January 2017

In the wake of the approval of the Townsquare and the Mriehel Towers, Din l-Art Helwa launched the Skyscraper Campaign to raise the funds necessary to make appeal cases against these two permits. The first hearings took place in November, and the process will resume in January.

The response from the public, was extremely encouraging, and goes to show that many have taken this issue very much to heart; that it is not just a concern for those who live in the neighbourhood, but rather, of nation-wide interest. Many arguments have ensued, both in the media and in private; are we against all high rise buildings? Do we need them, and what will the effects of this kind of development be on our country?

We felt that we had to rope in the knowledge of an expert in the field, and invited Dr Michael Short from the Barlett School of Planning, University College London, to come over to Malta and give us his advice. Dr Short’s expertise is specifically in the field of tall buildings and heritage. We took him all around the island, and organised meetings and discussions with various architects and Din l-Art Helwa Council members over three intense days. He studied the Floor Area Ratio Policy, which gives the paramenters within which tall buildings may be approved, the two approved projects of Townsquare and Mriehel, the Paceville Masterplan, and gave us a report with his recommendations, which I shall highlight here.

The first significant comment which he makes is that although the Floor Area Ratio Policy, is a “useful, comprehensive and strategic document”, the spirit in which it was drafted is being ignored in its implementation. Moreover, the status of the document is being questioned, as has been pointed out by Din l-Art Helwa, seeing as it was never subjected to a Strategic Environmental Assessment, and that the site of Mriehel was never open to public consultation. He also notes that “characterisation studies”, are lacking, and should have been carried out on various areas, to understand what to protect, and how to go about further development.

“Characterisation studies are a method of examining and understanding the fabric, form, topography and design within a particular geographic area, thereby establishing its character and what makes the place special and unique1. It can underpin the development of specific design guidance in providing baseline information about the character of the area or city in question.”

He states that he is very concerned about the impact that the towers proposed on the Tigne Peninsula will have on the character and significance of the world heritage site of Valletta.

Regarding the Paceville Masterplan, Dr Short says;

“There is, no doubt, potential in Paceville to absorb some development but the amount, extent and density of development can only be outlined based on a robust examination and understanding of infrastructure capacity in the area. The masterplan does not do this.”

He goes on to make several recommendations, based on his discussion, which are reproduced below:

1 Infrastructure-led national spatial strategy

Malta should implement an infrastructure-led national spatial strategy. This should examine the capacity of the country to absorb development, identify growth poles where higher density (including potentially taller buildings) might be appropriate, protect the character, significance and value of the country’s built heritage, and protect greenspace and the non-built up areas of the island. This strategy should be coherent, nationwide and react to the particular circumstances of Malta. In addition, the role of strategic environmental assessment in assessing major development proposals should be outlined including how the cumulative impacts of development might impact at the strategic level.

2 View management framework

A Malta-wide view management framework2 – following on from the national spatial strategy – should be developed which seeks designate two different elements: firstly Malta-wide panoramas (such as from Mdina to Valletta) which are strategic in nature and which are vulnerable to major development at the national level; and secondly, views of the urban townscape (townscape views, such as from various points in the Grand Harbour into the built up area surrounding Valletta) which might be from a number of fixed points but which also might be experienced moving through particular areas as a pedestrian (or from one of the many ferries as a passenger). Each view has specific characteristics that contribute to an appreciation of the character of the country at different spatial scales.

3 Tall buildings policy and FAR

The FAR policy as it stands should be robust. It is clear however that this is not being implemented in the spirit that it was developed. As such, the status of the FAR should be clarified, particularly through the appeals process for both the Sliema and Mrieħel towers. This is a priority. The future implementation of the FAR can only be augmented through the adoption of the other recommendations in this report. In any future review the FAR policy there should be two priorities: firstly to make sure that the implementation of FAR augments and enhances the protected views established as part of the view management framework; and secondly, to promote more tangible and useful public benefits through the planning process. It should be additionally be augmented by a clearer design quality element which refers to the elements of tall buildings and how they should be approached from a design perspective.

4 Characterisation study and the world heritage site

In relation to the Valletta world heritage site, UNESCO and ICOMOS should be approached as a matter of urgency to explain two things: firstly, the approval of the two applications in Sliema and Mrieħel and the impact of these proposals on the character of Malta as a whole, and the towns themselves; secondly, it should promote a number of characterisations studies which seek to understand the fabric, form, topography and design within a particular geographic area, thereby establishing its character and what makes the place special and unique. The priority areas for these studies are Valletta, Sliema and Paceville.

5 Paceville Masterplan

Based on the national spatial strategy, protected views and an appropriate characterisation study, a new masterplan should be developed which seeks to understand the capacity of Paceville to absorb development and thereby promote realistic development strategy. The current draft masterplan does not take into account the infrastructural capacity of this part of Malta in seeking to promote major and significant development. It should therefore not be adopted in its current state.

6 Design Advisory Committee

The role and status of the DAC should be reviewed at the national level. Design review is an administrative mechanism to control the visual quality of proposed additions and alterations to the built environment3. In southern Europe, the aesthetic review of new building proposals has a long history of assessment by learned architects, historians and artists for example whilst in North America most large cities have formal design review processes that legally involve key actors such as planners, conservationists, public agencies and the public itself. For a design review body to carry out its function effectively, probity and transparency is key. The UK House of Commons4, for example, suggests that design review bodies should be publicly accountable and publicise how design review decisions are undertaken and reached, and who was involved in that decision. This should mean that the process of design review becomes more transparent and open to question specifically about how decisions are reached and by whom.

Din l-Art Helwa endorses Dr Short’s report, and will be making recommendations to the authorities based on it.


1 Thomas, R. M. (2004) Urban characterisation: improving methodologies, English Heritage Conservation Bulletin (47) 11-17.

2 The London View Management Framework, for example, establishes four different types of views worthy of protection.

3 Kumar, S. (2003) Information in design review, Planning, Practice & Research 18 (4) 243- 263.

4 House Of Commons (2005) Government response to the ODPM Housing, Planning and Local Government and the Regions Committee Report on the Role and Effectiveness of CABE, London: April 2005.