Mepa is winding down its public consultation on the Townsquare project to be built in the heart of Sliema. However, many may have missed the report, buried within the labyrinthine Mepa website at http://www.mepa.org.mt/environment/index.htm?SEA/mainpage.htm&1.

Being drawn up by the developers, this project description statement is rather one-sided and, therefore, merits comment.

The Townsquare project is an interesting complex that begins at a low level with the stately old Villa Drago, just off Tower Road (facing Norman's Pharmacy). Three two-storey buildings will be built close to Villa Drago and an avenue, flanked by large four-storey blocks, runs from the back of the villa to the blocks at the back, which step from eight to 12 storeys. The 32-storey tower dominates the whole project from the centre of this row. The project accommodates 242 apartments and acres of office and shop space.

Townsquare follows a formula to accommodate as many units as possible in an attractive way, a formula originally conceived for areas with a shortage of vacant housing, certainly not the case in Sliema. The developers did leave more open area than strictly necessary and, while this is laudable, one has to ask whether the whole project is justified and sustainable.

The development is packaged almost as a social work project to create a piazza where people can relax in Sliema, claiming that: "Pedestrians are presently limited to narrow, crowded pavements with the occasional quick dash through moving traffic to cross the road. This return to a 'human' lifestyle and relaxed use of open spaces will be an enormous relief".

They fail to mention that Sliema's lack of a village square is more than compensated for by the Ferries, Qui-Si-Sana and Tower Road seafronts, which provide plenty of space for relaxation. It is to be noted that these are the same developers who demolished the old Union Club, a building of architectural significance and a real community focal point, which was effectively destroyed when its clubhouse was demolished.

A "return to a human lifestyle" is hardly an apt description of a project dominated by a 32-floor skyscraper, just as the increased traffic and diminished light and sun created by the project is far from an enormous relief to neighbouring residents.

The overshadowing of buildings is becoming a major issue in Malta. In this case the developers say that most of the shadow will lie within the project site. This might be correct if the sun were to stop in its tracks at the sight of the Townsquare tower, but I think not. When the sun is overhead, shading will not be a problem, but in the morning and late afternoon, the long shadow of the 32-floor tower and its 12-storey flanks is going to fall far beyond the project's precincts, throwing neighbours in Hughes Hallet and Tignè streets into deep shade.

Much is made of the integration of scheduled Villa Drago into the project, however only the front garden is being retained, while the remains of its back garden will be built over. This would allow the old villa some "breathing space" for much of its value is being dwarfed to insignificance in between higher blocks. Wherever possible, buffer zones are left around protected monuments and the trees of Villa Drago's back garden are essential to prevent it being swallowed up by the surrounding mass of buildings.

The developers report a positive response from estate agents but none of them mention that the Tignè peninsula is already heavily over-developed. Recent projects will create over 1,300 new apartments in the 500-metre stretch from Townsquare to the MidG project.

Now to the construction details. The excavation phase will take a full year, with 110,000 m3 of rock, the equivalent of a small quarry, being cut and almost 12,000 trips required to cart it away. The work will run from 7 a.m. until 5 p.m. (4-7 p.m. in summer); 10 hours of drilling vibrations, noise and dusty trucks rumbling past every day. No mention is made of the route to be taken through the residential area or the price to be paid by residents in terms of toxic fume emissions. Neither is the eventual destination of the rubble specified. Or is it to be dumped at sea? Surely such a valuable resource should be recycled!

The fact that no indication of the completion date of the project is given is also worrying. Although the developers must be praised for pledging to introduce dust, noise and vibration damping measures, in practice builders often ignore such guidelines and no mention is made of redress or systems of monitors and checks. At best neighbours are looking at half a decade of noise, dust and fumes.

The developers themselves say that the 1999 traffic impact statement is outdated and needs to be revised as traffic impact will be substantial, both during construction and once the project is operational. Yet, the developers state that the existing roads are adequate for the anticipated traffic flows. Mepa's latest air testing results indicate that, while air quality has improved over most of Malta, the quality of the air in Sliema has deteriorated since November 2005 due to intense traffic and unceasing building activity.

Hughes Hallet Street, presently a quiet residential street, will become a busy access road for at least 424 extra cars. The provision of 424 residential parking spaces is about 60 fewer than what is required by Mepa circular 3/93, which requires a minimum of two car spaces per apartment in congested locations. The shortfall on offices and retail space is also significant.

The report claims that the supply of essential services such as water and drains will not be a problem as the Townsquare project will benefit from the upgrading of services undertaken for the MidG project. However, the fact is that residents in adjacent Tignè Street have been experiencing consistent water supply problems since the late 1990s.

Other serious issues include safety and maintenance. While the Civil Protection Department has assured the press that its inability to cope with emergencies in skyscrapers is made up for by the safety measures required for such buildings, the reassurance rings hollow. Elevator technology is not new to Malta and, yet, experts in the industry report that standards fall far short of EU regulations. So how much faith can one have in the monitoring of new high-rise technology?

Wind studies are also significantly lacking from this report.

Whatever the technological innovations claimed by architects, repairing existing tower blocks can be exorbitantly expensive; replacement of high-storey windows, for example, becomes a major undertaking. It costs at least 10 times more to refurbish a block than demolish it, so, if anything serious goes wrong, the cheapest option is often to knock them down. Demolition of any structure is eventually inevitable but can we seriously envisage demolishing a 32-floor structure over Hughes Hallet Street?

The project's impact on to the environment of the area will not be negligible. Although the garden areas will look very pretty if well maintained, it is now known that tall building projects cause surrounding temperatures to rise. This is partly due to the massive amounts of heat-retaining concrete and asphalt used in the buildings and roads, while glass, widely used on tall building façades, tends to allow solar energy inside to enter and remain trapped, leading to increased temperatures.

This is aggravated not only by the increased traffic generated by tall buildings but also by electric power consumed for lighting and household appliances, which greatly contribute to urban heat accumulation. Cooling systems are of particular concern as more use of air conditioning during a heat wave throws more hot air into the surrounding atmosphere, which, in turn, leads to more air conditioning use. The buildings' very topography causes the sun's rays to be bounced off each other instead of being reflected back up, creating what is known as urban heat canyons. In this year, when the government has finally woken up to the reality of climate change, can we seriously be encouraging the very scenario that creates this global warming?

A final point is the project's impact on the landscape.

Landscape values are enshrined not only by Mepa but in our Constitution, and one could say that our most precious landscapes are our unique historic ones. Mepa regulation UCO 10 stipulates that developments will not be permitted which adversely affect views of or from urban conservation areas - in this case it is not just an urban conservation area that is being affected but a World Heritage Site. Already views of Valletta's bastions have been affected by a lower tower; a 32-storey tower on higher ground will spell the end of Malta's unique historic harbour vistas.

In conclusion, in the context of a glut of 1,300 new apartments on the Tignè peninsula and a further 1,000 within a kilometre, do the disadvantages outweigh the benefits of yet another commercial centre? Do we need more shops when many shut after a short while? Is such an intense exploitation of the site justified or sustainable? Would the quality of life of residents be better served by a mitigation of the project, reducing it to a more reasonable scale? Will Sliema be well served by what is essentially a speculative project putting more traffic on its streets and more pressure on its creaking infrastructure?

Interested parties are invited to submit their comments to Mepa's environment impact assessment unit by mail or e-mail (eiamalta@mepa.org.mt) without delay as the consultation period is about to close.

Ms Vella is coordinator of Flimkien ghal Ambjent Ahjar.

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