In recent months, it has become quite clear that the planning circular PA 3/20 that aims to protect the context and setting of scheduled buildings is truly an important document that has created a wind of change. This circular was spearheaded by Environment Minister Aaron Farrugia who is keen on changing the current status quo that pervades our planning culture. Hats off to him and his team who are attempting to protect our historic buildings.
In fact, this was very much the case with the planning application for five floors within the buffer zone of the windmill at Tal-Bwier, Xagħra, Gozo. The Planning Commission refused this application in view of the protection of context. In doing this, the commission is abiding by the spirit of the Design Guidelines 2015 themselves that emphatically talk about the importance of context and reinforcing the importance of the circular PA 3/20:
“Each scheduled building is located within a spatial context with which it relates to in different aspects. The setting is therefore an essential part of the building and the way in which it is experienced. It is the area in which the building is perceived and is, therefore, a constituent part of the building’s value. For this reason, it deserves specific attention. Unlike the building which, as a static element, changes slowly over time, the setting generally undergoes greater dynamics and undergoes faster mutations. In case of interventions to the context of a building, particular care must therefore be applied.”
However, while, on the one hand, we have the ministry and others within the planning system that are truly fighting to create protection of our heritage, it appears to be the case that it is not a level playing field.
There is something very wrong with this system
I am referring, in particular, to the case of a five-storey proposal, recommended for approval, within the buffer zone of three scheduled buildings at Triq Santa Marija, Tarxien (PA 913/20). The shocking recommendation for approval ridicules all the hard work put in, since January 2020, by Farrugia for a change in tack.
It is seriously indicative of a system within the planning application that urgently needs to push the ‘reset’ button to indeed create a properly planned vision. All that appears to be happening is an automatic analysis of each application against the infamous annex 2 of DC 15, application of 17.5 metres (five floors), completely ignoring all the other planning policies and circulars that are meant to underpin planning policy.
The application in question is within less than 40 metres of no less than three scheduled buildings: Casa Manduca, a 16th-century dwelling with Melitan mouldings, a Grade 1 scheduled building at 38 metres from this development; No. 94, a Grade 2 scheduled building at 29 metres from the development; and the noteworthy historic country house dating from the 16th-century Palazzo Barbaro, a Grade 1 scheduled building at 20 metres from the development. It, therefore, beggar’s belief that the case officer report makes no reference to any of these important scheduled buildings, even stating “no constraints”.
The report is also an insult to the hard work of the Superintendence of Cultural Heritage that “strongly objects to this planning application as proposed” in more than one consultation and recommended that the street remains two floors due to it being in the immediate proximity of the urban conservation area and because of the historical context:
“The superintendence once again objects to the proposed additional floors above the existing facade. The proposed development would result in the creation of unsightly high blank party walls within such a sensitive area. Such excessive heights and volumes pose an unacceptable negative impact on the spatial context and the visual integrity of several scheduled buildings located in close proximity to the site. This runs counter to the policies and guidelines set by PA circular 3/20, P6 of the DC15 and thematic objective 8.6 and 8.7 of the SPED. Any development is to be limited to the existing two full floors as not to exceed the existing predominant height within this transitional area.”
It is indeed worrying that a case officer report is written in complete disregard of the planning circular PA 3/20, the recommendations of the Superintendence of Cultural Heritage and the objections from NGOs Din l-Art Ħelwa and the Archaeological Society and, last but not least, the Tarxien local council.
There is something very wrong with this system and we urge the minister and the Ombudsman for the Environment to see what is really happening on the ground of this beloved country.
Joanna Spiteri Staines is council member of Din l-Art Ħelwa and also an architect specialising in conservation and rehabilitation of historic buildings and sites. She is a partner at Openwork Studio and Nidum.