Flimkien għal Ambjent Aħjar said it is objecting to a planned development at Għargħur, saying it will be an “eyesore for miles around." 

The site, in Triq Kromb il-Bahar, Sqaq Charlotte, is not, as the location description in the application implies, a vacant plot. The site forms part of agricultural land straddling UCA and ODZ, which has been purposely left to deteriorate only in the last few years.

The proposal will create huge unsightly blank party walls on the border with the Għargħur UCA which will be an eyesore for miles around, from the Salina Coastroad, up the ‘Telgħa t’Alla w Ommu’ and overlooking the Victoria Lines, jeaopardising their status as a Tentative UNESCO World Heritage Site, FAA said in a statement.

According to Policy P6 of DC15, “where development is sited immediately adjacent to an UCA and adjoins a garden in the UCA, it will be set back from that wall by a minimum distance of 3 metres. In this manner the height of the new building will reflect its context and be related to the height of the wall, the size of the garden or space, the distance of the building from that garden, and its overall effect on the garden,” FAA said.

On 18 October 2019 the SCH wrote to the Planning Authority re both PA 0481/13 and PA 0229/19, noting that they were not consulted during the processing of PA 0481/13 which is the permission being renewed with PA 4897/23. On this basis alone PA0481/13 should be revoked and certainly not be automatically renewed. The SCH wrote:

“The site in question is a large tract of agricultural land partly located within the Urban Conservation Area and partly Outside the Development Zone of Għargħur, extending downwards towards the valley overlooking the Grade 1 Victoria Lines. The Victoria Lines is an Area of Ecological and Scientific Importance and Area of Very High Landscape Sensitivity as indicated in policy CG 22 of the Central Malta Local Plan (Maps CV1-2). The Victoria Lines were completed in 1897 and have been placed on the Tentative List for inclusion as a UNESCO World Heritage Site. It is noted that the proposed development is still covered by a valid development permit (PA 00481/13), on which the Superintendence was not consulted……The land in question borders the Urban Conservation Area of Għargħur and extends downwards into the valley overlooking the Victoria Lines. A footpath leading from Triq Kromb il-Baħar towards the Victoria Lines passes along the site footprint in question….rural area in a zone that is registered in the Local Plan as a listed area and a site of scientific importance, as indicated to Central Malta Local Plan Policy CG25 (map SE1). The Planning Authority is therefore urged to implement its policies to ensure the protection of the natural and cultural landscape. It is opinion of this office that the proposed development also runs counter to planning policies, particularly, Policies P2, P3, P5, P6, P13, P14, P15, P16, P42. The proposal is also in breach of the Għargħur Local Plan and of the SPED policies for Thematic, Urban and Rural Objectives. The proposal runs counter to a number of DC15 policies including P2, P3, P5, P6, P13, P14, P15, P16, P42. Clearly this completely rules out any form of development on this site due to its very narrow configuration. In view of the above, the Superintendence strongly objects to this development application.”

Moreover, in 2019, ERA made the following recommendation for a pending development application on this same site (PA 0229/19): “This site forms part of a stretch of fields bordering the urban conservation area of Għargħur and extending down into the valley on to the Victoria Lines. Access to the proposed development is limited to a 3metres wide alley with just one entry and exit point. The proposal will ruin the skyline of this picturesque corner within the Għargħur Urban Conservation Area and destroy the character of this conservation and rural area in an area zone which is also listed as a site of scientific importance along a popular public footpath leading to the protected Victoria Lines, Malta’s most extensive national monument. In this regard, the comments in the previous ERA’s memo are still valid and are being reiterated. For these reasons we call on the Planning Authority to refuse this proposed development, and similar urbanisation of ODZ sites.” For these reasons we call on the Planning Authority to refuse this proposed development, and similar urbanisation of ODZ sites.”

In a very recent ruling the Environment and Planning Review Tribunal gave on an adjacent site in Għargħur (Appell 115/19 for PA 8051/18 – Third Party Appeal) the EPRT upheld the fact that a 3m distance should be kept from gardens within a UCA. Similarly, the Planning Commission also insisted that this distance should be respected in another Għargħur site both PA 1943/21 and PA 1824/21.

PA 4897/23 has been submitted as a new application to renew PA 0481/13. However this application has expired and its application for renewal submitted under PA 2995/20 was refused by the Court of Appeal on 1 February 2023. Therefore, this application must be processed as a new application taking into account all new planning policies and guidelines.

The site has not been committed by any development and no commencement notice was ever submitted. PA 4897/23 Central Malta Local Plan identifies land as:

The site can only be accessed through a network of alleys of less than 2.5 m in width, 270 metres to transmitting pylon, 180 metres to Triq Kromb

il-Bahar and 120 metres Sqaq Charlotte:

Traffic Congestion & Policies P13, P15 & P16 of DC15 The access to the land is extremely restricted and convoluted. The main alley is 270 metres long to the transmitting station and 180 metres to the site with no other exit. Sqaq Kromb il-Bahar, which leads to the actual site is only about 2.8 metres wide. The entire system of alleys averages a width of only 3 metres so there is practically no space for the passage of a car and a pedestrian let alone for two cars. Anybody entering or leaving the alley often ends up having to reverse the whole way back to allow another vehicle to pass.

The present scarcity of parking space and associated problems in the area are enormous. This has been the cause of much frustration and, as pointed out by the Gharghur Local Council in their representation to another application on this site in an email dated 17 January 2019, many serious arguments between the residents and visitors alike. The Gharghur Local Council had objected to the proposed development on this site. This development will not only aggravate the congestion and parking problems that already exist but will also undermine the residential amenity and quality of life.

Additionally, the site will not be accessible to fire tenders and will go against Policies P13, P15 and P16 of DC15. The development goes against various SPED objectives formulated to regulate the development of conservation areas. These are listed in the last section. Objection 7 - Destruction of rural character.

The proposed development will be accessible from Sqaq Kromb il-Bahar. The alley is particular not only for its traditional winding, narrow lanes bordered with old and restored village houses but also because it integrates the village core with the surrounding rural areas. The attached images show the urban to rural character displayed along the exact location of the proposed development. The development goes against the SPED objectives formulated to regulate the development of rural areas listed in the last section. The rubble walls leading off the existing buildings and the winding earth paths to the fields will be destroyed by the development thus going against Subsidiary Legislation 552.01- Rubble walls and rural structures (conservation and management).

As stated above the land forms part of a series of fields that border the urban conservation area of Gharghur and extend down into the valley on to Victoria Lines. A footpath leads from Sqaq Kromb ilBahar down to the Victoria Lines. The proposal will destroy the very nature of this conservation and rural area in a zone that is registered as a listed area and site of scientific importance in the Local Plan.

For the reasons listed above, FAA vehemently calls on the Planning Authority to refuse the application.

Since our objection is being made within the stipulated period, or within a day of a public holiday when closure of the representation period falls on a public holiday, FAA requested:

• That the Planning Directorate takes into account all these objections when considering this application.
• Gives confirmation of receipt of this objection and confirmation of our status as official objectors.
• That FAA be kept informed of any developments including new plans, publication of the DPA report and outside consultation reports.
• That FAA is given reasonable fore-notice of the date and time when the application is considered by the Environment and Planning Commission in order that we can attend such sitting and present additional submissions as considered appropriate.