Żonqor development: impact studies lacking due to zoning ‘ruse’

A 5,000sq.m green area inserted in the Żonqor development zones in 2006 could be slated for a five-storey block of 118 apartments, because the Planning Authority’s case officer argues that its “holistic design” would be preferable over piecemeal developments on single plots.

While a final decision will be taken by the PA’s planning commission on 27 October, it turns out the GAP Projects development does not include the entire site zoned for five-storey heights back in 2019.

The 8,000sq.m area had been rezoned on request of developer Anton Camilleri.

This would mean that traffic, visual and environmental impact studies from GAP will not take into consideration the development of the entire site, which borders on a Special Area of Conservation and is set to alter the skyline from across the bay.

Significantly, as is the norm in the planning process, no traffic assessment and visual studies were conducted for Camilleri’s zoning application.

Camilleri is a co-owner of the land being developed by GAP, which naturally has the consent of the different owners of the site. But the 2019 zoning request also included another 2,240sq.m plot and an 800sq.m plot, adjacent to the GAP site – all owners granted their consent to rezoning.

This means it is very likely that, following approval of the GAP project, other permit requests will follow, to develop the entire site without any studies assessing the development in its entirety.

The photomontage of the proposed five-storey, 118-unit apartment block

No mercy for carob trees

This development application is marred by incorrect information on the presence of trees and rubble walls on site.

In October 2021, GAP failed to declare the presence of carob trees and rubble wall, instead stating unequivocally that no trees would be felled and no rubble walls will be demolished. The case officer report also stated that “although within the original submission it was declared that there are no trees on site” this omission was rectified in subsequent plans, which indicated the presence of these trees and rubble walls.

But Malta’s Trees and Woodlands Protection Regulations do not protect carob trees when these are located inside a development zone. So the Environment and Resources Authority concluded that no nature permit is needed for their uprooting, and simply recommended “efforts” to transplant the trees and incorporate them in landscaping.

Ironically, the same carob trees would enjoy full protection had this site not been included in the notorious 2006 extension of development zones.

Neither the ERA nor the case officer made reference to the fate of a hedgehog community in the area. While objecting to the development, Moviment Graffitti had also called for a condition obliging the developer to relocate the hedgehogs with the assistance of Nature Trust. The NGO also warned that excavations may leave a high vertical rock wall which could endanger animals living in the area.

Despite the close proximity to the Special Area of Conservation, the ERA exempted the project from an Environment Impact Assessment, which means no study was conducted on the impact on this sensitive location’s flora and fauna.

The case officer did acknowledge “an environmental impact” from the permanent loss of the area, but conceded that it had now been rezoned for five-storey heights since 2019.

The case officer also acknowledged that long-distance views from Triq Is-Salini and Triq Il-Blajjiet would see the skyline “change significantly with the proposal”, contradicting the previous case officer’s claim on the 2019 rezoning that five-storey heights “would have minimum impact on long distance views”.

Now the case officer concluded that GAP’s development is coherent with the area’s urban setting with a holistic design approach, ignoring the fact that the application does not include the whole site.

The GAP development will generate around 60,000 cubic metres of inert material from excavation, soil clearance and rubble walls, but this was not considered a significant impact – “as long the ex-excavation waste and rubble walls are reused and recycled.”

GAP’s project development statement says geotechnical investigations will “assess the quality of the excavated rock and its suitability for re-use.”

Development will increase traffic by 662 trips

And while the development will create an average 662 new car trips a day in this presently quiet area, the case officer claims the impact is addressed through “the implementation of sustainable measures such as provision of electric vehicle charging bays; parking spaces for motorbikes, bicycles and electric scooters,” which would limit air quality impacts.

Although any development over 75 apartments is obliged to carry out a Traffic Impact Assessment, this obligation was waived due to a “scoping report” that deemed there would be no congestion in an area with already low traffic.

A traffic consultant’s report declared that a holistic development like this one was preferable to separate developments.

No decorative lighting can be applied to the building being close to the Inwadar nature park, a special area of conservation of national importance.