Unlike most sites within the development zone, the former-Jerma hotel is not regulated by a specific set of planning parameters dictating what can or can’t be built.

Instead, the policy concerning the site basically states that before any applications for development can be considered, a development brief would first have to be approved. The development brief– a form of site-specific planning guidelines – would need to be based on objectives set out by the Planning Authority.

Following instructions from the government, the Planning Authority started this process, and in mid-October the objectives of the development brief for the former-Jerma hotel were issued for public consultation.

The objectives have raised serious concerns.

First off, in one simple move, the site being referred to as the ‘ex-Jerma’ site and being subjected to this development brief, more than doubled in size from that which was originally intended to be considered in the 2006 Local Plans. In addition to the former-Jerma hotel grounds, the area being reviewed now includes all the open public space extending from the original site to the coast, as well as the historic St Thomas Tower, its surrounding open space, and everything in between. From an area of just over 18,000sqm, the site grew to roughly 52,000sqm.

The entire coastal area being included in the brief is presently completely natural and free of any commercial activity. It is protected as a public open space in the 2006 Local Plans. It is not designated for development. There is absolutely no reason to include this natural coast within the boundary of the ex-Jerma development brief unless there were intentions to change the policies governing it.

The St Thomas Tower and surrounding area is also governed by its own policy in the 2006 Local Plan. Under the policy this historic tower and its surrounding grounds are reserved for cultural use.The open space is not designated for development. Again, why include these sites of national importance within the confines of the development brief that is meant to regulate only the use of the ex-Jerma site which will be privately developed.

The other issue of major concern is the proposed capping of developable floorspace at 100,000sqm. To understand the implications of the figure, consider this, the present building occupying the site has a floorspace of about 30,000sqm split across five levels. Therefore, at 100,000sqm of developable floor area, any new development that would occupy the same footprint as the existing could beat least 16-storeys in height. Through this review, the Planning Authority is essentially paving the way for a high-rise development in Marsascala.

On what basis is the Planning Authority justifying introducing a high-rise development in the South of Malta? How was the figure of 100,000sqm reached? Were there any studies carried out on the area’s carrying capacity? Was there an assessment of growing economic trends? Were there any considerations for the implications of a development of this type of density on the environment and community? Or is it just simply reflecting what the potential developers of this site want to get out of it? 

Such a mammoth figure cannot be proposed without research backing it.

By committing the site to a developable floorspace of 100,000sqm, it is essentially being committed to a major project that will bring with it high-user density, high infrastructural demands, increased traffic and further environmental strains on the local community.

Any studies carried out after having already committed the site to this extent of development would be trivial. It essentially also renders the whole process of this public consultation exercise futile.

The other issue of major contention is the introduction of residential use and any ‘other uses which the Authority deems can contribute to the regeneration of this part of the urban coast’. ‘Other uses’ can literally mean anything. Where is the planning in that? How is the Planning Authority taking control of how this site will be developed through such an open ‘objective’?

The objectives set out by the Authority should have been based on careful assessment of the carrying capacity of the area and centred around the community’s needs. Moreover, the objectives should have set out a clear direction for the development brief to follow. The more detailed the objectives are, the more control the Planning Authority will have over what can or cannot be built. A development brief should not be something prepared in a vacuum and most certainly should not turn into a developer’s wish-list.

Tara Cassar is an architect focusing on planning policies and environmental issues related to land-use, active with a number of local eNGOs.

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