“Planning policies are being rendered useless”
Dr Antoine Zammit, academic and our founder at STUDJURBAN, is a prominent figure in Malta’s urban design planning, having also authored the influential DC15 policy document. In his recent podcast interview with Jon Mallia, which has just been made public this week, Dr Zammit tackled topics such as building heights, planning policies, urban mobility as well as the unfeasibility of a metro system.
“Development is not a right and policies do not give automatic rights to development. They are there to guide. And it is a pity that after so much work was put into them, these policies are being undermined by decisions that go against some of the document’s provisions,” was Dr Zammit’s first thought-provoking statement.
Perit Zammit delved into the intricacies of Malta’s Development Planning Act and the significant issues plaguing the island’s development trajectory, giving a lengthy, heartfelt commentary on the constant abuse of guideline policies and the profound impact of their negative shaping of the urban landscape.
“The hierarchy of policy documents is there, established in our Development Planning Act. We have everything in place to guide us when regulating development and deciding development planning applications to ensure better outcomes.
“Although the guiding policies are informed by context and good street design, they are being undermined by decisions that go against some of the document’s underlying provisions and an indiscriminate application of Annex 2’s provisions height interpretation in metres without consideration of contextual safeguards.
“Unfortunately, people pick and choose parts of the policy that apply to them. As a result, these policies have been rendered useless because decisions that outrightly go against them become existing commitments with more weight than the policy provision itself. This is what is leading authorities to repeat the same mistakes and contributing to a lack of informed strategic planning.”
Building height and the value of the street
“Culturally, we need to start looking again at the value of the street whose aesthetics are being eroded by the blatant ignoring of the important height-to-width ratios, especially in UCAs, where a ratio can provide a basis on which future building heights could be established.
“There is an underlying assumption by developers, authorities and Government alike that what should be considered as a ‘maximum’ height is an ‘absolute’. This is a major problem in most localities where many buildings are reaching heights that are not necessarily warranted everywhere.”
Dr Zammit explained that whereas the Local Plan Interpretation document of 2007 stated that ‘development proposals should strictly adhere to the number of floors stipulated in an approved local plan’ thus suggesting an ‘absolute’ height approach and development that respected both the height in metres and the number of storeys, there is the recent Circular 2/24 that states: ‘The Local Plans approved between 1995 and 2006 included maps outlining building height limitations, expressed in terms of the maximum number of floors allowed for each urban block’ – an admission as it were, that height is a ‘maximum’ consideration and not ‘absolute’.
“So now we are talking about ‘maximum’ consideration and not ‘absolute’ building height!”
“It is not true that Dc15 Annex 2 increased building heights indiscriminately. If we compare the building heights in metres given by the previous policy document DC07 and DC15 Annex 2, we find that they either match or were marginally rounded up.
For instance, the largest number of properties designated in the Local Plans have ‘three floors plus semi-basement’, which meant achieving In fact, a street façade height of 14m was achievable with DC07 and, similarly, with DC 15 this is 14.1m, with a setback floor over and above in both instances.”
“What has happened is that prospective applicants (aided by subsequent changes to the Sanitary Provisions Law in 2016 and a planning interpretation of the 1m parapet wall at setback floor level) have opted for the minimum internal height to ‘squeeze in’ extra floors where this was previously not permissible, due to the need to also adhere to the number of floors as specified in the Local Plans,” he added.
“A critical change that DC15 did was the elimination of the semi-basement (nearly a full floor) and the replacement with a proper ground floor that reintroduces harmony and horizontal alignment in the street, which the introduction of the semi-basement had disrupted, while providing a better street interface and improved internal environments.”
Perit Zammit referred to the notion of transitioning and how the lack of it, is leading to our villages losing their identity.
“Planning has long stopped following the landscape’s topography, with the Local Plan changes compounded by the indiscriminate application of heights in metres as an absolute, everywhere, right till the edge of the development zone. Similarly, the DC15 introduced the concept of ‘transition’ to offset the Local Plans’ disregard of this between the Urban Conservation Area and the rest of the scheme.”
On urban mobility
Dr Zammit spoke about Studjurban’s Slow Streets project and revealed how a very recent study by Studjurban in Naxxar found that 85 per cent of traffic through Naxxar’s centre was through-traffic.
“Why are we allowing so much through-traffic in our village cores and killing their liveability? With Slow Streets, we want to give back streets to residents and the community and help people understand that we cannot afford to remain a car-centric society at the cost of losing the freedom of enjoying our open spaces in our communities.”
In some localities, the idea behind Slow Streets is slowly taking off.
“Change happens slowly but people need to experience change in small doses without too much disruption.”
Density, mix, access
According to Dr Zammit, a far better quality of life can be achieved if the country’s vision takes into consideration density, mix and access, “three principles that need to be considered and seen together.”
Asked about the metro project, Dr Zammit was outright.
“It’s definitely a non-viable idea. Society, lifestyles and demographics are changing at a fast pace and by the time a metro is nearing completion in 20/30 years, it will already need to change to accommodate a changed Malta.”
“But ultimately, any debate concerning future urban development, density, land use, mobility and infrastructure boils down to political will,” concluded Dr Zammit.