Image – Site in Area of High Landscape sensitivity as can be seen in images forming part of application
| Date: | 23rd September 2016 |
| PA Reference: | PA 04934/16 |
| Site Location: | Site at, Triq Ta’ Gafan, Qala, Gozo |
Flimkien għal Ambjent Aħjar is hereby submitting its objectionto PA 04934/16, for the reasons listed hereunder and others it may submit at a later stage.
The site in question is within a largely undisturbed area that according to Qala local plans falls Outside of the Development Zone. The development runs counter to various policies found in the RURAL POLICY AND DESIGN GUIDANCE(as listed below) and furthermore promotes an unsustainable use of land proposing the direct loss and degradation of the environment in a highly sensitive rural area, thereby running counter to the SPED – as highlighted by the ERA.
From the RURAL POLICY AND DESIGN GUIDANCE;
- Policy 1.2H states “The Authority will seek to conserve, maintain and enhance important landscape features that contribute to the character, scenic or ecological value of the rural area.
As can be seen on the inset mapbelow taken from the SPED, the site is directly within an Area of High Landscape Sensitivity atop a predominantly undisturbed rural coast, and should therefore be protected from any development (such as that being proposed through this application) that stands to impinge negatively on this rural landscape and detract from the natural undevelopedcharacter prevalent in the surrounding context of this site.
| Image 1: Site denoted as RED dot below |
The PAs’ adherence to the protection of AHLSs is further emphasized by local plan policy, GZ-RLCN-1 which specifies that “Apart from the normal restrictions on development in rural areas, there shall be a strong presumption against thecreation of new built structures (including cultivation andanimal husbandry related structures) in AHLSs.”
- Policy 6.2C states that redevelopment of existing buildings in ODZ will only be allowed if the proposed development does not exceed the total floor area of the previous building.
This development seeks to increase built-up floor area by 5 to 6 times the area of the existing structure (the exact figure could not be confirmed as the applicant did not provide clear data on application drawings). The redevelopment area is well beyond the permissible allowed size and therefore cannot be deemed to be in line with existing policies as set out by the competent authority.
- Furthermore Policy 2C(3) states that any replacement building must be of high quality rural design and shall fully respect the wider context in which it is located.
The undetailed and vague drawings representing the proposed elevation, submitted with this application, clearly show thata minimal effort has been put into the design of this proposal.
Given the particular visual,as well as environmental, sensitivity of the site and its context, any proposed development within it would especially demand comprehensivehigh-quality design as stated in the above policy. This would be necessaryto ensure that the proposal would not impinge negatively on the rural scenic environment,and to certify that any possible measures thatcould be taken to mitigate visual as well as environmental impact have been thoroughly analysed and implemented as deemed fit.
- Rubble walls
Finally, we would like to draw attention to the fact thatany removal/replacement of rubble walls within the vicinity of the existing structure (which will likely be necessitatedthrough the approval of this development)has not been declared or depicted adequately in the application drawings.
Given the above, we call on the authority to see that no information forming part of this application is omitted or misrepresented, to ensure a fair and correct processing of said 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 requests:
- 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.