Flimkien għal Ambjent Aħjar said Friday it is objecting to a planning application to build a seven-storey block in Misraħ tal-Madonna Medjatrici, Triq Ganni Bonavia, Zabbar.

This proposal to build 7 storeys does not respect the Local Plan height limitation of three storeys and will inevitably set a precedent for more multi-storey buildings ruining the traditional streetscape, the NGO said in a statement.

This proposal violates Urban Objective 3.7: To identify, protect and enhance the character and amenity of distinct urban areas by protecting and greening open spaces which contribute towards the character and amenity of urban areas; the proposed replacement building will not result in an improved or more pleasant streetscape. This project will increase soil-sealing due to the destruction of most of the garden and contrary to the applicant’s declaration, the project will be destroying many existing trees.

We highlight the fact that at 48m from the Zabbar Parish Church, the building’s facade falls within the setting of a Grade 1 Scheduled building therefore the following Circular 3.20 policy applies: “an assessment of the setting of Grade 1 scheduled buildings must include all levels of the context – immediate, wider and extended”.

The proposal, according to FAA, also violates SPED Thematic Objective 8: To safeguard and enhance biodiversity, cultural heritage, geology and geomorphology by:

1. Identifying, designating and managing areas, buildings, structures, sites, spaces and species for protection and appreciation

6. Re-appraising the value of the character, amenity and distinctiveness of designated areas and sites for their built heritage value

Urban Objective 2: To improve the townscape and environment in historic cores and their setting with a presumption against demolition of property worthy of conservation by:

a. Control design, form, scale, density and type of development

3. Adopting a context driven approach to the control of building heights within Urban Conservation Areas

4. Development within historic sites is to be carried out in such a manner so as to ensure that the historic sites’ skyline is not adversely affected 

Urban Objective 3: To identify, protect and enhance the character and amenity of distinct urban areas:  

6. Establishing appropriate building heights and development densities

7. Protecting and greening open spaces which contribute towards the character and amenity of urban areas, reduction of soil sealing and support biodiversity with a view of developing ecological corridors

Finally, we emphasise that the accommodation of elderly and infirm patients on high storeys violates EU norms of care of elderly people due to the high risks involved in evacuating bedbound patients or patients suffering from dementia/Alzheimer’s from upper storeys in case of an emergency. The Planning Authority should not be complicit in exposing elderly people to such danger.

For the reasons listed above, FAA vehemently calls on the Planning Authority to refuse the application.

Since our objection is being made within the stipulated period, or within a day of a public holiday when closure of the representation period falls on a public holiday, FAA requested:

  • That the Planning Directorate takes into account all these objections when considering this application.
  • Gives confirmation of receipt of this objection and confirmation of our status as official objectors.
  • That FAA be kept informed of any developments including new plans, publication of the DPA report and outside consultation reports.
  • That FAA is given reasonable fore-notice of the date and time when the application is considered by the Environment and Planning Commission in order that we can attend such sitting and present additional submissions as considered appropriate.