Tista' taqra bil- Malti.
db Group has issued a right of reply after ten local NGOs issued a joint press statement on Tuesday. The joint press statement called for a physical Planning Authority Board meeting. The NGOs said that the proposed project would be in breach of several policies.
Newsbook.com.mt is publishing the right of reply in full:
The rule of law. Always.
Reference is made to a press release issued by a number of NGOs (16/6/20) objecting to the revised version of our Group’s proposed City Centre project in St George’s Bay, St Julians.
On the NGOs’ specific points we declare the following:
It is not true, as the NGOs claim, that “demolition of part of the barracks had already started without any regulatory supervision before being halted by the Superintendent of Cultural Heritage (SCH)”. A portion of the barracks was demolished in line with the approved permit at that time, in line with the approved SCH’s Terms of reference and in line with the method statements submitted by the Project Architects. In fact, the portion in question did not form part of the Grade 2 scheduled area and was only an accretion. Furthermore, all works commenced following a formal Clearance issued by the SCH and conducted under the supervision of an archaeological monitor.
It is not true, as the NGOs claim, that the SCH issued a stop notice related to Harq Hamiem or the barracks. The stop notice related to the opening of a number of trial pits for the purpose of geological and geotechnical investigation. In fact, the SCH duly declared that it had no objection to further on-site works to proceed.
It is not true, as the NGOs claim, that the development “will have a deleterious effect upon the residential amenity of residences”. The maximum daily increase in shade created by the project on Pembroke will be 90 minutes during some weeks in December and on only some residences. In June, for instance, the shading increases by only 30 minutes a day, and again impacting only some residences. A detailed technical sun path study covering all seasons proving this is publicly available on the PA stream.
Regarding building heights and use, the proposed development is perfectly in line with the 2006 Local Plan, the Height Limitation Adjustment Policy for Hotels as well as the FAR Policy, both approved in 2014. The objectors do not seem to understand the concept of ‘Tall Buildings’ as defined in the latter policy. Furthermore, no part of the site is within or adjacent to Pembroke Natura 2000 site. Above all, a PA permit is issued or withheld according to law, not opinions. That’s what the cardinal principle of rule of law dictates.
It is not true, as the NGOs claim, that the “visual integrity” of St George’s Barracks will be “highly endangered”. The visual integrity has already been compromised considerably by the accretions and adaptations to fit the former ITS. SCH had already issued a permit to dismantle and rebuild the barracks. Notwithstanding this permit, we decided to retain and fully restore them. Excavation plans under the building were also scrapped.
It is not true, as the NGOs claim, that the SCH objected to a proposed pool. The SCH found the pool proposal acceptable.
It is not true, as the NGOs claim, that our plans for the underground Cold War bunker are unclear. It shall be retained in its totality, preserved and made accessible from the public open space.
It is not true, as the NGOs claim, that no Character Appraisal was ever carried out. In fact, two independent ones were carried out and they form part of the comprehensive EIA assessment. In addition to this, a detailed assessment was initially carried out by Profs Conrad Thake to assess the barracks buildings. Subsequently a detailed Military Barracks Heritage Report was also carried out by the project architects.
It is not true, as the NGO’s claim, that the project poses a threat to the Harq Hamiem underground cave. Detailed studies and conclusions by the geologists and geotechnical engineers Dr Peter Gatt and Perit Dr Adrian Mifsud, who together with Solidbase prove this. The project poses no threat because 24m of rock separate it from it. In addition, only 0.5% of the project buildings overlap the cave. In addition, no excavation works will be conducted without the necessary archaeological and geotechnical monitoring.
It is not true, as the NGO’s claim, that the proposed publicly-funded tunnel is not in the public interest. It will serve all the residents, businesses and visitors to the area. The Traffic Impact Assessment ratified by Infrastructure Malta proves this in no uncertain terms.
The NGO’s are also completely twisting facts when they claim, that the Planning Authority held the db Group liable for damages for putting the project on the market. In fact we were the ones who first filed a judicial letter holding the PA responsible for damages sustained as a result of Court of Appeal ruling in July 2019) The Planning Authority subsequently filed a reply to this judicial letter as one would expect in such circumstances in order to rebut our claim for damages.
Regarding other environmental considerations, all our proposed plans will be assessed by the various entities and regulating bodies during the consultation period. It is also pertinent to note that the latest version we submitted in April reflects a substantial downscale and is thus an improvement on any former studies.
Finally, technical and more detailed submissions will be filed with the Authorities at the appropriate time.
NGOs request physical hearing on db Group’s City Centre application
Several NGOs have requested a physical hearing before the Planning Authority when the latter decides on the freshly submitted plans by the db Group for its City Centre project planned for Pembroke on the former ITS site.
Ten NGOs which are formally objecting to db Group’s plans highlighted that a virtual hearing was no substitute for a physical hearing where people could voice their opinion in line with their right to participate fully in the decision-making process, in a joint statement on Tuesday.
The organisations have submitted a detailed objection to the Planning Authority (PA) in connection with the project. They have also made available a summarized version of the objection which the general public may use through its online form.
The NGOs dismissed the claims made by the company that the project plans were significantly amended, saying that a thorough review of the revised plans revealed that the ‘project’s monstrosity remains virtually the same’.
They warned that if the planning watchdog had to give its green light to the project, the tower and the hotel proposed would engulf surrounding localities and their residents under massive structures as well as further push Paceville towards residential areas.
“The project also remains as damaging to the surrounding natural environment as it was before the revised plans.”
A number of planning policies have been breached by the proposed plan, the NGOs maintained. They stated that the exaggerated massing, volume and height of the proposed development are out of context. The proposed hotel tower – 64m high – and the residential tower – 112.25m tall – did not respect the topography and surrounding context. The shadowing cast by the superstructures would also have a deleterious effect upon the residences in the affected area.
Detrimental impact on cultural heritage was also highlighted by the NGOs.
“The visual integrity of the Grade 2 Scheduled St George’s Barracks is highly endangered and no “Character Appraisal” of the context was carried out (in breach of Circular 3/20). Extensive and extremely risky rock-cutting will take place near the Grade 1 scheduled cave system of Ħarq Ħamiem, and within the ‘Buffer/Constraint Zone’ of the same cave system.”
They added that there was no indication of whether the studies on its geological structure and vulnerability had been undertaken, and if so, on what data these studies were based on. It also remained unclear what would happen to the Cold War bunker which was discovered through the research carried out by the NGOs. They noted that from the plans it was not possible to deduce to what extent the bunker was being retained and which elements would be lost.
Volume of traffic, noise, pollution remain major concerns
The NGOs noted that there no updated Traffic Impact Assessments which would provide a holisitic overview as to whether the current road infrastructure could contain the increased traffic which would be generated by the proposed project.
Concern related to the excessive amount of traffic, noise and pollution the development would generate in the area still remained, the NGOs said.
“The application does not include the infamous tunnel being touted by the DB Group as the solution to the traffic generated by the project. Moreover, a tunnel which is not funded by the developer is in breach of the Floor to Area Ratio policy; this policy requires applicants to contribute to the costs of measures implemented to accommodate the burdens and inconveniences generated by the development.”
The joint statement was signed by Bicycle Advocacy Group, BirdLife Malta, Din l-Art Helwa, Flimkien għal Ambjent Aħjar, Friends of the Earth Malta, Moviment Graffitti, Nature Trust Malta, Sustainable Built Environment Malta, The Archaeological Society of Malta and Żminijietna – Voice of the Left