Tignè is at the centre stage for yet more major development with pending development applications being unprecedented both in scale and, more worryingly, in lack of holistic planning.

There are two towers presently being assessed by Mepa. Townsquare, a mixed development which includes the ex-Union Club site, is at full development permit application stage, while a hotel development at Fort Cambridge, which includes the ex-Holiday Inn site, is at the initial screening stage.

A reading of the oddly titled A Planning Policy Guide on the Use and Applicability of the Floor Area Ratio (FAR) 2014, hereinafter referred to as the Tall Buildings Policy, indicates that there will be intense scrutiny on the quality of the aesthetic design, which is encouraging.

In theory if we develop vertically, this should diminish the horizontal development, however based on the experience of the past 20 years such an assertion seems to be doubtful conjecture.

MIDI’s and Portomaso’s development did not save Marsascala, Xlendi or Baħrija from incongruous crammed development. Neither were many of the town houses in Sliema saved, instead we gutted them, left their skeleton, and built huge structures totally disproportionate to the street level ashes of the original house.

Tignè has been identified as one of the five locations for tall buildings in Malta. The logic adopted to select the locations was one of elimination.

The drafters of the Tall Buildings Policy list the localities where there are medium to tall buildings, then start to eliminate the ones where further tall buildings are likely to be most damaging to the characteristics of the place. Marsalforn is identified but gets eliminated, while Tignè resists the test of ‘most damaging’.

The policy does not assess any aspects of the infrastructure of the area to cater for the tall building development. There are no studies on the road infrastructure, traffic issues or the potential to develop and improve that road infrastructure. Development à la Maltija: build now, face infrastructural problems later.

The tall buildings plan states that a design for a tall building needs to “embrace principles of sustainability”. The fundamental criteria required to objectively assess the sustainability of the Tignè developments is the readiness of the area to cater for the increased residents and visitors.

The plan inadvertently encourages the developer to downplay any holistic planning to address the sustainability issues in that it states that “developers would also need to identify any measures, and contribute to the costs of their implementation, that will be needed to remedy shortcomings in local capacity to accommodate the demands generated by the development”.

It is utter delusion to think that developers will come up with remedies which they themselves will have to pay for. Suggesting that tall building developers will identify shortcomings in a capacity which they will have to address and fund is as naive as telling the inmates of Corradino that they are responsible for the locking of all gates of the building.

Many of the town houses in Sliema were not saved. Instead we gutted them, left their skeleton and built huge structures totally disproportionate to the street level ashes of the original house

Back in 2007 when the developers of Townsquare first submitted their application, an Environmental Planning Statement (EPS) submitted by the developer indicated that a major negative impact on air quality, due to operational traffic, would materialise.

Furthermore, it proposed that measures to reduce private car use in the area were to be encouraged.

A revised EPS was carried out in 2011 which, lo and behold, concluded the exact opposite, in that it stated that the impact of traffic is “negligible”.

On-site monitoring of car emissions and dust particles was undertaken for six weeks between August 9 and the September 20 of 2011.

During the same period an automatic traffic counter was installed that collected data on the volume, speed and classification of passing traffic.

Here lies one of the many flaws in the second EPS. We all know that traffic varies according to the time of the year.

The summer period chosen would not have accounted for the traffic congestion resulting from schools, whichis significant.

Another major cause of traffic at the Qui-Si-Sana seafront that was omitted is the Tignè car park entrance from Qui-Si-Sana which opened a month after the traffic counter stopped counting, on October 26, 2011.

There are other traffic variables which were not assessed in the EPS, such as the opening of a popular beach club, the increased popularity of the shopping mall and the coming onto the market ofvarious apartments.

The biggest lacuna by far in the2011 EPS was that the planned 40-storey hotel earmarked for Fort Cambridge was not contemplated.

The tall buildings plan states that: “Where there are concurrent proposals for other tall buildings, or where others are likely to follow, the implications of these should be addressed as well.”

The exchange between the drafters of the developer’s EPS and Mepa makes for entertaining reading. The data, presented in Annex 2, shows that the average measured speed of Qui-Si-Sana seafront was 30.6 km/hour, to which Mepa replied that it is not realistic.

The justification given by the EPS drafters was the absence of local factors to convert peak hour traffic to Annual Average Daily Traffic (AADT). I ask,if there was no basis for conversionhow were the projections carried out? How can a study which concludes that the average speed for Qui-Si-Sana seafront is an exaggerated 30.6km/hour be taken seriously?

Assessing the developer’s EPS calculation on the AADT still gives a bleak picture of the traffic congestion to becreated. It states that the number will increase from 23,386 to 27,627, a staggering 4,241, or an 18% increase.

This increase is undoubtedly on the downside in view of the limited period of the traffic counter, the radically changed scenarios since 2011, and the lack of a mathematical basis for conversion.

An assessment of the EPS was carried out by Mepa’s Environment Protection Directorate (EPD). The report’s conclusion lists the major and minor impacts resulting from this development. It is beyond belief that the EPD does not mention traffic congestion, not even as having a ‘minor impact’. The notion that traffic is a perception is a malady which afflicts the EPD too.

The Tignè developments offer us as a country a challenge to really plan holistically. We can’t rely on the biased and flawed studies of developers. I remain incredulous at the lack of acknowledgement that it is in the interest of the developers to ensure that future owners can get to their abode without being stuck in traffic.

Ultimately it is the State which has to ensure that the infrastructural plans are objective and implemented. Delegating this duty to the developer is going to result in an unsustainable development, wherever these towers get erected.

Paul Radmilli is a Nationalist Party Sliema local councillor.