
not included the impact of a proposed Fort Cambridge hotel project because this had not been “validated”, a Planning Authority spokesman said.

Reacting to criticism that the Townsquare project was being assessed in isolation, the spokesman said that the authority’s regulations stipulated that only those projects that were approved for consideration could form part of studies.

The spokesman denied allegations by the Sliema local council that there would be a shortage of parking for the Townsquare project. He also defended a report conclusion that peak hour traffic on the Tigné Peninsula had decreased. This, he said, had been based on traffic counts carried out by appointed traffic consultants.

“During this week’s public meeting, the Planning Board which will include a representative of the Sliema local council will have all the facility and time needed to query the conclusions and recommendations made by both appointed consultants and the Planning Directorate prior to taking an informed decision,” the spokesman said.

More information:

Townsquare SkyScraper Report - Shocking statistics and missing data - Click here

Protest against the Skyscraper proposal - George Bonello Dupuis Gardens, Qui-si-Sana, Sliema, 6pm, Wednesday 22^nd June 2016.- click here for more info

Planning Authority meeting to decide on the proposal - click here for more info and to reserve a place