Paceville Master Plan: Front’s reaction
Front Ħarsien ODZ notes that a masterplan has been prepared for Paceville. We note that proposed development also includes land reclamation for real estate/hotel purposes. According to the plan, the development on reclaimed land near Portomaso would comprise residential units over 50 per cent of the land, hotels on 44 per cent, offices on five per cent and “other” using one per cent.
Front Ħarsien ODZ opposes land reclamation for real estate/hotel purposes. In the specific case of Paceville, our opposition also relates to the fact that a marine protected area exists close to the site identified for land reclamation.
In view of Malta’s small size and the immediate proximity of localities, it is illogical to have a master plan for one area and not master plan for areas close to it.
Therefore, Front Ħarsien ODZ calls for a national master plan that comprises ecological, marine, social, economic, traffic and waste impact assessments before development proposals such as the one in question are processed. The national master plan should be evidence-based and should have clear indicators on Malta’s carrying capacity in relation to factors such as those mentioned above.
Front Ħarsien ODZ also calls for full transparency and therefore calls for the publication of all submissions by developers to Government and the Planning Authority
Feedback on the VO Act amendment as submitted by Front Ħarsien ODZ and Kollettiv Ambjent.
1. Front Ħarsien ODZ objects to a definition of ‘public purpose’ that rests upon the Commissioner’s discretion. A more objective account of what counts as public purpose and public benefit ought to be provided. If one is aiming at a quantitative definition, then precisely what sort of things are to be taken into consideration should be specified. If the intention is simply to exclude the promotion of private benefit as a form of social purpose, then ‘social purpose’ could be redefined in such a way, and the ‘public purpose/benefit’ clause can be omitted altogether.
2. Front Ħarsien ODZ also objects to the new definition of ‘statutes’ as regulating the operation and management of the organisations. Some organisations work better with a more fluid structure and ad hoc, democratic decision making.
Front’s proposals for the terms of reference for both ODZ Kalanka Hotel:
1. Impact on surrounding Area of Ecological Importance during the construction phase must be fully assessed. This would include impact of transportation of the raw materials, impact of works on site.
2.Project Development Statement estimates that project would create 4019 cubic metros of construction waste. Assessment should assess impact of excavation of geological features. Impacts of proposed excavations, site levelling and site clearance should be assessed. Studies must assess slope stability and possibility of cliff collapse especially in view of interventions on Globigerina Limestone which include the excavation of a tunnel on the beach should be assess
3.Social impact on bathers and people who frequent beach should be assessed. Impact on Public accessibility should also be assessed.
4. Impact of noise during both construction and operational phase must be assessed and compared to present noise levels.
5.Proposal is located in close proximity to the coastal water body MT 112 (Ras il- Fenek to Wied ix-Xaqqa), designated under the Water Policy Framework Regulations, 2004 (Legal Notice 194 of 2004). Any risk to this water body must be fully assessed,.
6.Photomontages from different viewpoints including from the direction of the sea, are required to assess impacts on landscape character and visual amenity.
7. Impact assessment on public access to coast.
8. Heritage appraisal of nearby structures
9.Impact assessment of accesibility to heritage structures.
10. Reversibility impact assessment
11. Estimates of services required (water, electricity, drainage, infrastructure, sanitary, etc..) and the impact of this at local, regional and national levels.
12. Waste generation and the cost of attending to this.
13. Impact assessment of visual and aesthetic factors (including short, medium and long distance views).
14. Ecological design factors
15. Impact assessment of water usage
16. Impact assessment of precedence setting in terms of further development on ODZ land.
1. Front Harsien ODZ objects to proposed legislation. Applications on AOCs should not be determined by an outline permits but by local plan revision.
2. In view of limited ODZ space, AOC should address national priorities and their use should be determined following public consultation and a transparent process. Applications should only be presented after such a process.
3. AOC should address collective needs of Maltese society and not of individual owners.
4. ODZ exceptions should not be extended from current state of affairs.
5. Local plans should not be relagated in importance.
6. SPED sequential approach should be followed.