Ap­pli­ca­tion for villa on Safi ODZ land sees strong crit­i­cism by ERA

Malta Independent - - News - ■ Kevin Schem­bri Orland

An ap­pli­ca­tion has been filed to con­struct a house on ODZ land in Safi by Charles Pol­i­dano, and the En­vi­ron­ment and Re­sources Author­ity (ERA) has al­ready heav­ily crit­i­cised the pro­posal.

The plans sub­mit­ted as part of the out­line plan­ning ap­pli­ca­tion show that the site will in­clude a pool, an in­door pool, a cit­rus tree or­chard, land­scap­ing and a house con­sist­ing of a base­ment, ground floor and first floor lev­els. The to­tal site area ac­cord­ing to the ap­pli­ca­tion is 3,329 square me­ters.

The rel­e­vant site is lo­cated out­side the de­vel­op­ment zone of Safi, along ‘Triq San Gwann’ the ERA said. “The area falls just out­side the lim­its to de­vel­op­ment and is com­mit­ted by res­i­den­tial de­vel­op­ment on one side, by a su­per­mar­ket di­rectly ad­ja­cent to it while the sur­round­ing area is char­ac­ter­ized by agri­cul­tural fields. The South Malta Lo­cal Plan des­ig­nates the site as an agri­cul­tural area,” the En­vi­ron­ment and Re­sources Author­ity said in its com­ments linked to this ap­pli­ca­tion.

“ERA con­sid­ers the cur­rent pro­posal ob­jec­tion­able from an en­vi­ron­men­tal point and the fact that it is an in­fill site, this should not be used as a pre­text to gain fur­ther de­vel­op­ment per­mis­sions and ex­pand­ing the range of land uses in this par­tic­u­lar agri­cul­tural area.”

The ERA noted that the sub­mit­ted pho­tos do not il­lus­trate the ex­ist­ing sit­u­a­tion within the site in ques­tion. “In fact, the ar­chi­tect has only sub­mit­ted pho­tos il­lus­trat­ing the bound­ary wall and the gate con­structed on site with­out the ap­proval of a per­mit.”

The ERA said that an en­force­ment no­tice is­sued on the site in 2018 by the Plan­ning author­ity notes that the build­ing of foun­da­tions of struc­tures in­side the site in ques­tion has com­menced.

“It is clear that this pro­posal will com­mit un­de­vel­oped ru­ral land lo­cated beyond the de­vel­op­ment zone bound­ary, to ac­com­mo­date ur­ban de­vel­op­ment, thereby re­sult­ing in sig­nif­i­cant en­croach­ment onto this par­tic­u­lar area.”

The ERA said that its con­sis­tent po­si­tion in re­la­tion to such pro­jects has been and con­sis­tently re­mains, “that there is no valid jus­ti­fi­ca­tion for the fur­ther loss of un­de­vel­oped land out­side the de­vel­op­ment zone bound­ary, along with the as­so­ci­ated en­vi­ron­men­tal im­pacts to ac­com­mo­date such use. There is also sig­nif­i­cant con­cern re­gard­ing the cu­mu­la­tive en­vi­ron­men­tal im­pact caused by the nu­mer­ous ad hoc pro­pos­als for new mod­ern res­i­den­tial dwelling be­ing pro­posed on ODZ land, and in this par­tic­u­lar case about the open­ing up of the rem­nant ru­ral lands over­look­ing the site in ques­tion to de­vel­op­ment pres­sures.”

The Su­per­in­ten­dence of Cul­tural Her­itage has also sub­mit­ted its com­ments. “This lo­ca­tion is known for its high de­gree of ar­chae­o­log­i­cal sen­si­tiv­ity. Recorded ar­chae­o­log­i­cal dis­cov­er­ies in the area in­clude tombs at Triq ix-Xarolla, Triq il-Kuċċard, Triq il-Fdal­i­jiet Pa­le­okrist­jani, Triq Safi and be­neath Saint Bene­dict Sec­ondary School, as well as vine trenches, struc­tural re­mains and an­cient quarry marks.”

The Su­per­in­ten­dence rec­om­mends that any de­vel­op­ment on the site foot­print must be sub­ject an ar­chae­o­log­i­cal in­ves­ti­ga­tion.

The Su­per­in­ten­dence be­lieves that the ap­pli­ca­tion runs counter to a ru­ral pol­icy, “which states that the pro­posed build­ing on Out­side De­vel­op­ment Zone land is lim­ited to a pre­vi­ously ex­ist­ing ‘dwelling (even if the for­mer use was not res­i­den­tial), pro­vided the ex­ist­ing build­ing to be con­verted has a min­i­mum hab­it­able area of 100m² (hab­it­able area refers to the roofed in­ter­nal space be­tween walls), pro­vided the site is al­ready ser­viced by a road net­work that would ad­e­quately cater for the pro­posed residence’. The site foot­print is shown as unoc­cu­pied on the 1968 sur­vey sheet.”

They said that, should the Plan­ning Author­ity con­sider this foot­print for fu­ture de­vel­op­ment, the pro­posed de­vel­op­ment must not pose a threat to cul­tural her­itage re­mains that may sur­vive within the foot­print of the pro­posed de­vel­op­ment. In or­der to in­ves­ti­gate this risk the Su­per­in­ten­dence made a num­ber of re­quests, in­clud­ing that the site be sub­ject to an ar­chae­o­log­i­cal eval­u­a­tion.

“In the ab­sence of the re­quested ar­chae­o­log­i­cal eval­u­a­tion, this out­line ap­pli­ca­tion can­not be ad­e­quately as­sessed and should there­fore be re­fused.”

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