Objection submitted to the PA:- Moviment Graffitti is hereby objecting to PA 3488/19 for the Excavation of site and construction of 3 star apart-hotel (Class 3B) and ancillary facilities comprising, 38 parking spaces in basement levels, four retail spaces (Class 4b) and one restaurant (Class 4D), two bars and lounges (Class 4C), gym area and two pools (Class 3C), 118 guest rooms over six floors (Class 3B), landscaping work including maintenance of rubble walls for the reasons outlined below:
1. Commitment to the North West Local Plan (2006)
According to the North West Local Plan Mellieha East Policy Map the proposed development is not only outside of the development zone, which should immediately nullify the application, it is also within the siteline of the existing Urban Conservation Area. The site also falls within an area designated by Map 4 North West Local Plan Areas of Agricultural Value as “NGAW1 Areas of Agricultural Value” and as such should be protected.
By undermining the unique and unobstructed view from the UCA over prosperous fields this development would create a dangerous precedent for the degradation of Malta’s unique coastline and agricultural areas.
2. Commitment to the mission statement of the Planning Authority
The Planning Authority states in their mission statement that, The New Planning Authority secures a balanced and sustainable environment for our community and provide a better quality of life through a sustainable land use planning system.
We believe that this development would serve only to degrade the quality of Mellieha’s agricultural environment, on which the region prides itself, but also does not provide sufficient evidence that it could justify this damage to the environment by bettering the quality of life for the residents of Mellieha. We believe the development of yet another hotel complex within the area is excessive and in direct contradiction to the Planning Authority’s commitment to secure a balanced and sustainable environment.
3. Oversaturation of similar properties within the locality
Mellieha currently offers more than 100 tourism accommodation options many within the proposed scope of the development such as Luna Holiday Complex, db Seabank Resort + Spa, and Mellieha Holiday Complex all within one kilometer of the proposed development.
In 2018, according to the National Statistics Office, the average occupancy rate for three star hotels in Malta was only 65%. This statistic would suggest that Malta is not without sufficient similar accommodation and as such this development would be unnecessary and excessive.
In light of our above objections, we trust that the Planning Authority will agree that this development does not align with the laws and ideology to which they are committed and as such recommend the development for refusal.
