The db Group has responded to claims made by NGOs regarding the former ITS site application, stating that a number of arguments made by the latter are false.

The db Group issued a right of reply in response to the statement that Several organisations submitting an objection to the Planning Authority (PA) in connection with the ex-ITS site project. Among other things, they argued that "it is not true that the Superintendence of Cultural Heritage issued a stop notice related to Harq Hamiem and the barracks," arguing that the notice related to the opening of a number of trial pits for geological investigations.

The Group also denies that the project "will have a deleterious effect upon the residential amenity of residences."

"The maximum daily increase in shade created by the project on Pembroke will be 90 minutes during some weeks in December and on only some residences. In June, for instance, the shading increases by only 30 minutes a day, and again impacting only some residences. A detailed technical sun path study covering all seasons proving this is publicly available on the PA stream."

The db Group also highlighted that the underground Cold War bunker shall be retained in its totality, preserved and made accessible from the public open space.

Right of reply:

On the NGOs' specific points we declare the following:

It is not true, as the NGOs claim, that "demolition of part of the barracks had already started without any regulatory supervision before being halted by the Superintendent of Cultural Heritage (SCH)". A portion of the barracks was demolished in line with the approved permit at that time, in line with the approved SCH's Terms of reference and in line with the method statements submitted by the Project Architects. In fact, the portion in question did not form part of the Grade 2 scheduled area and was only an accretion. Furthermore, all works commenced following a formal Clearance issued by the SCH and conducted under the supervision of an archeological monitor.

It is not true, as the NGOs claim, that the SCH issued a stop notice related to Harq Hamiem or the barracks. The stop notice related to the opening of a number of trial pits for the purpose of geological and geotechnical investigation. In fact, the SCH duly declared that it had no objection to further on-site works to proceed.

It is not true, as the NGOs claim, that the development "will have a deleterious effect upon the residential amenity of residences". The maximum daily increase in shade created by the project on Pembroke will be 90 minutes during some weeks in December and on only some residences. In June, for instance, the shading increases by only 30 minutes a day, and again impacting only some residences. A detailed technical sun path study covering all seasons proving this is publicly available on the PA stream.  

Regarding building heights and use, the proposed development is perfectly in line with the 2006 Local Plan, the Height Limitation Adjustment Policy for Hotels as well as the FAR Policy, both approved in 2014. The objectors do not seem to understand the concept of 'Tall Buildings' as defined in the latter policy. Furthermore, no part of the site is within or adjacent to Pembroke Natura 2000 site. Above all, a PA permit is issued or withheld according to law, not opinions. That's what the cardinal principle of rule of law dictates.

It is not true, as the NGOs claim, that the "visual integrity" of St George's Barracks will be "highly endangered". The visual integrity has already been compromised considerably by the accretions and adaptations to fit the former ITS. SCH had already issued a permit to dismantle and rebuild the barracks. Notwithstanding this permit, we decided to retain and fully restore them. Excavation plans under the building were also scrapped.

It is not true, as the NGOs claim, that the SCH objected to a proposed pool. The SCH found the pool proposal acceptable.

It is not true, as the NGOs claim, that our plans for the underground Cold War bunker are unclear. It shall be retained in its totality, preserved and made accessible from the public open space.

It is not true, as the NGOs claim, that no Character Appraisal was ever carried out. In fact, two independent ones were carried out and they form part of the comprehensive EIA assessment. In addition to this, a detailed assessment was initially carried out by Profs Conrad Thake to assess the barracks buildings. Subsequently a detailed Military Barracks Heritage Report was also carried out by the project architects.

It is not true, as the NGO's claim, that the project poses a threat to the Harq Hamiem underground cave. Detailed studies and conclusions by the geologists and geotechnical engineers Dr. Peter Gatt and Perit Dr. Adrian Mifsud, who together with Solidbase prove this. The project poses no threat because 24m of rock separate it from it. In addition, only 0.5% of the project buildings overlap the cave. In addition, no excavation works will be conducted without the necessary archeological and geotechnical monitoring.

It is not true, as the NGO's claim, that the proposed publicly-funded tunnel is not in the public interest. It will serve all the residents, businesses and visitors to the area. The Traffic Impact Assessment ratified by Infrastructure Malta proves this in no uncertain terms.

The NGO's are also completely twisting facts when they claim, that the Planning Authority held the db Group liable for damages for putting the project on the market. In fact we were the ones who first filed a judicial letter holding the PA responsible for damages sustained as a result of Court of Appeal ruling  in July 2019) The Planning Authority subsequently filed a reply to this judicial letter as one would expect in such circumstances in order to rebut our claim for damages.

Regarding other environmental considerations, all our proposed plans will be assessed by the various entities and regulating bodies during the consultation period. It is also pertinent to note that the latest version we submitted in April reflects a substantial downscale and is thus an improvement on any former studies.

Finally, technical and more detailed submissions will be filed with the Authorities at the appropriate time.