Over recent years the Planning Authority [PA] has processed, and more often than not approved, dozens of requests to develop multi-storey hotels.

One recent request that has caused apprehension concerns an 11-storey hotel over a 667sqm plot on Triq Santu Wistin ( just behind Baystreet Complex) in Swieqi, on a site presently occupied by a detached villa.

Under the North Harbour Local Plan, the site is designated as a ‘Residential Bufferzone’. The intent behind such designation is to provide some form of a transition between the entertainment area of Paceville and the residential area in Swieqi.

The permitted uses for this Residential Buffer-zone include retail, offices, as well as fast-food and take-away establishments, the latter being allowed only if restricted to the ground floor level. The policy also allows uses related to assembly and leisure, such as cinemas and theatres, as well as language schools. A hotel is not listed as a permitted use.

The Local Plan only permits these uses provided that they ‘will not cause any deleterious impacts on the neighbouring residents.’

The policy also restricts development on this site to a maximum height of 3 floors. Such a low-lying development would inevitably curtail the impact of any of these uses by restricting their scale.

An 11-storey hotel with 141 rooms can by no means be considered the type, or scale, of development envisaged and permitted under the Local Plan for this site. However, in the world of Planning (at least locally) things are never so straightforward.

This massive increase in height that well exceeds the 3floor building height limitation may be considered through the Hotel Height Adjustment Policy of 2014. Under this policy developers are allowed to gain at least two additional floors over and above the stipulated building height limitation. So, in this case, the site may be considered as having a building height limitation of 5-floors.

In addition to that, thanks to amendments to the Development Control Design Policy, Guidance and Standards in 2015, 5-floors is no longer translated to read five actual floors as would seem logical. Instead, 5-floors is converted to the metric value of 25 meters. One could cram up to 8 floors within 25 meters. This phenomenal increase in built floors was further aided thanks to additional amendments made to the Health and Sanitary Regulations in 2016, where the minimum internal height of any habitable room was lowered from 2.75 meters to 2.60 meters.

By making amendments to three seemingly separate planning regulations, the PA increased permissible building heights across the board. By doing so through incremental changes, as opposed to a holistic change of the Local Plans, the PA also availed itself of having to assess the cumulative impacts of these changes.

In this case, the three separate amendments turned an area that was zoned (and is still technically zoned) for 3storey buildings into one where 8-storey hotels can be considered.

The present request for 11floors is still (remarkably) over and above the already inflated permissible building height of 8-floors, and hotels are still technically not allowed within this Residential Buffer-zone, however asking for more than you are entitled to seems to be the nature of development requests in Malta.

The Environment and Resources Authority is assessing whether this project qualifies for an Environmental Impact Assessment and has requested information with regards to the projected increase in traffic flow in order to assess whether studies on air quality and noise impact will be required.

Meanwhile, the Malta Tourism Authority has already issued its clearance for the 141-room hotel, prior to any studies concerning the development’s impact having even been published.

The Superintendence of Cultural Heritage has expressed its reservations due to the development’s proximity to the Grade 2 scheduled Monks Convent of St. Augustine and St. Rita Chapel. The heritage watchdog noted that these historical sites have already been ‘significantly overshadowed’ by other developments. At 11storeys, this ‘ excessive’ hotel ‘will create extensive blank party walls on each side of the proposed building’, visually impairing these heritage properties.

The site is also just 80m away from the Grade 1 scheduled Villa Rosa. The development will block and scar long-distance views surrounding the iconic villa that despite all the ‘progress’ in the area still stands as a historic landmark atop St Georges Bay.

It’s obvious that an 11-storey hotel providing 141 rooms, will impact the neighbouring communities. Entertainment hubs like Paceville should be strictly contained and not allowed to sprawl, further impoverishing the lives of the surrounding residents. Their wellbeing should not be compromised by permitting multistorey hotels in areas that were simply never intended for such high-impact developments.

By making amendments to three seemingly separate planning regulations, the PA increased permissible building heights across the board