Marsa: a planning mess

turkish-cemetry-marsa-malta2

The Chamber of Architects has taken the Planning Authority to task on the piecemeal local plan reviews that it has been churning out, one at a time. The latest tirade was with reference to a partial review of The Grand Harbour Local Plan (originally published in 2002) specifically with respect to a Marsa Park Site.

We have just concluded a public discussion on a Masterplan for Paceville, which was shredded by public opinion and sent back to the drawing board.

Earlier, we had the Planning Authority itself contesting whether Local Councils, NGOs and the Environment and Resources Authority  had a right to contest the decision to permit high-rises in Townsquare Sliema and in Imrieħel.

To make matters worse, instead of consolidating the environmental regulatory functions of the state, this government has opted to deliberately fragment them, thereby ensuring their reduced effectiveness by design.  In a small country such as Malta, it pays to have one consolidated authority  directed by environment professionals through whom land use planning responsibilities should be accountable.

Land use planning needs to be more focused but holistic in nature. The Chamber of Architects aptly makes the point that focusing the efforts of the partial review of the Grand Harbour Local Plan specifically on “a Marsa Business Park” without considering this within the context  of a much needed regeneration of Marsa would be a futile exercise. The decay of Marsa as an urban centre needs to be addressed at the earliest opportunity and this will not be done through piecemeal local plan reviews but through comprehensive planning “which ought to include community needs, road transport re-alignment, environment improvement and flooding mitigation measures”.

These are the basic issues which should be addressed by a local plan review concerning Marsa. Tackling major infrastructural and social problems facing the Marsa community should take precedence over any proposal for the redevelopment of the Marsa Park site. It is the whole of Marsa that should be addressed and not just one tiny corner.

The partial local plan review is ignoring the local community, just like its cousin the Paceville Masterplan did some months ago. Many years ago we learned that “planning is for people”. This seems to be no longer the case as, according to the Planning Authority, planning is apparently for business hubs, high-rises and, obviously, for developers. They seem to be very well connected, thereby ensuring that they occupy the first items of this government’s land use planning agenda.

Marsa has been forgotten over the years. With the closure of the Marsa power station now is the appropriate time to consider the various accumulated impacts on the Marsa community in order that an integrated approach to addressing them is identified. Planning is for people. That means that the Marsa community should be actively involved when these plans are being formulated, including at the drawing board stage. Land use planners should stimulate the Marsa community to speak up and involve itself in drawing up a blue print for its future.

The regeneration of Marsa is an urgent matter which should not be left unattended.

published in The Malta Independent on Sunday : 15 January 2017

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Townsquare: qed jgħadduk biż-żmien?

Townsquare.Fawlty Tower 

Il-bieraħ kont preżenti għall-ewwel seduta tal-appell mid-deċiżjoni tat-torri ta’ Townsquare.

Ir-rappreżentant legali tal-Awtoritá tal-Ippjanar nixxef lil kulħadd meta talab lill-membri tat-Tribunal ta’ Reviżjoni għall-Ambjent  l-Ippjanar [dak li sa ftit ilu kien il-Bord tal-Appell] biex jikkunsidraw li l-Kunsill Lokali ta’ tas-Sliema, l-għaqdiet ambjentali u l-Awtoritá tal-Ambjent ma kellhomx dritt li jippreżentaw  dan l-appell.

Tafu għaliex?

Għax kull wieħed minnhom kellu rappreżentant fil-Bord tal-Awtoritá tal-Ippjanar meta din ħadet id-deċiżjoni dwar it-torri ta’ Townsquare.

Uħud minnkom forsi tiftakru kemm kien hemm min ftaħar li s-separazzjoni tal-Ippjanar mill-Ambjent kien ser iwassal għal iżjed attenzjoni u fuq kollox li l-Awtoritá tal-Ambjent kien ser ikollha id-dritt mhux biss li tipparteċipa fil-Bord imma li fuq kollox kien ser ikollha d-dritt li tappella mid-deċiżjonijiet tal-Ippjanar biex tħares l-ambjent aħjar.

L-Avukat Robert Abela jidher li għandu ideat differenti minn dawk li ħabbru diversi Ministri fil-Parlament.

Inkella, dawn l-istess Ministri ppruvaw jgħadduk biż-żmien!

The Paceville Master Plan: a preliminary peek

paceville

 

In an event marking European Mobility Week, Transport Minister Joe Mizzi announced various initiatives which, if properly implemented would contribute to a reduction in the amount of congestion on our roads. Studies on the feasibility of a tram service, car-sharing and bike-sharing, as well as e-bike schemes are all welcome initiatives.

Barely 48 hours after Minister Mizzi had made his announcements, the Planning Authority published a draft Paceville master plan for public consultation which also contains a number of transport related initiatives. It is entitled Paceville. Malta’s prime coastal location. Development Framework. Given the almost simultaneous announcements, it is not known whether there was any consultation with the  Transport Ministry.

The proposed master plan seeks to establish parameters for the further development or redevelopment of Paceville in view of the high concentration of large-scale development projects in the area, most of which are still in the pipeline, including various proposals for the development of high-rise buildings. Readers will remember that, way back in 2008, a Professor Mir Ali from the University of Illinois at Urbana-Champaign USA had advised the then MEPA on the urban design strategy to be adopted when considering the future of tall buildings in Malta. (Tall Buildings: the advice ignored by the Maltese authorities TMIS, 26 June)

Professor Ali had then emphasised the need to draw up a master plan identifying and addressing the impacts of tall buildings.  This advice was ignored when the Floor Area Ratio policy was drawn up by the Planning Authority. Likewise, it was ignored regarding development proposals currently under consideration in Sliema – notably on the Tignè peninsula.

The Mott-Macdonald draft master plan for Paceville is a vindication of Professor Mir Ali’s advice. Professor Ali stressed that Malta needed to pull up its socks on issues of public transport, irrespective of whether high-rise buildings are developed or not. An efficient, integrated and sustainable public transport system is essential in under-pinning the essential infrastructure for tall buildings. Way back in 2008  Professor Mir Ali had emphasised that this must cover the whole of Malta and Gozo and should not be limited to just Paceville!

The Mott-Macdonald draft master plan puts forward three options through which it presents two contrasting transport strategies for public discussion. The first option, entitled Sustainable Transport Strategy seeks to reduce the dominance of the car and places considerable emphasis on the pedestrianisation of Paceville (including the pedestrianisation of coast), cycling facilities and bike sharing schemes, and seeks to ensure that  public transport is within easy reach – not more than a four-minute walk away.

The second option, aptly labelled Car-Based Transport Strategy defends the car’s dominance on our roads and puts the emphasis on reducing congestion by improving road intersections and better traffic management through an intelligent transport system and also proposes the introduction of a tunnel to be bored beneath Paceville. The third option, misleadingly labelled as the Balanced Transport Strategy, is a mixture of the first two options with the proposed tunnel shifted to the edge of Paceville.

The Mott-Macdonald draft strategy suggests that the third option is the preferred option.

During the coming six weeks (the length of the consultation period) we will have the opportunity to dissect the different transport strategies as well as the other proposals in the draft master plan. The draft is over 200 pages long and deals with various development, transport and infrastructural options of relevance to the various Paceville development proposals and is to be implemented over a number of years.

It is right and proper that the impacts of the extensive developments projected for Paceville are examined cumulatively and in a holistic manner. Such an attitude and methodology, if maintained throughout, can only lead to workable solutions that will benefit everyone’s.

It does, however, inevitably beg the question: why is all this applicable to Paceville but ignored in respect of the Tignè peninsula in Sliema, as well as elsewhere else?

published in the Malta Independent on Sunday, 25 September 2016 

Victor Axiaq : meta ser jirreżenja?

Victor Axiaq

L-Awtorità tal-Ambjent u r-Riżorsi immexija minn Victor Axiaq s’issa qegħda hemm għal xejn. Suppost li l-Ippjanar infired mill-Ambjent biex flok MEPA għandna żewġ awtoritajiet prinċipalment biex l-ambjent ikun iktar b’saħħtu.

Imma, sfortunatament qatt daqs illum ma kien daqshekk dgħajjef l-amministrazzjoni tal-ambjent f’pajjiżna. Meta hu magħruf li fil-memo mibgħuta mill-Professur Victor Axiaq lil Dr Timothy Gambin l-EIA dwar Townsquare f’Tas-Sliema kien deskritt bħala farsa (a sham) bil-fors tistaqsi għalfejn s’issa l-Awtorità tal-Ambjent għadha ma għamlet xejn.

L-anqas ma kellha toqgħod tistenna sa wara li tittieħed id-deċiżjoni biex l-Awtorità tal-Ambjent tiċaqlaq. Għax jekk kienet taf li l-EIA kien farsa kellha l-obbligu li tiċċaqlaq ħafna qabel. L-anqas biss indenja ruħu jinkariga uffiċjali tal-awtorità li jmexxi biex jippreżentaw il-kaz ambjentali kontra it-torri ta’ Gasan (Townsquare) f’tas-Sliema. Għax dawn l-uffiċjali, nhar l-4 t’Awwissu 2016 kienu preżenti għas-seduta pubblika tal- Awtorità tal-Ippjanar, imma kollha baqgħu b’ħalqhom magħluq. Dan minkejja l-memo li ħejja Victor Axiaq u li inżammet mistura minn Dr.Timothy Gambin.

Kif qalu l-attivisti ambjentali li iddimostraw quddiem l-uffiċini tal-Awtorità tal-Ambjent u Riżorsi dalgħodu :  l-Awtorità hi baħħ. S’issa jidher li biha u mingħajrha xorta. Ma nafx x’inhu jistenna l-Professur Victor Axiaq biex jirreżenja.

The financing of Fawlty Towers

Townsquare.Fawlty Tower

The saga of the Mrieħel and the Townsquare towers is now entering a new phase, with the planning appeal stopwatch due to start ticking shortly –  most probably towards the end of the month. It is known that, so far, Sliema Local Council and a number of environmental NGOs will be appealing against the 4 August decision of the Planning Authority to approve the “Fawlty Towers” at Mrieħel and Townsquare Sliema .

Financing of the projects is next. The banks cannot increase their already substantial exposure to loans that are dependent on building speculation. Consequently, the developers will inevitably have to seek the involvement of private citizens and, possibly, institutional investors. Most probably, the process for financing the projects has already commenced; it will involve the issuing of bonds to the public and will normally be sponsored by a bank and a stock-broking agency.

The bank or banks and stockbrokers sponsoring the bond issue will have to ensure that the bonds are subject to an “appropriateness and suitability testing” subject to such direction as the Malta Financial Services Authority  may consider necessary and suitable. Also, in the light of past local unpleasant experiences, the Authority will undoubtedly be guided by the need to ensure  that prospective investors fully understand the inherent risks of the proposed investments.  It will also ensure that detailed information is published in the form of a suitable prospectus in which the small print is both legible and understandable.

Those who finance the high-rise projects should shoulder responsibility for their impact together with the Planning Authority and the developers. They will potentially make it happen, so they should carry the can. It is important to get this message through: those who will invest in the Gasan and Tumas bonds intended to finance the “Fawlty  Towers”  should receive more than a monetary return on their investment. The moment they sign up they will also assume co-responsibility – with the developers, the Planning Authority, the bank or banks and the sponsoring stockbrokers – for this projected development .

Word is going around on the need to boycott the services and products placed on the market by the Gasan and Tumas Groups. Journalist Jürgen Balzan, writing in Malta Today described these services and products as being wide-ranging (hotels, car-dealerships, gaming, finance and property) which easily impact on the daily life of a substantial number of Maltese citizens. However, such a boycott’s only link with  the “Fawlty  Towers”  would be through the owners.  It would be preferable for a boycott to have a direct link with the offensive action.  In this context, the forthcoming bond issue to finance the “Fawlty  Towers”  presents itself as a suitable opportunity.

A boycott is a non-violent instrument of protest that is perfectly legitimate in a democratic society. The boycotting of the forthcoming bond issue would send a clear message that people will not be complicit in further ruining the  urban fabric of Sliema and ensure that development at Imrieħel is such that the historic landscape is fully respected.

A social impact assessment, if properly carried out, would have revealed the apprehensions of the residents in particular the residents on the Tignè peninsula. But, unfortunately, as stated by Sliema Green Local Councillor Michael Briguglio, the existing policy-making process tends to consider such studies as an irritant rather than as a tool for holistic management and community participation.

We have had some recent converts on the desirability of social impact assessments, such as Professor Alex Torpiano, Dean of the Faculty for the Built Environment at the University of Malta. Prof. Torpiano, in an opinion piece published by the Malta Independent this week, stressed that spatial planning in Malta needs a social-economic dimension. Unfortunately, I do not recollect the professor himself practising these beliefs as the leading architect in the MIDI and Cambridge projects on the Tignè peninsula,  a stone’s throw from Townsquare!

Investing in this bond issue is not another private decision: it will have an enormous impact on the community.

Responsibility for this ever-increasing environmental mess has to be shouldered by quite a few persons in Malta. Even the banks have a very basic responsibility – and not one to be shouldered just by the Directors: the shareholders should also take an interest before decisions are taken and not post-factum.

I understand that the Directors of APS Bank have already taken note of the recent  statements regarding the environment by  Archbishop Charles Scicluna. As such, it stands to reason that APS will (I hope) not be in any way associated with the financing process for the “Fawlty  Towers”.  However, there is no news as yet from the other banks, primarily from the major ones – ie Bank of Valletta and HSBC.

This is a defining moment in environmental action in Malta. It is time for those that matter to stand up to be counted – and the sooner the better.

published by the Malta Independent on Sunday – 21 August 2016

Boycott ta’ Gasan u Tumas? X’inhi l-mira?

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L-iskop ta’ Martin Scicluna u Edward Mallia li jħeġġu boycott tas-servizzi u prodotti li joffru l-kumpaniji fil-gruppi ta’ Gasan u Tumas għandu intenzjonijiet tajba.  Imma l-boycott avolja għandu l-merti tiegħu hu arma qadima u biex ikun effettiv irid jitħaddem sewwa fuq tul ta’ żmien.

Hu iktar għaqli li l-familja ambjentalista tpoġġi fil-mira l-proċess tal-finanzjament tal-proġetti nfushom.

Fil-mira għandu jkun hemm il-bonds li jridu jinħarġu, il-bank u l-istockbroker li jieħdu ħsieb is-sejħa għax-xiri tal-bonds.

Azzjoni ta’ din ix-xorta tista’ tkun iktar effettiva għax l-impatt tagħha ikun direttament relatat għall-proġetti tat-torrijiet tal-Imrieħel u Townsquare infushom.

Il-klijenti ta’ Victor Axiak u Timothy Gambin

Delimara EIA contents

 

Fl-artiklu tagħha tal-bieraħ il-Ħadd fuq is-Sunday Times intitolat Of hats and despicability, Claire Bonello identifikat problema oħra kbira konnessa mal-proċess tal-permessi tat-torrijiet tal-Imrieħel u Tas-Sliema (Townsquare).

Victor Axiak u Timothy Gambin fil-passat riċenti kellhom fost il-klijenti tagħhom lill-gruppi ta’ Gasan u ta’ Tumas li jiffurmaw parti mill-konsortium li twaqqaf għall-Power Station tal-Gass f’Delimara. Għalihom Victor Axiak u Timothy Gambin għamlu xogħol li kien jikkonsisti fi studji dwar impatti ambjentali ta’ dak il-proġett. Axiak dwar l-ekoloġija marittima u Gambin dwar l-arkejoloġija marittima. Ir-ritratt ta’ hawn fuq juri paġna mir-rapport tal-EIA dwar il-power station li taħdem bil-gass f’Delimara bl-ismijiet ta’ Axiak u Gambin u l-oqsma li rrappurtaw dwarhom.

Il-mistoqsija ċara hi jekk hux etiku li Axiak u Gambin jieħdu sehem f’laqgħat tal-Awtorità tal-Ippjanar li fihom jagħtu l-opinjoni u jiddeċiedu dwar applikazzjonijiet tal-klijenti tagħhom.

Axiak ma attendiex għal uħud mil-laqgħat. Imma la hu u l-anqas Gambin ma ħassew il-ħtieġa li jgħidu li għandhom xi konflitt ta’ interess. Din x’serjetà hi?

L-imġieba korretta mhiex qegħda għall-politiċi biss iżda ukoll għal kull min hu involut fit-teħid ta’ deċiżjonijiet.

The professor who messed things up

Victor Axiaq

 

Professor Victor Axiaq, Chairman of the Environment and Resources Authority, is not at fault for being absent at a Planning Authority public meeting on the 4 August which discussed the Mrieħel and Sliema high-rise applications. By now everyone is aware that he had just been discharged from hospital and was instructed to rest for 15 days.

There were various officers of the Environment and Resources Authority present for the 4 August public meeting, yet instead of entrusting one of them with presenting the environment’s case on the Sliema high-rise, Professor Axiaq preferred to entrust Dr Timothy Gambin with a memorandum which Gambin opted to keep to himself.

There were various environmentalists, Sliema Local Councillors and civil society activists present for the public hearing. Those of us who were present for the public hearing presented the environment case and managed to convince six out of 13 Planning Authority members to vote against the proposed high-rise at TownSquare Sliema. Support for the environment case from a representative of the Environment and Resources Authority during the public hearing would have been most welcome. It could also have had a determining impact.  Yet it was not forthcoming notwithstanding the presence of a number of the Environment and Resources Authority employees at the public hearing.

The split of MEPA into two separate and distinct authorities, we were irresponsibly told by Government representatives some months ago, would ensure that the environmental issues would be more easily defended when considering land use planning applications. Yet prior to the split, an official of The Environment Protection Directorate would have addressed the public hearing. On the 4 August none were invited. The only person who was briefed to speak (Dr Timothy Gambin) opted instead to ignore his brief and instead openly supported the development proposal for a high-rise at TownSquare.

Professor Victor Axiaq, as Chairman of the Environment and Resources Authority, missed the opportunity to contribute to convince the majority of members of the Planning Authority due to his two basic mistakes. He entrusted his memorandum to another Planning Authority member (Dr Timothy Gambin) who had opposing views and hence had no interest in communicating Professor Axiaq’s memorandum on TownSquare to the Planning Authority. Professor Axiaq also failed to engage with his own staff at the Environment and Resources Authority as none of those present for the public hearing uttered a single word in support of the case against the high-rise proposal. The person sitting on the chair next to me, for example, preferred to communicate continuously with his laptop correcting with track changes some report he was working on. I have no idea why he even bothered to be present for the public hearing.

Unfortunately, Professor Axiaq, as chairman of the Environment and Resources Authority, messed up the first opportunity at which the input of the authority he leads could have made a substantial difference in the actual decision taken. It would have been much better if a proper decision was taken on the 4 August instead of subsequently considering whether to present an appeal, as this will be an uphill struggle as anyone with experience in these matters can confirm.  This could only have happened if Professor Axiaq had acted appropriately, which he unfortunately did not.

Next Wednesday, the Sliema Local Council will be convened for an extraordinary session in order to discuss the planning appeal relative to the TownSquare high-rise development permit. Environmental NGOs will also be meeting presently to plot the way forward and consider whether they too will appeal the decision.

Even the Environment and Resources Authority will be shortly considering whether to appeal. In view of the way in which Professor Axiaq handled the whole issue, the Sliema Local Council and the environmental NGOs would do well if they do not place any trust in the Authority led by Professor Victor Axiaq. They will avoid ending up in another mess.

After creating this mess, there is only one option left for Professor Victor Axiaq in my opinion. He should immediately resign from his post as chairman of the Environment and Resources Authority. The sooner he resigns the better.

published in The Malta Independent on Sunday – 14 August 2016

L-ambjent marid bħall-Professur Axiaq

Stethoscope

 

Il-ġimgħa l-oħra ċ-Ċhairman tal-Awtorità tal-Ambjent u r-Riżorsi, l-Professur Victor Axiaq għax kien marid, kien jaf li ma kienx ser jattendi għal-laqgħa tal-Awtorità tal-Ippjanar. Il-laqgħa kellha tiddiskuti it-torrijiet tal-Imrieħel u ta’ Townsquare f’tas-Sliema. Huwa għaldaqstant  kiteb il-fehmiet tiegħu dwar dawn it-torrijiet f’email. Din l-email għaddiha lil Dr Timothy Gambin, membru huwa ukoll tal-Awtorità tal-Ippjanar u awtorizzah biex, fid-diskrezzjoni tiegħu, jaqra dawn il-fehmiet waqt il-laqgħa tal-Awtorità.

Għaliex il-Professur għadda l-kummenti tiegħu lil Dr Gambin? Mhux aħjar kieku għaddihom liċ-Ċhairman tal-Awtorità tal-Ippjanar Vince Cassar biex b’hekk il-membri kollha tal-Awtorità jkunu jafu l-fehmiet tiegħu?  Għaliex kien jaf Dr Timothy Gambin biss? Stramba! Mhux soltu għall-Professur li joqgħod lura milli jkun ċar ma kulħadd.

Il-Professur Axiaq inħatar membru tal-Awtorità tal-Ippjanar biex jirrappreżenta lill-Awtorità tal-Ambjent. Fid-dibattitu biex il-MEPA tinqasam fi tnejn, b’falsità kbira, diversi esponenti tal-Gvern kienu qalu li l-ambjent kien ser ikollu leħen iktar determinanti u b’saħħtu meta jittieħdu d-deċiżjonijiet. Imma fis-siegħa tal-prova, il-leħen tal-ambjent kien marid bħall-Professur Victor Axiaq, u allura ma nstemax. Bid-differenza li fil-waqt li lill-Professur nawguralu li ma jdumx ma jgħaddilu, għall-ambjent jidher li għad hemm ħafna diffikultajiet.

Il-Malta Today dan l-aħħar tkellmet dwar il-fatt li nafu x’qal il-Professur Axiaq dwar it-torrijiet tal-Imrieħel. Dan minħabba li Dr Timothy Gambin waqt il-laqgħa tal-Awtorità tal-Ippjanar qara silta mill-email fis-seduta ta’ fil-għodu, waqt id-diskussjoni dwar l-applikazzjoni għat-torrijiet tal-Imrieħel. Imma waranofsinnhar, meta kien hemm is-seduta pubblika dwar l-applikazzjoni għat-torri ta’ Tas-Sliema, Dr Gambin ma qarax fil-pubbliku dak li qal il-Professur Axiaq dwar Townsquare.

Il-mistoqsija hi għaliex Dr Timothy Gambin ma qalilniex x’jaħseb il-Professur Victor Axiaq dwar it-Torri ta’ Tas-Sliema? Dr Gambin biss jista’ jgħidilna għaliex huwa żamm l-informazzjoni għalih. Għaliex għamel hekk, hu biss jaf, s’issa. Dejjem sakemm ma jkollux il-kuraġġ li jitkellem il-Professur Victor Axiaq.

Imma, forsi, l-Professur għadu marid, bħall-ambjent. Nawguralu fejqan ta’ malajr. Mhux biss lill-Professur, immafuq kollox anke lill-ambjent.

Townsquare high-rise: an internal development

townsquare site

 

The public hearing by the Planning Authority prior to a decision regarding the issuing of the development permit for the Townsquare high-rise project was held on Thursday. The discussion was essentially channelled towards applying existing planning policy and explaining the conclusions of studies mostly carried out some eight years ago. However, as I submitted during this hearing, the proposal for the Townsquare high-rise project infringes existing planning policy.

It is known that the Floor Area Ratio Policy establishes that for a site to be considered for the development of tall buildings it needs to be surrounded by streets on four sides. In fact the expression “completely detached urban block” is used (paragraph 5.3) in the document  entitled A Planning Policy Guide on the Use and the Applicability of the Floor Area Ratio (FAR).

It is clear that, when drawing up the Development Permit Application Report, the Planning Authority case officer adopted a very wide interpretation of the term “road” without realising that the context required a strict literal interpretation.  A  member of the Planning Authority even considered it appropriate to reply to my submissions by reading out to me the definition of the term “road” as contained in section 2 of the 2016 Development Planning Act.  I was informed – in open session – by this over-enthusiastic member of the Planning Authority that the term “road” means “any road, whether public or private, and includes any street, square, court, alley, lane, bridge, footway, passage or quay, whether thoroughfare or not”.

This bright spark is probably unaware that this definition is preceded by the words “unless the context otherwise requires”. This necessarily leads to the consideration as to what is meant by a  “detached urban block” and,  in particular, whether the creation of footpaths large or small on the Townsquare site itself serves to create such “a detached urban block”.

Various doubts were expressed at the voting stage by 6 out of the 13 members of the Planning Authority present for Thursday’s sitting, leading them to vote against the approval of the development of the Townsquare project, even though the Executive Chairman considered that he had to declare in open session that the proposal (in his opinion) did not in any way infringe the Floor Area Ratio policy. Unfortunately, however, no substantial discussion took place on whether the requirement of having “a detached urban block” as the site for the proposed high-rise was being observed.

The open space around the Townsquare high-rise is a result of the 50 per cent maximum site coverage determined by the Floor Area Ratio Policy. It is an integral part of the project and consequently does not serve to detach the project from the surrounding urban blocks. In fact, this open space borders the backyards of the bordering residential properties on all sides.

The proposed development at Townsquare can be said to have an elevation on only one street, Qui- Si-Sana Seafront, due to the development of the first part of the Townsquare project some years ago. It is shielded by other third party buildings on Hughes Hallet Street, Tignè Street and Tower Road.

Access to the proposed development will be through Qui-Si-Sana Lane, Tignè Street (next to the Union Club) and a small opening between third party property onto Hughes Hallet Street in addition to the reserved point of access on Qui-Si-Sana Seafront. There is no way that this can be construed as being “a detached urban block” but rather as an internal development primarily contained by third party development.

This is just one of many reasons on the basis of which the request of a development permit for the Townsquare high-rise should have been refused by the Planning Authority. Together with various other reasons, this can be a suitable basis for contesting the decision through the submission of an appeal to overturn it.