** Deadline 15th March **
Will you take a minute to object to the Jerma proposal in its current form? ALL of us are clearly in favour of demolition of the current dangerous structure – there is no question about that. The point of this objection is to influence what is done with the space left AFTER the demolition.
The monstrous 15-storey development being planned will likely bring some low-paid jobs to the area, which is positive, but it will also harm many who reside in Marsaskala. For those of you who may not be aware, this is proposal PA/04710/18:
“Proposed demolition of existing hotel and excavation of site. Proposed construction of two levels of below ground car parking facilities, a chapel, a beach lido with pool consisting of catering facilities (Class 4D) , and a mixed use development consisting of commercial spaces at ground floor (mix of Class 4C, Class 4B and Class 3C) with 12 storeys of overlying residential units (Class 1A) and a 13 storeys high hotel (Class 3B) with roof top restaurant (Class 4D) at penthouse level and outdoors pools. Extension of the landscaped area around Torri San Tumas to create a public park and construction of a Public Open space at ground floor above the proposed parking as an extension of the existing promenade.“
Some additional info: there will be a mix of 128 self-catering apartments and 250 5-star rooms. In addition, there will be another 166 residential units. It has been alleged that the residential units have been added to generate money to finance construction of the hotel, because otherwise the development would not be “financially viable”. In other words, it has been said that the owners do not currently have enough capital to independently finance the hotel itself, so the prime waterfront residential units will be sold at (presumably) sky-high prices, in an area originally meant for tourist purposes only.
We now have the opportunity to participate in the Environmental Impact Assessment being carried out. Taking part in this consultation process is important, and quick. Some points you may wish to submit are outlined below. You can do so UP TO THE 15th March, by doing the following:
1) Open a new email
2) Email address: firstname.lastname@example.org
3) Subject line: Public Consultation re. PA/04710/18
4) Copy some or all of the text underneath the line below
5) Add your name and ID number just underneath
Thank you! The more comments, the better. Feel free to edit the text as you deem fit.
Whilst welcoming the pending demolition of the existing dangerous structure previously known as the Jerma Palace Hotel, I would like to register my concerns regarding the proposal PA/04710/18 as it currently stands, for the following reasons:
- The proposal is misleading from the start, since the application refers to 12 and 13 storeys, whereas the text in the EIA refers to thirteen storeys (residential units) and 15 storeys (hotel).
- Residential units: The Jerma area was granted by the Government through an act of parliament to Lafico for tourism purposes only. The inclusion of residential units in the plans, in an area supposedly reserved for tourism-related development only, is a betrayal of the original agreement and will irrevocably harm the area.
- 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
- It is unclear whether the tunnel underneath the proposed open space between Jerma and St. Thomas Tower is still being considered. Digging a tunnel may cause structural damage to the tower itself and requires an impact assessment, whereas if a tunnel is no longer an option, the Tower will be transformed into a glorified roundabout. As the PDS itself states: “The presence of St. Thomas Tower and the proximity to the existing residential areas may also cause adverse impacts that hinder their ‘key strategic, long distance views and important vistas at a national and local level’. “
- Marsaskala was not among the localities identified in the policy regulating high buildings of over 10 storeys. The development should be scaled down to 10 stories or less.
- Impact assessments:
No Transport Impact assessment has been carried out (as noted by Transport Malta on the 5th June 2018, who reserved its right to require consultation at a later stage)
No Social Impact Assessment has been carried out
- No consultation with residents in the area has been carried out. The Local Council have been asked to vote on very preliminary plans, 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. They are against the inclusion of residential units, and the proposal has been visibly changed since the last consultation period.
- 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.
- St. Thomas Tower will effectively be incorporated into the development and mostly hidden behind the hotel when views from sea level
- It is not clear from the site plans whether access to the foreshore will be retained, or whether it will be physically possible to access parts of the foreshore where the rubble boundaries seem to touch the shoreline. This is unacceptable; the foreshore belongs to the public, and the boulders currently blocking access (which were placed illegally when Jerma was in operation) should be removed and not retained in the proposal.
- It is unclear whether the land owners will take responsibility for maintenance and upkeep of the public open space in the area – this is not mentioned in the PDS.
- There will be a substantial shadowing effect on nearby residential properties, depriving residents of sunshine during the morning, affecting both mental health. This may also have an economic impact as investments in solar PV panels or solar heaters will no longer be worthwhile.
Thank you for your time,