Professional Documents
Culture Documents
Appendix
Appendix
PUBLIC CONSULTATION
SUBMISSIONS BY BICC
Prepared by
K. Morris
Perit G. Vella
For
Planning Services Consultancy
September 2002
DRAFT GOZO AND COMINO LOCAL PLAN:
PUBLIC CONSULTATION
SUBMISSIONS BY BICC
INTRODUCTION
1. The Gozo and Comino Local Plan, like its predecessors, is a well-structured and
coherent document covering a wide range of issues, which has been improved by the
adoption of many of BICC’s suggestions on previous plans.
• To ensure that enough land is available for the envisaged spatial development
requirements up to the year 2012 and beyond.
GENERAL COMMENTS
Implementation
4. The plan generally has two types of policy, one type controls development, the other
identifies projects that need to be undertaken for the good of the community. In
some cases the Plan indicates the responsibility for carrying out the policy; it relies on
third parties to bring the plan to fruition. There are no indications of when the
project is needed or who will pay for it.
Public Consultation on the Draft Gozo and Comino Local Plan: Comments by BICC September 2002
Rather it is assumed that third parties will see the wisdom of MEPA’s thoughts and
take the project in hand. Such an approach is not conducive to good planning, and
runs the risk of reducing land use planning to an academic exercise. It is usual, in the
case of projects funded by Government (including Local Councils), that a
Development Programme be part of the Plan, and that the plan and programme of
works be part of Government’s commitment when the Plan is approved by
Parliament. Such a commitment includes the acquisition of land and the funding of the
development.
5. BICC would wish to point out that through the approval of the Plan in Parliament,
Government would be making a commitment to its implementation. It is incumbent
on the Plan, therefore, to indicate the nature, scale, and revenue commitment
necessary for the implementation of at least the Government-funded projects.
6. Through discussions with MEPA officers during their presentation to BICC, it was
agreed that, as a first step it would be beneficial to the public and Government
Departments if the Plan could include a table that would indicate responsibility for
implementation and the priorities as envisaged by MEPA. For example,
implementation could identify the party responsible for financing and undertaking the
project such as Government Department or Agency, or private sector initiative, and
priorities could indicate the timing of the project such as: Priority A: urgent
immediate action required; Priority B: construction to commence within 3 years;
Priority C: construction to commence within 7 years; and Priority D: construction to
commence between years 7 and 10.
Response: Priorities and implementation are outside the remit of the Local
Plan and MEPA, although there are advantages to the approach suggested
above, there are also a number of disadvantages including:
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7. It would follow from this that implementing agencies would incorporate the relevant
projects within their development programmes in the knowledge that there is a
Government commitment.
Economic stimulus
9. Although one of the main directions of the Plan is to encourage development that
creates wealth and opportunities, it is lacking in clear guidance and incentives to
encourage the private sector to bring this about. Such incentives could be direct
fiscal measures, or they could be through the clear interpretation of polices and
guidelines at site level.
Building heights
10. The general policy of maintaining current building height limits is supported.
However, although height limitations are clearly indicated on plans for each
settlement, it is surprising that para 4.2.4 indicates that in scheduled areas other
height limitations might apply. In order to avoid doubt, it would be appropriate to
clearly indicate height limitations.
Vacant properties
11. In view of the fact that a considerable proportion of Gozo housing is vacant, MEPA’s
stance not to release further land for housing within the plan period is supported.
Land supply per se however, will not start to have an effect in reducing vacant
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property numbers until it begins to run out, and in view of the fact that there is
enough land for over 5,500 houses, that time is well beyond the plan period. In the
meantime, Gozo’s inner-urban fabric will continue to decay Land supply, however, is
not the only tool available to planners to affect the numbers of vacant dwellings.
BICC would strongly recommend MEPA to investigate policies based on incentives
such as fiscal, multiple ownership, and housing standards / densities. BICC would be
pleased to assist in this regard.
Garage industries
12. The Plan rightly acknowledges the importance of micro-industries to the Gozo
economy, and indicates they should be retained within residential areas “where
sufficient mitigation measures are undertaken to render them acceptable”. The means by
which MEPA is to implement this policy is very unclear. It is possible that the new
Section 55 of the Development Planning Act will be applied; it allows MEPA to take
enforcement action where the appearance of a site or building harms the amenity of
an area, but there are no means in law where MEPA can require an operator to do
something about noise, dust etc unless he actually makes a planning application,
infringes his permit conditions, or in the case of a non-conforming use enjoying
existing use rights action may be possible if the nature of the use changes – if for
example it attracts more traffic or employs more people or becomes noisier.
Although there is considerable case law from abroad, the latter may be challenging in
Malta.
13. The Plan should make it very clear that, in the absence of either a planning application
from the operator, or the introduction of fiscal incentives, MEPA can do very little to
ameliorate the situation.
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Amenity
15. Specific guidelines / policies are needed for noise abatement. This is especially
important in relation to plant installed in new or rehabilitated buildings, such as
central air conditioning units, lifts, and heating units. Many complaints arise from
neighbours of new buildings where such plant has been installed. It is also very
important in respect of quarrying, and noisy sports such as off-roading. Rectification
of the problem after installation is much more expensive and difficult than dealing
with the problem at the building design stage.
Air Quality
16. Since considerable volumes of data from EPD air quality and dust monitoring
programmes are available for parts of the plan area, BICC would have expected the
high levels of air and dust pollution evident in the area to have been addressed by the
Plan.
Response: Air quality data does not necessarily imply that the exact
sources are pinpointed. Additionally, it is not the role of this plan to set out
guidelines relating to air quality. Air pollution needs to be addressed
nationally at the strategic level.
The only mention is a vague statement under para 3.9, Rural Environment. BICC
finds this to be a serious omission, especially in view of the environmental sensitivity
of the islands and the problems associated with over-development, high levels of
visitors (and vehicles), and an extremely high car ownership rate. Although
translating the concept of living within our means into land use policies is not an easy
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task, through its introduction at the beginning of the plan, members expected to find
policies predicated on environmental sustainability and capacity, in particular how the
building industry might be expected to respond.
Response: Although the point is a valid one, the designated areas are
already established as such thus the envisaged impact is not deemed to be
unacceptable in these areas. These impacts are also taken into account in
the development control application stage.
Helicopter noise
20. The plan completely ignores the effects of helicopter noise, especially its disturbing
effect on humans and wildlife. Aircraft noise and the time when it arises needs to be
carefully controlled. The current location of the helicopter landing pad, which
requires the aircraft to pass close to areas that are already densely inhabited, and in
the future, as a result of development of projects like the Ta’ Cenc Heritage Park
facilities and accommodation, and Fort Chambray, the numbers of people exposed to
unacceptably disturbing noise will increase dramatically.
21. BICC recommend that MEPA investigate the feasibility of a modest coastal
reclamation (using C&D Waste) to the East of Mgarr Harbour to accommodate a
heliport. The aviation facilities have been already committed at Xewkija.
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area. Low flying helicopters can also be adversely affected by the nearby
topography and the ferry service.
Larger balconies
24. BICC feels that in situations where buildings enjoy good views, either panoramic or
in the case of inner urban areas, views of festa parades etc, there is a good case for
the depth of balconies to be increased to accommodate seating etc.
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GZ-GNPR-1 Land not covered by the Plan Policies Reference to any other relevant material
MEPA will determine the acceptability of development permission applications planning considerations gives cause for
on land, which is not covered by policies in the Local Plan, in accordance with: concern. Material planning considerations is
the zoning conditions and building alignments, Policy and Design Guidance 2000, a long standing planning concept that is
and other relevant approved policies and design guidance, Structure Plan well defined abroad through a large body
policies, and any other relevant material planning considerations relating to the of case law. It is a relatively new concept
site and to its context. to planning in Malta, and although foreign
case law may be drawn upon, it is
incumbent on the MEPA to clarify the
matters that are considered to be material
planning considerations.
Response: There is a checklist
for what constitutes material
planning considerations in the
fact folder.
GZ-GNPR-2: Release of additional land for urban uses Support
The criteria for the release of additional land for development (in addition to The requirement that the site is an infill
that identified in the Plan) are: (abbreviated) pocket makes some of the other criteria
i. Housing demand from a high rate of household growth can not be met redundant
ii. Development would be associated with planning gain Response: Changes to Schemes
iii. The site should be well-contained and not invite further sprawl of are addressed within the
development into as yet uncommitted land, and be adjacent to existing principal Development Zone
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Ghajnsielem Support
New / intensification of commercial development along the arterial route which
bisects Ghajnsielem (Triq Ta’ L-Imgarr) will not be permitted GZ-Ghjn-1
GZ-EDGE-1 Design & height of buildings on the edge of urban areas This policy could discourage the
The massing and facades of new development overlooking ODZ areas is to be construction of additional floors (setback)
designed in such a manner as to respect the traditional edge of settlement and hence the ability of the housing stock
skylines. Additionally, it shall NOT be permissible to have blank party walls at to meet the needs of the increasing
the edge of a Development Zone. In such cases, the façade would need to have population. Response: All studies
apertures and to be separated from the Development Zone Boundary by a in Inception Report and earlier
back-garden (or side garden) of at least 3m. statements in this BICC report
Unless otherwise indicated the height limitation of Development Zone Edges indicate that this problem is
are to be 2 floors with a 3-course basement (ie. As per Policy and Design
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GZ-RLST-3 Boundary adjustments Category 2 settlements (large settlements Support with the exception that the
away from urban areas): new buildings mature trees should be limited to those in
New dwelling units may be permitted if the site is in a gap of not more than 6.0 the MEPA Planting Guidelines.
m. and abuts blank party walls at least one storey high on both sides, it does not Response: Noted
contain any mature trees, the design parameters of policy GZ-RLST-2 are
observed, and the development does not conflict with any other relevant
policies in this plan.
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Signals Support
Traffic lights should be located near strategic junctions. GZ-Ghjn-2: Programming?
Response: Programming is not
in the remit of MEPA as it does
not have an implementation
role.
GZ-TRAN-4 Amenity Support
MEPA will strongly encourage schemes to secure the enhancement of the areas Programme & funding?
in and around the centre of settlements. The schemes should pay particular
Response: Programming and
attention to:
funding are not in the remit of
a) reducing traffic speeds and improving conditions for pedestrians and cyclists;
MEPA as it does not have an
b) reducing the visual impact of parking, and providing facilities for cyclists and
motorcyclists; implementation role.
c) providing more space for informal recreation, and in some cases providing
the space for street cafes and similar uses; and
d) achieving a better balance between the requirement for
parking and the need for attractive public space.
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Zebbug Support
MEPA in consultation with the Local Council will strongly encourage schemes Further details indicating the proposed
to improve road safety, increase pedestrian comfort, and upgrade programming, financing and maintenance of
environmental conditions in the main areas of visitor activity. GZ-Zbug-2 the scheme are needed.
Response: Programming and
budgeting are not in the remit
of MEPA as it does not have an
implementation role.
GZ-TRAN-5 Lorry network Support in principle
MEPA will support the introduction of a lorry route network in order to;
a) ensure that quarry traffic uses the most suitable routes; Further details indicating the proposed
b) minimize nuisance to residents; and programming, financing and maintenance of
the scheme are needed. This scheme
c) limit damage to the road network.
could place such a heavy burden on quarry
The proposed lorry route network is based on the proposed arterial / owners, thereby jeopardising the success
distributor roads, plus designated access routes to and from quarry entrances.
of the scheme. Response:
In the case of quarries SG01/SG03/SG07, MEPA will permit works to upgrade
the access route across Wied il-Kbir, to establish a lorry route, which avoids Programming, funding and
Kercem. maintenance are not in the
To ensure that the network is effective, traffic management measures and remit of MEPA as it does not
regulations will be required. This could include lorry prohibitions and possibly have an implementation role.
width restrictions to ensure that unsuitable routes are not used. In the cases
where the lorry route network overlaps the cycle way network particular
attention should be paid to providing measures that limit the conflict between
these two modes. MEPA will encourage the Malta Transport Authority to give
priority to road maintenance, both structural and routine, along the sections of
the lorry route network, which pass through residential areas. This will ensure
that problems associated with noise and vibration causing by the passage of
lorries are reduced as much as possible.
MEPA will require all applications for new quarries, or extension of existing
ones, to contribute toward the cost of introducing and maintaining the lorry
route network.
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Comino Support
MEPA will encourage the development of Destination Ports in appropriate
areas around Comino with a view to completely prohibit anchoring of individual
boats in the Marine Conservation Area established in policy GZ-Ghjn-12.
GZ-Ghjn-15
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A site of 4ha or over is safeguarded in Rabat the provision of additional school Support
facilities GZ-Rbat-6
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Ghajnsielem Support
The space due south and southeast of the Ghajnsielem parish church is
reserved for social and community facilities. Existing open spaces in the area
shall remain essentially free from built structures. GZ-Ghjn-4
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Kercem Support
The watercourse protection channel feeding into Wied tal-Lunzjata will be kept
free from any development or other obstructions to surface water flow. GZ-
Kerc-4
GZ-UTIL-9 Runoff harvest: reservoirs Support
MEPA encourages initiatives to channel surface runoff conveyed through
country-roads onto the surrounding fields and/or into appropriate agricultural
irrigation reservoirs (where permitted). These reservoirs shall be constructed
in a manner whereby the perimeter above ground shall not be higher than 1.2
m. above the surrounding soil surface and shall be constructed in random
rubble stone.
The planting of indigenous, archaeophytic or fruit trees around such reservoirs
is encouraged.
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GZ-UTIL-12 Antennae
Requests for development permission to erect antennae on scheduled buildings Support
will not normally be given favourable consideration, unless the antennae are
well hidden from view.
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MEPA will support initiatives from public agencies and the public sector which
contribute to the enhancement of the external environment of Town Centres,
such as, pedestrianisation/pedestrian priority and traffic management schemes,
landscaping of public areas and public transport services which add to their
attraction as a retail hub.
Shops in il-Borgo, Rabat Support
Whilst MEPA will promote economic activity within the Borgo, there shall be a 50m2 limit should be for shop area only
presumption against the creation of new commercial outlets with a gross floor and not include storage space.
area higher than 50 m2, .and against the creation of projecting features (such as
Response: Although MEPA
air-conditioning units), which disrupt the continuity of the streetscape.
promotes economic activity
There shall also be a presumption against the creation of new basements within
Il Borgo. Gz-Rbat-3 within the Borgo, this is
balanced against the sensitivity
of the UCA characteristics of
the area.
Gozo Communal Centre – Rabat Support
A site is reserved for the development of the Gozo Communal Centre in What about the bus terminus, the playing
accordance with a development brief approved by MEPA. field, and the football ground that are
The main objectives of the development include the upgrading of this central replaced by the communal centre?
part of Rabat, grouping of key public facilities to enhance public access, the Response: These are being
provision of employment and revenue generating opportunities, an
considered through a
underground car-park. GZ-Rbat-4:
development brief for the area.
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Strategy
TOURISM
Promote the rehabilitation of buildings for tourist accommodation
Establish entertainment priority zones
Set guidelines to upgrade open spaces
Control the appearance of non-traditional buildings
GZ-TRSM-1 Rehabilitation of buildings for tourist accommodation Support
MEPA will give favourable consideration to the sensitive conversion of
traditional urban houses of character (within Development Zones) with the
scope of accommodating tourism. In such cases, the basic planimetric features
and the facades should be as much as possible retained. The creation of back-
garden landscaping (including swimming pools) will also be encouraged except
on areas designated as ridge edge development .
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Zebbug Support
An area within the existing excavated area due north of building block at Triq
ix-Xwieni shall be developed within the context of an entertainment priority
area with a height not exceeding three (3) floors. This development should be a
high quality development which utilizes elements of the traditional Gozitan
coastal development. Public access between this development and the
foreshore should be maintained and a green wedge is being imposed. GZ-
Zbug-3
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Ghajnsielem Support
Applications by public entities to develop a pedestrian route through Incentives, funding & programme?
Ghajnsielem would be supported subject to a range of environmental conditions
Response: See previous
and possibly an EIA and management plan GZ-Ghjn-3
comments on this issue.
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Ghajnsielem Support
The site between Triq il-Gudja and Triq Hamrim is reserved for a public garden
GZ-Ghjn-5
Gharb
The area due south-west of Triq Tumas Cassar is designated as a recreational
area (subject to the Structure Plan Review).
The area due north-west and south-east of the Gharb football ground is
safeguarded areas reserved for any eventual provision of informal rural
recreation. GZ-Ghrb-1
Munxar
An area currently ODZ is proposed to be included within the development
zone for a playing field GZ-Mnxr-1
Kercem
An area in the north east of the village is designated as a recreational area
(subject to the Structure Plan Review).
The area due east of the football ground shall be to cater for future
requirements related to informal rural recreational facilities. GZ-Kerc-1
The sensitive transformation of the nursery due west of Triq Kercem into a
public garden is supported by MEPA GZ-Kerc-2
The site at L-Ghadira ta’ Sarraflu will continue to be protected as a site
supporting a freshwater community. The area around the site is to be
promoted as an informal recreational site, which doubles as an educational site
through the introduction of sensitively designed and unobtrusive interpretation
panels. Limited car-parking facilities should also be provided nearby and the
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San Lawrenz
The area at San Lawrenz due south-east of the existing primary school is
designated as a public recreational area. Additionally, a small parcel of land
ODZ touching Triq Nicholas Monsarrat and opposite Triq Dun S. Portelli is
proposed as an open-air formal recreational area GZ-Slwz-5
Sannat
Proposals for the upgrading of the sports and recreational
facilities at Sannat would be favourably considered GZ-Snat-1
Qala – geological and industrial heritage park Support
The coastal area to the north and north east of Qala is safeguarded for a Implementation, funding and programme?
geological and industrial heritage park that focuses on the geological and
Response: See previous
geomorphological heritage of the area as well as the rich traces of a long
heritage of quarrying activity (utilizing different and evolvingtechniques) in the comments on this issue.
area. GZ-Qala-2
Qawra/Dwejra Heritage Park Support
Land designated as the Qawra/Dwejra Heritage Park will be afforded protection Timing?
as an Area of Ecological Importance, a Site of Scientific Importance, an Area of
Response: See previous
Archaeological Importance and an Area of High Landscape Value. The area shall
be managed according to the provisions of clauses 15.34 to 15.40 of the comments on this issue.
Explanatory Memorandum of the Structure Plan and according to criteria of the
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Strategy
CONSERVATION
• Protection of important urban open spaces, gardens, and sites that offer key strategic and local views is given priority
• Upgrading of the urban environment
• Contain urban areas
• Promote initiatives to improve quality of rural environment
• Follow a strategy of sustainable development
• Safeguard the natural and cultural heritage, including open landscape
GZ-URCO-1 Classification of UCAs according to quality Quality is very difficult to measure and
MEPA proposes to introduce a system of classification of UCAs according to a agree on. MEPA needs to conduct public
street hierarchy that takes into account the overall quality of the architecture, consultation exercise on this policy.
streetscapes and open spaces within the various sub-areas. The hierarchy Support if the guidelines / categorisation is
(abbreviated) is: clear. This could be developed into a tool
GRADE A: No changes to the facades or alignment that would actively encourage
rehabilitation. BICC would be willing to
GRADE B: Minor alterations to the facades
participate in the development of this
GRADE C: Significant alterations to the facades including demolition policy. It is keen to explore the possibility
Discretion to be used in the introduction of new materials. of more site-specific guidance on
If a building or feature is listed under the provisions of Structure Plan policy aesthetics, streetscape and design.
UCO 7 and has more onerous restrictions than those of the UCA hierarchy,
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GZ-URCO-4 Visual Integrity Buffer Zones This policy seems to duplicate the intent of
New development in Visual Integrity Buffer Zones outside UCAs shall be the Strategic Gap Policy, albeit somewhat
restricted. Unless a UCA buffer zone has already been scheduled, a minimum more restrictive and onerous. The case
distance of 50 m. beyond the Development Zone boundary shall be adopted as for restricting built development is not
a Visual Integrity Buffer Zone. The policy context applicable to such areas shall convincing and could lead to considerable
be that related to rural conservation. In such areas, traditional cultivation and economic disbenefit to the land owners.
maintenance of existing rubble walls will be encouraged. However, requests for Response: The rationale is
new non-traditional rural development which may be legitimate in various ODZ
different. In this case, the idea
areas (eg. greenhouses, animal farms) shall be refused within the said 50m.
unless the area has been specifically designated as an Intensive Agriculture is to protect the UCA fringe
Zone. from visual clutter whereas in a
strategic open space gap the
idea is to discourage
coalescence of settlements.
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GZ-ARCO-2 Interpretation of archaeological features This does not take account of the
MEPA will give favourable consideration to development which facilitates the development of heritage areas such as at
interpretation of an archaeological monument, provided that all the following Ta’ Cenc.
conditions are observed: Response: It does because this
a) the interpretation facilities should utilize existing built structures and accesses is a general policy that applies
which do not entail any addition of vertical or lateral extensions to the to all the local plan areas.
structures;
b) in areas ODZ, the general landscape context around the archaeological site
shall be retained (see condition c);
c) the removal of accretions from nearby buildings (in the case of archaeological
features within Development Zones) and the reinstatement of traditional rural
landscapes in the case of features ODZ, will be encouraged; and d) the
provision of new access to archaeological features shall not be permitted.
Ghajnsielem Support
Better interpretation of the archeological site at Borg il-Gharib and l-Imrejsbiet Incentives & funding?
GZ-Ghjn-6
Response: See previous
comments on this issue.
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Il-Borgo
A similar heritage management plan is proposed for il-Borgo. GZ-Rbat-2
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GZ-COAS-1 Public Coastal Access MEPA cannot require public access over
The coastal area all around Gozo is to be designated to safeguard Public privately owned land. Much of the area
Coastal Access. The public is to have a right to free and unhindered access to designated in the plan is privately owned.
these areas. This right shall not however be interpreted as a right to the Perhaps priority should be given to the
provision of facilities to improve access. upgrading of existing country lanes, rights
of way, etc.
A Coastal Viewshed Protection Zone is also being indicated. Unless otherwise
specified in this policy document, development in these areas shall be restricted
to the maintenance of existing traditional coastal features with no lateral Response: The coastal strip
increase in built footprint or vertical increase in height of the built structures.
which denotes physical access
The relevant coastal areas may also be safeguarded for their ecological, natural
heritage or landscape importance as indicated through policy GZ-RLCN-1. is very limited. Policy is in line
with CZM 3 of the Structure
Plan. The main issue is not to
take land from private
ownership, but to secure
pedestrian access through such
areas. Some of the strips are
inaccessible and can only be
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