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I refer to the article titled ‘Stopping minister Pullicino and MEPA’. Whilst appreciating Mr Martin Debono’s interest in MEPA’s work, it would have been pertinent to address feedback on the draft document through email on fortcambridge@mepa.org.mt, enquiries@mepa.org.mt or through normal post in addition to restoring solely to the media to air his views. To date MEPA has no such input.
With regards to the letter, the following clarifications are being made by MEPA.
Regarding the statement that the Brief includes direct references to Structure Plan Policies, including Policy BEN 2, it is to be noted that the Draft Brief has been formulated in the light of the Structure Plan and the North Harbours Local Plan and that such policies were approved by MEPA to give direction to subsidiary plans. It is important to point out that it is standard practice to include and list such policies within Subsidiary Plans for ease of reference by the general public and hence there is nothing out of the ordinary in this particular case.
May I also take the opportunity to remind Mr Debono regarding the application of the concept of the Floor Area Ratio. This concept implies that under certain circumstances, the proposal in question would qualify for a higher development provided that a pre-determined area for an equivalent built floor space is left as open space. The principle has been established way back in 1992 through the Structure Plan for the Maltese Islands and the operational details appear in the Policy and Design Guidance which is regularly used by architects. Therefore it is not clear how Mr Debono is bewildered by the high building when a substantial proportion of the whole site is going to be left open. It is important to remind readers that more that 5000 square metres of the open space are specifically earmarked for public enjoyment.
Around two-thirds of the site will not be accommodating additional built development and development is being directed towards the environs of the existing hotel which was developed in the early 1980s. Moreover, there are safeguards to restore Fort Cambridge and limit interventions to the barracks and the surrounding spaces.
Regarding the comment that there is too much detail on the type of residential development and their floor spaces, it is noted that such a subsidiary plan by its very nature is site specific and being a technical report, it must include a requisite level of detail. May I indicate to readers that the public consultation exercise includes the opportunity for members of the public to query about details which are not clear and to suggest how these may be ameliorated.
The residential option for development is also referred to. It must be pointed out that this is only one of five possible alternatives of development for the site in question being considered by MEPA, so the site may not necessarily be developed only as a residential area. Given that the inhabited buildings directly adjacent to the site are residential in character, good planning practice suggest that the uses for the site are compatible with this land use. Therefore, if the residential use option is chosen, this would be compatible with the environmental characteristics of the area as indicated through Structure Plan Policy BEN 2 referred to in Mr Debono’s letter.
With reference to the beach concession, it is to be noted that the existing concession already forms part of the hotel site and is in fact used by the hotel at present. It is clearly stated in the Draft Brief that the concession was granted on the basis of tourism use, as a hotel. The use of this beach concession would be permitted by MEPA in relation to reuse as a hotel.
It is rather ironic that criticism is levelled for producing the document in a relatively short period of time. Actually this is taken as a complement as the document has gone through the normal channels and there was nothing extraordinary about this particular document. It seems that MEPA is now being criticized for being efficient.
Lastly, regarding the point that the Development Brief has been approved it is pointed out that MEPA has only approved the Fort Cambridge Public Consultation Draft for consultation purposes at this stage. MEPA considers public consultation as a very useful exercise in order to fully take into account the public’s views on development and conservation approaches being proposed. Public consultation is not limited to subsidiary legislation but also extends to the whole development control process. In fact MEPA is one of the few organisations that has consultation entrenched through legislation.
Sylvana DeBono
PRO
Malta Environment and
Planning Authority
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