‘Eye-candy’ photomontages can fool planners

A number of photomontages depicting the impact of new developments on existing views are falling short of the stringent and detailed guidelines issued by the Planning Authority in 2015, a probe conducted by MaltaToday reveals.

While the rules are largely being adhered to in the case of large-scale projects requiring the presentation of an Environmental Impact Assessment, for which adherence to the 2015 guidelines is mandatory, this is not always the case for smaller or medium-sized projects, which can still have a significant visual impact and may require a visual assessment.

The probe reveals deficiencies in several visual assessments presented in the past five years, including cases where cut-and-paste images were simply superimposed on Google Earth photos.

In other instances, artistic images or computer-generated 3D images and even drawings were used instead of photomontages. The probe also found a widespread use of a wide-angle lens, which lessens the visual impact of the development since most of the photo is taken by the foreground and middle-ground.

The practice of using a wide-angle lens has been denounced by environmentalists for the past decade, particularly in the case of the Mrieħel high rise development, in which a first batch of photomontages taken with a wide-angle were later replaced by a more accurate batch conforming to official guidelines.

And the Planning Authority does not have any official body entrusted with the verification of the photomontages, which means it remains unclear which projects necessitate a visual assessment and which do not, even if various entities are increasingly relying on photomontages in their assessment of both large scale and smaller projects, particularly those impacting on strategic viewpoints.

Additionally, since photomontages are not included among the list of approved documents like plans and drawings, the PA cannot take remedial action in cases where these visuals fail to accurately represent the real impact.

The purpose of photomontages, unlike that of artistic impressions, computer-generated images or 3D renders, is to illustrate what a development will look like to a person standing at the same point as the image was taken. Therefore, proper photomontages require a clear and exact baseline showing the existing view and the correct use of the camera, especially the angle. Proper photomontages are also presented in a way which enables the verification of their correctness and compliance with guidelines, by providing full information on both the viewpoint and angle used.

Use of wide angle: Wasteserv’s engineered landfill

Planning Authority’s reaction

When asked whether there is an established process to determine which projects require a visual assessment, a PA spokesperson replied that the Development Management Directorate or any deciding body, such as Planning Commissions and the Planning Board, can request photomontages to better assess the impacts of a proposed development.

But the guidelines are not applicable exclusively for applications which request an EIA “but for when and wherever a visualisation study is requested”.

In fact photomontages are also regularly requested by the Superintendence for Cultural Heritage and the Design Advisory Committee. A circular issued by the PA in 2020 had itself recommended photomontages of developments proposed next to scheduled buildings taken from strategic viewpoints.

Asked whether any entity within the Planning Authority is responsible for following up on projects after construction, to verify whether the photomontages presented during the process correspond with reality, the spokesperson replied that it is the responsibility of the person or entity requesting the photomontage to ensure that the photomontage submitted is a correct interpretation of the approved drawings submitted and approved.

From a compliance and enforcement standpoint, the PA can only ensure that the development follows the approved drawings and documents listed in the development permission, while noting that photomontages are not typically included as approved documents.

What the guidelines state:

The PA’s guidelines, approved in 2015, have established standards for visualizations of proposed buildings and other structures, which are requested during the assessment of planning applications.

While all planning applications requiring an Environmental Planning Statement (EPS) and an Environmental Impact Statement (EIS) must adhere to the requirements outlined in these guidelines, a “proportional approach”, depending on the size and context, is recommended for other applications.

For projects requiring an Environment Impact Statement, a set of photographs of the completed project, taken from the same viewpoint locations and under the same photographic conditions, must be submitted. These guidelines advocate the use of a high-quality digital SLR camera with a full-frame sensor and a 50mm fixed focal length camera lens.

The use of a 28mm fixed focal length camera lens is only permitted in specific circumstances. Visual impact assessments necessitate 75mm single-frame images recalibrated from the 50mm images to ensure proper assessment by a broader audience.

Visualizations should include all relevant viewpoint information, camera and photographic data, reading distance, and all other information used in the preparation of the visualizations.”

Examples of good practice

The guidelines have clearly raised the standards of photomontages of major projects requiring an EIA showing the real impact of various developments including the proposed Comino bungalow development by Hili, the DB project, the Sliema Townsquare project, the Mercury House project, the proposed St Albert school in Ħal-Għaxaq and the high-rise Villa Rosa development amongst many others.

Another example of good practice in a smaller project are the detailed photomontages of an old people’s home being proposed in an ODZ site in Naxxar. But this is not always the case with photomontages presented for other developments where the 2015 guidelines are not mandatory.

Cases falling short of guidelines

While a number of good photomontages have been submitted in urban studies for medium sized developments, this was not the case with a number of visual representations, some of which cannot be remotely described as photomontages.

1. Use of Google Earth image: PA 1342/22 and 1466/22-Boulder scree at Veccja and old people’s home in Swieqi

A photomontage to show the visual impact of a proposed boulder scree on a protected coastal cave, in works proposed by the public works department, is based on a Google Earth image. A graphic image is simply superimposed on the Google Earth image. This is more of an approximate artistic impression giving a useful indication of what the development would look like, but it definitely cannot be considered to be a photomontage. Yet the image is described as a photomontage on the PA’s public information system. Google Earth images were also used as a baseline in the visual assessment of a proposed old people’s home in Swieqi which was rejected a few weeks ago.

2. Use of wide angle: PA 3920/22 11 storey development in Smart City

No information is provided on the camera and photographic data and reading distance. But it appears that some of the photomontages in the visual assessment are taken with a wide-angle lens. This lessens the impact of the development since most of the photo is taken by the foreground and middle-ground, with the background reduced to a tiny proportion of the image. This is most obvious in the photomontage from Valletta breakwater. From this angle even the existing Smart City development looks considerably smaller when seen from this image than when it is physically viewed by someone looking in the same direction from the same viewpoint.

3. Use of wide angle and cropping: PA5500/22 – 13 floor Xlendi apartments

The photomontages suggest that the development will have practically no visual impact on the surroundings. This is mostly because of neighbouring developments which have mushroomed in the same area. But the impact of the proposed development is further lessened by photomontages taken with a wide-angle lens and cropped from the width. This further lessens the impact of the development since most of the photo is taken by the foreground and middle ground, with the background reduced to a small proportion of the image. Once again, no information is provided on the camera and photographic data and reading distance.

4. Use of wide angle: PA1222/19 – Xgħajra high rise

The visual assessment correctly makes a clear distinction between photomontages and artistic impressions, both of which are included in the report. But no information is provided on the camera and photographic data and reading distance.

It also appears that most of the photomontages are presented with a wide-angle view which lessens the impact of the development since most of the photo is taken up by the foreground and middle ground, with the background reduced to a small proportion of the image. This is most obvious in the photomontage from Upper Barrakka where the development is nearly invisible. The construction of the photomontages also leaves much to be desired, in particular the viewpoint of the development from Triq Dawret ix-Xatt which appears somewhat distorted.

5. Use of wide angle: PA5136/22 – Wasteserv’s engineered landfill

No information is provided on the camera and photographic data and reading distance. But most of the photomontages are presented with a wide-angle view and in very small dimensions. The wide-angle view clearly lessens the impact of the development since most of the photo is taken by the foreground and middle ground, with the background reduced to a tiny proportion of the image. The small dimensions of the presented images also contribute to lessening the visual impact of the proposed landfill.

6. Close ups and no views for afar: PA 73/21 – 10-floor hotel in Rue D’Argens

In the urban design study the visuals submitted consist of close-ups of the new building. Only one of the visuals presented gives some indication of the impact of the development on the rest of the Rue D’Argens. No medium to long-distance views have been submitted as normally required for high buildings.

7. Drawings instead of a photomontage: 4443/19 – Commercial project in Hamrun next to parish church

A photomontage of the development simply consists of a drawing. In its last submission on the project approved just a few days ago, the Superintendence for Cultural Heritage insisted that the images as presented “cannot be considered as photomontages, since they do not depict the proposal in its context”. The SCH correctly noted that “useful photomontages should be based on viewpoints within the adjacent streets.”

8. Computer generated images instead of photomontage – 2713/23 and 8866/20-Suncrest Lido and Centerparc project in Qormi

It has also become customary for developers to submit artistic impressions or computer-generated images which can be useful in assessing the visual impact but fall short of documenting the real visual impact of projects as perceived by the general public from particular viewpoints. In some cases like the proposed Suncrest lido and the Centerparc project in Qormi, the images are correctly labelled as “visuals” not as “photomontages”.

But this raises the question why computer-generated images are being presented instead of proper photomontages. Moreover, in a recent planning hearing even board members incorrectly referred to the computer generated images of the Qormi development as “photomontages.”