Respond to the Public Consultation – ex-Jerma Palace Hotel, Site Development Brief*

** Deadline 11th November **

*Updated: It’s even worse than we thought. Figures below have been updated.

Here we go again. Back in February we urged residents of Marsaskala to respond to the public consultation and object to the monstrous Jerma Hotel proposal. You can read more about what has happened since April in our blog post here. The new owners are now asking for PA’s blessing for an extra 39,000sqm of visible floor space. That’s right, the development application we last heard about in February states on page 4:

“The site will have a total gross floor area of 92,000 sqm, split into 61,000 sqm above plaza level and 31,000 sqm below the plaza.”

Translation: the visible portion of the building was spread over 61,000 sqm in the 2018 application, with the remainder (parking and services) being underground. Now, the owners are asking for the visible portion of the building to be spread over 100,000sqm instead. An increase of 64% over the 2018 application!

ALL of us are clearly in favour of demolition of the current dangerous structure. The point of this consultation is to influence what is done with the space left AFTER the demolition. In order to get rid of the current eysore, do we need to have forced down our throats a 15 storey high-rise and at least 166 new apartments in Marsaskala, with all the additional traffic problems this will invetiably cause? The monstrous 15-storey development previously proposed would likely bring some low-paid jobs to the area, which is positive. However, given the historically low unemployment rate Malta is enjoying, we wonder whether the economic argument is worth making at all. We also ask ourselves, given looming tourist accommodation oversaturation and industry warnings to beware of investing in new hotel accomodation, whether 15 floors (9 more than the current Jerma building) of hotel rooms is justified. Why not keep to the current, relatively low-lying building design? Why include residential buildings at all, when Marsaskala is so overcrowded and its infrastructure strained to its limits?

We now have the opportunity to send our representation to the public consultation – doing so is both important and quick. Representations should be as personal but as knowledgeable as possible. Numbers count! Some points you may wish to submit are outlined below. You can do so UP TO THE 11th November, by doing the following:

1) Start a new email to smlp@pa.org.mt
2) Subject line: Response to open Public Consultation – ex-Jerma Palace Hotel, Marsascala Site Development Brief – South Malta Local Plan (2006) (Phase 1)
4) Copy some or all of the text underneath the line below – feel free to edit and make your representation as personal as possible.
5) Add your name and ID number just underneath

Thank you! The more comments, the better. Numbers matter!


To whom it may concern,

Whilst welcoming the delayed demolition of the existing dangerous structure, and expressing concern at the lack of enforcement, I would like to register my concerns regarding the new site development brief for Jerma Palace Hotel. Over the years, the abandoned hotel has become a structurally unsafe site, with a number of recorded accidents occurring, and effectively depriving the general population from the full
enjoyment of the coastline surrounding it. Marsaskala is struggling with infrastructural issues relating to overdevelopment, public spaces are declining, and property prices are rapidly becoming unaffordable for the local community. While there is a strong general consensus that the current building needs to be demolished and the site needs to be rendered safe, with full access to the coast, a large-scale development could make Marsaskala a less desirable place to live in.

We wish the following points to be considered during discussion around this development brief:

  • We agree with the proposed demolition of the current abandoned hotel and urge the PA to reissue an enforcement order in line with the applicable legislation, and ensure that any fines applicable are collected;
  • The increase in GDF from 61,000 sqm to 100,000sqm is disproportionate, insensitive, and unacceptable, and should not be permitted. Furthermore, St. Thomas Tower will effectively be incorporated into the development: among other conditions, the Height Limitation Adjustment Policy for Hotels states that permission for an additional 2 floors over the statutory building height limitation should only be given if:

    “Site responds positively to its context including natural topography, scale, height,
    streetscape, built form and the skyline”

    &
    “Proposals should be sited where visual impact within their context and on sensitive historic environments and their settings such as World Heritage Sites, conservation areas and scheduled buildings is minimised, and should retain and enhance key strategic, long distant views and important vistas at a national and at the local level.”
    &
    The development shall not cause a detrimental impact on the local community as a result of unacceptable levels of increased traffic, noise and bad neighbourliness;

    None of these conditions apply given the proximity of the development to St. Thomas Tower. An open space should be included between the tower and the coastline so that the important visual link between the tower and the sea is restored.
  • The 166 residential units mentioned in the former application (PA/04710/18) have been added so that this massive, large-scale project can be self-financed. This is of great concern, and the mere fact that residential units are required for the economic success of the project should send plans immediately back to the drawing board.
  • Impact assessments: given the density and scale of the project, such a decision should not be taken without having adequate data at hand to highlight the issues and problems that such a large development might create for decades to come. At the very least, independent experts should be commissioned to conduct a thorough:

    (1) Social impact assessment
    (2) Visual impact assessment
    (3) Transport impact assessment
    (4) Health impact assessment
    (5) Environmental impact assessment

    These should be urgently carried out before taking any decision regarding the new site developement brief, and residents informed about the potential impact so as to be able to make an informed contribution to the decision-making process.
  • Residential units: The Jerma site was granted by the Government to Lafico through an act of parliament tourism purposes only. The inclusion of residential units, although permitted in the South Malta Local Plan of 2006, is a betrayal of the original agreement. Including residences in the plan will irrevocably harm the area and further strain the social and urban fabric of Marsascala.
  • The site should be rehabilitated to its original natural state – the land should be given back to the public to enjoy, the tower restored and rehabilitated to continue generating sustainable economic activity, and the Jerma area embellished so that it can be enjoyed by generations to come. Alternatively, only tourist accomodation should be permitted, keeping to the GDF currently occupied by the Jerma Palace Hotel
  • Marsaskala was not among the localities identified in the policy regulating high buildings of over 10 storeys. A 15 storey building will permanently alter the town’s skyline and give precedent to other buildings being raised to similar heights. The development should be scaled down to 10 stories or less, or kept to the current level
  • No real consultation with residents in the area has been carried out. The Local Council gave its approval to an earlier application (PA/04710/18) which is now being superseded, and with no real understanding of the impact that such a huge development will have on the fabric of the area, and on Marsaskala as a whole. Most residents are against the inclusion of residential units.
  • Increase in traffic and pollution in the area: this development will severely exacerbate residential traffic in the area, to the detriment of Marsaskala as a whole.
  • There will be a substantial shadowing effect on nearby residential properties, depriving residents of sunshine during the morning, affecting mental health. This may also have an economic impact as investments in solar PV panels or solar heaters will no longer be worthwhile.

    I hope you will take note of these concerns and reduce, rather than expand, the scope of the development brief.
    Regards,
    [Name]
    [ID Number]

What’s happening at Jerma?

Nothing good. Recent reports that the Jerma site is likely to be (or already has been) purchased by Joseph Portelli – the Gozitan construction baron who is lately on the news for all the wrong reasons, including construction illegalities and ODZ applications (see here, here, here, here and here) – is terrible news for Marsaskala.

Let’s rewind a bit. In our last blog post on Jerma back in April, we posted that the Environment and Planning Review Tribunal had just reached a decision (3 years after the initial enforcement notice was published) not to penalize the owners for abandoning Jerma, or oblige them to pull down the dilapidated building. Instead, they were given 30 days to present a ‘method statement’ describing what they would do to minimise the damage caused by the abandoned building to Marsaskala’s coastline. Since then, absolutely nothing has happened on the ground, except for more rubbish accumulating on the site.

Marsaskala Community & Friends decided to follow up on this and emailed the Planning Authority on the 13th September (more than 3 months after the expiry of the enforcement notice) asking for an update:

Email sent to Planning Authority by the MC&F

We received a reply on the 25th September stating:

Dear Sir,
 Referring to your email below, kindly be informed that a Method Statement has been submitted and is currently being evaluated by the Planning Authority.
[Customer Care, Planning Authority]

Not very informative, but hey, at least the method statement has finally been submitted… it’s only been a few extra months anyway. No penalties of course…

Something is brewing…

On the 18th October 2019, a public consultation on the Jerma site was launched by the Ministry for Transport, Infrastructure and Capital Projects. The consultation proposes a number of objectives for a Site Development Brief (which sets out the planning parameters for development of the site…amazingly, this had never been done previously). We reproduce the relevant ones below:

Request by the Government for the preparation of a Development Brief for the site of the ex-Jerma Palace Hotel, Marsascala.

a) To designate the site shown in Map A as a Comprehensive Planning Area for Regeneration of the Urban Coast;

b) To promote the development of a mix of land uses which shall include:

• Tourism accommodation which must include Class 3B (Use Classes Order (SL552.15) hotel/s
which shall never be smaller, in terms of Gross Developable Floor space (GDF), than the ex-Jerma Palace Hotel;
Category A residential uses (Use Classes Order (SL552.15) which shall not exceed 40% of the total allowable GDF;

c) To ensure that the overall development density
does not exceed 100,000 sqm GDF, excluding spaces for car parks and services, irrespective of the position of the floor space in relation to any street level;
…….

Map A of the Site Development Brief. Note how St. Thomas Tower is now included in the site.

In addition to the inclusion of St. Thomas Tower in the site plan (Map A), objective (b) is truly shocking. It is clear that the developer is betting on people not understanding what 100,000 sqm (square metres) of development means for Marsaskala.

By the numbers…what do they mean?

  • The current site boundary of the Jerma Hotel occupies 17,500 sqm. All of the current abandoned building and landscaped areas fit within this area. All of the proposed development will also have to fit within this area.
  • According to the Floor-to-Area Ratio policy, the scale of public open space should never be less than 50% of the site area.
  • The development density (EXCLUDING parking areas and services) will be 100,000sqm. This is 63% higher than the 61,000sqm of the application currently being considered by the PA. Based on the site brief, not less than 40,000sqm of the density will be dedicated to residential use (apartments), and 60,000sqm to a mix of tourism and commercial use.

Now for some math…

  • Assuming FAR applies, the land area actually available for building is:
    17,500 ÷ 2 = 8,750sqm
  • Assuming all of the above area will be built up, and dividing 100,000sqm by 8,750sqm, gives us a figure of 11.4. At this point, these are just assumptions as we do not yet have a project application to look at, but let’s say that the building or buildings (previous applications have proposed more than a single building) will be around 11 floors high as a minimum. Each floor equates to roughly 3m height, give or take, depending on use, so the building will be around 34m high.
  • Assuming that an existing policy loophole will be exploited (while the policy regulating high-rise buildings excludes Marsaskala, the policy regulating hotel heights permits four and five star hotels to extend their accommodations to more than two floors over and above the permitted number of floors in the Local Plan), let’s add another 2 floors – equivalent to 6m – to the total height.
  • This brings the potential total height of the building up to 40m. Again, these are rough estimations, but for the moment they are what we have to work with.

In short, it’s a monstrosity

Anybody living in Marsaskala should be horrified at this news. Think about it… the current Jerma building is around 5 storeys + penthouse above street level. Think about what a building 3 times this height will look like. What kind of shadows will it cast?

ALL of us are clearly in favour of demolition of the current dangerous structure. The point of this consultation is to influence what is done with the space left AFTER the demolition. In order to get rid of the current eysore, do we need to have forced down our throats a 15 storey high-rise and at least 166 new apartments in Marsaskala, with all the additional traffic problems this will invetiably cause? The monstrous 15-storey development being planned will likely bring some low-paid jobs to the area, which is positive. However, given the historically low unemployment rate Malta is enjoying, we wonder whether the economic argument is worth making at all. We also ask ourselves, given looming tourist accommodation oversaturation and industry warnings to beware of investing in new hotel accomodation, whether 15 floors (9 more than the current Jerma building) of hotel rooms is justified. Why not keep to the current, relatively low-lying building design? Why include residential buildings at all, when Marsaskala is so overcrowded and its infrastructure strained to its limits?

What can you do about it?

You could send an email to smlp@pa.org.mt with your objections. These should be received by 11th November 2019. We are working on a template submission and will post this for you to copy/edit and send in the coming hours.