Mriehel high-rise photomontages in breach of Planning Authority circular

Photomontages showing the impact of the Mriehel high-rise on sensitive views like that from the Mdina bastions or Hastings Garden in Valletta were taken using a 25mm wide angle in contrast to guidelines issued by the Planning Authority, which recommend the use of a 50mm lens.

During last week’s meeting Daniel Cilia, a photographer speaking on behalf of objectors, said the photomontages presented had been taken with a wide-angle lens, which made objects appear more distant than they do to the human eye.

He also presented photos from the same viewpoints that more accurately replicated what people would actually see, showing the visual impact significantly magnified.

The Environment Impact Assessment on the Mriehel project, which included the photomontages taken with a 25mm lens, was published in October 2015.

The circular recommending the use of a 50mm lens was issued by the Planning Authority on 25 November, 2015 just weeks after the EIA on Mriehel was published.

This means that the circular was not applicable when the EIA was presented but was already in force when the application was brought in front of the PA board for a decision.

Photomontage of view of towers from Hastings Garden in Valletta as submitted in EIA, using a 25mm wide-angle

Photomontage of view of towers from Hastings Garden in Valletta taken by Daniel Cilia using a 50mm lens

Environmental NGOs present for the meeting had called on the board to postpone the decision until new photomontages were prepared. But their demand was turned down.

The circular issued by the PA specifies that when presenting photomontages showing the impact of particular projects on long distance views a “high quality digital SLR camera with a full frame sensor and a 50mm fixed focal length camera lens is used”. According to the circular the “use of a 28mm fixed focal length camera lens shall only be permitted in very particular circumstances”. 

Moreover 75mm single frame images (recalibrated from the 50mm images) are required for the visual impact assessment of panoramic views when these are presented to a wider audience 

Cilia’s argument was supported by Environment and Resources Authority chairman Victor Axiak, who in a written submission said he had personally visited the Mdina viewpoint and found the actual view was different to that seen in the photographs.

Axiak was indisposed and did not attend the meeting which decided for the high-rise towers, but had sent a memo to board member Timmy Gambin which was read during the meeting. Comments sent by Axiak on the impact of the Townsqaure project in Sliema, which was also discussed on the same day, were not read.

During the meeting FAA coordinator Astrid Vella had also questioned why photos were taken from Hastings and not from the Barrakka where the impact on views towards Mdina would have been more marked.

The Environmental Impact Assessment concluded that the impact on views from Hastings was moderate. The report found no significant impacts on long-distance views, including Mdina and Siggiewi, while the only major impact was from a popular rural walking route in the vicinity. No photomontages of views from nearby locations like Fleur de Lys were submitted in the EIA. Mriehel had been included as a high-rise zone by the government after the closure of the public consultation period and despite the fact that Mriehel lies in the line of vision between Mdina and Valletta.