FAA objects to the above-mentioned Application on the grounds that the site in question had been found to be of ecological importance as well as the fact that it would contravene Malta's adherence to EU Conventions against development of the sea-shore and right of public access to such seashore both of which are also enshrined in Malta's code of laws.

The structure being proposed was not included in the original project which was permitted on the basis of the formula of the FAR Regulations which would be violated with the encroachment of extra land.

There is no justification for this development and questionable feasibility as out of Malta's over 70,000 empty properties, 4,500 are located in Sliema and St. Julians. The area is already over-developed and over-populated, suffering from noise and traffic congestion day and night, as well as shadowing from surrounding buildings. This has been recognised in the Local Plans:

NORTH HARBOURS LOCAL PLAN:

Issues. B, Urban design/Conservation and Quality of the urban densities ; In localities such as Sliema and St Julians further development would exceed environmental capacity through further noise, traffic, overshadowing, sense of enclosure and degradation of the public realm

1. Discussion: The environmental capacity concept implies that if an urban area is pushed beyond certain limits, there is a risk of destroying the very things that are valued and give the area its special character/advantage over other areas.

A Promote Efficient use of Land: There is pressure in localities such as St Julians and Sliema to increase building heights from existing levels. However, many of the coastal belt residential areas have reached their environmental capacity and require a more restrictive approach to further developmental intensification.

- The proposed development is unacceptable since it does not comply with policy BEN 1 : "The development will not normally be permitted if the proposal is likely to have a deleterious impact on existing or planned adjacent uses..."

The proposed development is unacceptable since it does not comply with policy BEN 2 : "Development will not normally be permitted if it is incompatible with the good urban design, natural heritage, and environmental characteristics of existing or planned adjacent uses, and is not likely to maintain the good visual integrity of the area in which it is located..."

- we furthermore submit that the application is registered in the wrong street as no part of the site abuts on Church Street which is in fact quite a distance away from the actual location of this planning application. We therefore maintain that the residents' right of notification was violated and call for this application to be re-issued on the right address.

Access to information on this case is also impeded by the fact that Case Officer Reports (see below) and the EIA for the original project are not freely available and therefore extra time for study is required.

As our objection to this application is being made within the stipulated period (ie. first working day after a deadline which falls on a public holiday) we request that we are recognised as official objectors and kept informed of any developments and hearings on this case by communicating with us at the above-mentioned email and street addresses.

Flimkien ghal Ambjent Ahjar

www.ambjentahjar.org