A controversial DC15 planning policy document is routinely misinterpreted to favour decisions that intensify development, its author has said.
The Development Control Design Policy, Guidance and Standards, better known as DC15, is back in the news, as the Planning Authority is seeking to formalise a controversial interpretation of how building heights should be calculated.
Height limitations for buildings were set by the number of floors that could be built in any given area, as set out by the local plans.
But a change in how the policy is interpreted would see the maximum height of a building calculated, in metres rather than floors, which critics say will allow developers to squeeze in an extra floor, creating more dense buildings.
Architect Antoine Zammit, who was the lead author behind DC15, told Times of Malta that when DC15 was drawn up, it had included safeguards that asked architects and planners to consider context, rather than assume that the maximum building height should be an automatic right.
“It’s a shame that the document is mostly known for its last page,” he said.
“When we were carrying out these revisions, we took the opportunity to put in urban design guidance, something that previously wasn’t there, and a lot of provisions that focus on context and streetscapes, but which conveniently many choose to ignore.”
He explained that the previous guidelines issued in 2007 had already included the conversion from floors to metres and that DC15 had taken out the need to strictly adhere to the number of floors as set in the local plan.
“When we did that, we had assumed that conversions would be of a normal-sized terraced house, around 12 courses,” he said.
'Height must be evaluated in its context'
“But when the sanitation law was revised and the minimum height of a floor went from 2.75 metres to 2.6, the practice suddenly became that if you have 14 metres then you can squeeze in as many floors as possible as long as you don’t go under the sanitation provisions.”
While Zammit understands that the policy revision the PA is proposing would essentially be formalising an absolute interpretation of building heights as a guaranteed right to the applicant, that ignores the fact that the policy says that the height must also be evaluated in its context.
“The principle of how this is being done and how heights were calculated, I don’t think that it is correct, and I don’t think it is a good thing that we are squashing in as many floors as possible right at the threshold of sanitary standards,” he said, adding that it flies in the face of the principles of sustainable developments.
He said Santa Luċija is a case in point where policy should have prevented a permit from being issued, had safeguards to adequately consider context been followed.
There is no automatic right to development, the local plan doesn’t even give you a right to develop, the only thing that does give you the right to develop is a permit- Antoine Zammit
“In some areas, it maybe makes sense to have a denser development to create an economy of scale, but in others like Santa Luċija, given the context, it is not acceptable,” he said. “There is no automatic right to development, the local plan doesn’t even give you a right to develop, the only thing that does give you the right to develop is a permit.”
Zammit thinks the way forward must include some tough decisions on where to draw the line and how to allow more dense developments, but what is sure is that the streetscape and the context of the building must be taken seriously.
“There are different ways to move forward but there needs to be a willingness to do something different,” he said.