Din l-Art Helwa comments to the Malta Environment and Planning Authority on the Review of the Height Limitation Policy for Hotels in Tourism Areas

30th September 2013

1.   All planning policies must be based on sustainable development. This means that the profitability of the tourism industry should not be the sole aim of this revised policy. Environmental aims must be included as a main priority.

2.   Which factors are going to influence the proposed ‘design-based’ criteria? Decisions on ‘design-based development criteria’ and ‘unique aesthetic characteristics’ should not be in the hands of planning case officers or planning boards. The application of these criteria would not be acceptable in the absence of an independent and expert Design Review Committee.

3.   This policy allowing individual buildings to be constructed without height limitations in urban areas will lead to haphazard planning outcomes with potential for huge negative impacts on surrounding areas. The predicted negative impacts on surrounding neighbourhoods must be clearly defined and taken into account in the formulation of this policy review. How are adjacent neighbourhoods to be safeguarded against the negative effects of this policy?

4.   Until the revised regional plan for Gozo is approved, no development applications to increase hotel heights in Gozo should be considered.