85 Rosia Dale,
Gibraltar.
16th November 2005.
By Hand
The Secretary,
Development & Planning Commission,
Suite 631,
Europort,
Gibraltar.
Dear Sir,
RE: PROPOSED DEVELOPMENT AT EXISTING WATER TANKS
SITE ROSIA ROAD
APPLICATION DATED 12TH
OCTOBER 2005
APPLICANT: OEM ROSIA DEVELOPMENTS
LIMITED
We refer to the abovementioned application published in the Gibraltar Chronicle on 18th October 2005 and the Gibraltar Gazette on the 27th October 2005.
Whilst we wholeheartedly support the aims of the Government in providing affordable homes in Gibraltar and recognise the urgent need to solve the housing crisis, we would object to the proposed scheme on behalf of over 2500 persons who have supported our petition against it, for the following reasons: -
1.
Heritage:
On the 200th Anniversary of the Battle of Trafalgar, it is extremely disappointing that perhaps the most significant historical site in Gibraltar with links to the Battle, is to be insensitively developed in a manner which not only defaces Rosia Bay but also significantly impinges on both Parsons Lodge and Victualling Yard, two of the most historical heritage sites in Gibraltar. We attach a number of artist’s impressions commissioned by us which clearly show the impact of this project in the area (attached as Exhibit A). We do not consider that the impressions produced by the Developer adequately reflect the impact to the area.
We would specifically refer you to the following Policy Statements in the current Gibraltar Development Plan and how it has been implemented to date. We consider that this project is in direct contradiction to the following:
POLICY Z13:
THE EXISTING LAND USE PATTERN WITHIN THE SOUTH DISTRICT WILL BE RETAINED. THE ZONE WILL REMAIN PREDOMINANTLY RESIDENTIAL AND IMPORTANT OPEN AREAS WILL BE PRESERVED.
THE
PRINCIPAL LAND USES AT ROSIA BAY/CAMP BAY/LITTLE BAY WILL BE LEISURE, TOURIST
AND RESIDENTIAL ORIENTATED. PROPOSALS
SHOULD TAKE ACCOUNT OF THE POTENTIAL FOR THE FOLLOWING DEVELOPMENTS:-
ROSIA BAY - TOURIST SCHEMES AT PARSON’S LODGE AND THE
VICTUALLING YARD, INCLUDING CAR PARKING
- COMMERCIAL DEVELOPMENT ALONG THE MOLE
- A SMALL BOAT MOORING
More importantly,
it is against the stated views of the Government which has previously described
the area as “of high local historical and heritage value and include (s)
some of the most important constructions … in Gibraltar”.
It is also against previous decisions and statements of the Commission itself which, on 11th July 2003, rejected an application by the owners of Rosia Cottages for the introduction of Dormer windows on the basis of their historical and unique architectural importance and stated that: “The Commission has been actively pursuing policies of conservation and preservation of our historic urban fabric” (this decision is attached as Exhibit B).
Consequently this area has been designated an area in which large scale development should not be allowed and indeed tourism should be encouraged and the Commission has acted accordingly in the past.
THE NEED TO AVOID ANY DETRIMENTAL EFFECTS ON TOURIST ATTRACTIONS WILL BE A MATERIAL CONSIDERATION IN THE DETERMINATION OF ALL PLANNING APPLICATIONS.
2. Over Development:
The Government has previously accepted as recently as 2002 in the tender for the Anchorage (copy attached as Exhibit C) that the area around Rosia Parade “is over developed as a residential area” and made clear that it would not allow development on the Rosia Tanks other than underground parking and an open space at ground level for the benefit of the community. It also indicated that no new buildings in the surrounding area should be more than 4 storeys high. The project at Rosia Tanks is 10 storeys high and does not incorporate any open areas. This is in specific contravention of:
IN
DETERMINING PLANNING APPLICATIONS AND BUILDING PERMITS FOR NEW HOUSING AND
EXTENSIONS THE FOLLOWING CONSIDERATIONS WILL APPLY:
(1) THE DEVELOPMENT
WILL BE EXPECTED TO BE SYMPATHETIC TO THE SCALE AND CHARACTER OF THE
SURROUNDINGS IN ITS DESIGN, SITING, MATERIALS AND LANDSCAPING,
(2) EXTENSIONS
SHOULD NOT DETRIMENTALLY ALTER THE CHARACTER AND SCALE OF A BUILDING,
(3) PROVISION IS MADE
FOR ADEQUATE OPEN SPACE AND ITS FUTURE MAINTENANCE,
(4) THERE IS NO
DETRIMENTAL EFFECT ON THE RESIDENTIAL AMENITIES OF NEIGHBOURING PROPERTIES OR
THE SURROUNDING AREA, AND
(5) CAR PARKING,
HIGHWAY, STREET LIGHTING AND OTHER STANDARDS AS CONTAINED IN THE REGULATIONS
SHOULD BE MET.
THE EXISTING PROVISION OF PARKS, PLAYGROUNDS AND INFORMAL OPEN SPACES WILL BE RETAINED AND ENHANCED FOR PUBLIC USE.
THE CONSIDERATION OF DEVELOPMENT PROJECTS WILL TAKE PARTICULAR ACCOUNT OF THE NEED TO PROTECT THE ENVIRONMENT.
This building will overpower all other buildings in the surrounding area and create excessive overshadowing and overlooking. It is 4 storeys higher than Rosia Plaza, itself a high building for the area. The Commission has previously been guided by and accepted the reasoning in AL WOOD-ROBINSON – v – (1) THE SECRETARY OF STATE FOR THE ENVIROMENT (2) THE COUNCIL OF THE LONDON BOROUGH OF WANDSWORTH (We attach a copy of the same as Exhibit D).
This project we would contend is precisely the type of project, indeed far more excessive, than the one rejected in that case.
The area has suffered from a lack of suitable parking for many years. The need for parking is acute and will be pushed passed saturation point by the construction of 200 apartments at Rosia Tank and the planned 100 apartments at the Anchorage. This presents a major problem for families with young children and the many elderly citizens who live in the South district. We would refer you to the following:
THE PROVISION OF ADDITIONAL OFF-STREET CAR PARKING WITHIN OR ADJACENT TO EXISTING RESIDENTIAL ESTATES WILL BE INVESTIGATED.
4. Congestion:
The flow of traffic from the South District into town is at a standstill at peak times of the day when it can take over half an hour to reach Referendum Gates. The proposed 900 houses in the various affordable housing schemes announced together with the current planned developments at Buena Vista, The Anchorage, The Cliftons and Genista House could potentially increase the number of cars and motorcycles circulating at peak times by 3000 to 4000. How long will it take to get in to town then?
A PROGRAMME
OF TRAFFIC PROPOSALS WILL BE ESTABLISHED BASED ON THE OUTCOME OF A COMPREHENSIVE
TRANSPORT STUDY.
5. Education:
What provision is being made for the massive increase in demand which will be placed on St Joseph’s School and others in the vicinity when all of these extra families are residing in the area? St Josephs already has a shortage of classrooms to meet the current demand. We appreciate this applies to all parts of Gibraltar but it is this one school that is being asked to cope with 900 families.
6. Local
infrastructure:
What plans are being put in place to deal with the additional strain that is to be placed on local water and sewage systems which are already stretched. Will all the roads need to be dug up to incorporate new services with the consequent further delays to traffic and increase in congestion in the area?
In view of the significant public interest issues which are involved in this application we would ask that there be a public hearing of this matter at a meeting convened solely to address this application. We would also request the opportunity to address the Commission in person on our objections. We trust that the Commission will accede to this request.
Finally, the applicant has not stated where we should send their copy of this objection. We would be grateful therefore if you would kindly provide the applicant with a copy of this letter.
Yours faithfully,
N. Banda
For and on behalf The South District Committee