Issue link: https://maltatoday.uberflip.com/i/1511791
10 NEWS maltatoday | SUNDAY • 19 NOVEMBER 2023 JAMES DEBONO A number of photomontages depicting the impact of new de- velopments on existing views are falling short of the stringent and detailed guidelines issued by the Planning Authority in 2015, a probe conducted by MaltaToday reveals. While the rules are largely being adhered to in the case of large- scale projects requiring the pres- entation of an Environmental Impact Assessment, for which ad- herence to the 2015 guidelines is mandatory, this is not always the case for smaller or medium-sized projects, which can still have a significant visual impact and may require a visual assessment. The probe reveals deficiencies in several visual assessments pre- sented in the past five years, in- cluding cases where cut-and-paste images were simply superimposed on Google Earth photos. In other instances, artistic imag- es or computer-generated 3D im- ages and even drawings were used instead of photomontages. The probe also found a widespread use of a wide-angle lens, which lessens the visual impact of the develop- ment since most of the photo is taken by the foreground and mid- dle-ground. The practice of using a wide-an- gle lens has been denounced by environmentalists for the past decade, particularly in the case of the Mrieħel high rise devel- opment, in which a first batch of photomontages taken with a wide-angle were later replaced by a more accurate batch conform- ing to official guidelines. And the Planning Authority does not have any official body entrusted with the verification of the photomontages, which means it remains unclear which projects necessitate a visual assessment and which do not, even if various entities are increasingly relying on photomontages in their as- sessment of both large scale and smaller projects, particularly those impacting on strategic viewpoints. Additionally, since photomon- tages are not included among the list of approved documents like plans and drawings, the PA can- not take remedial action in cases where these visuals fail to accu- rately represent the real impact. The purpose of photomontages, unlike that of artistic impressions, computer-generated images or 3D renders, is to illustrate what a development will look like to a person standing at the same point as the image was taken. Therefore, proper photomontages require a clear and exact baseline showing the existing view and the correct use of the camera, especially the angle. Proper photomontages are also presented in a way which enables the verification of their correctness and compliance with guidelines, by providing full infor- mation on both the viewpoint and angle used. Planning Authority's reaction When asked whether there is an established process to determine which projects require a visual assessment, a PA spokesperson replied that the Development Management Directorate or any deciding body, such as Planning Commissions and the Planning Board, can request photomontag- es to better assess the impacts of a proposed development. But the guidelines are not appli- cable exclusively for applications which request an EIA "but for when and wherever a visualisation study is requested". In fact photomontages are also regularly requested by the Super- intendence for Cultural Heritage and the Design Advisory Com- mittee. A circular issued by the PA in 2020 had itself recommended photomontages of developments proposed next to scheduled build- ings taken from strategic view- points. Asked whether any entity with- in the Planning Authority is re- sponsible for following up on projects after construction, to verify whether the photomon- tages presented during the pro- cess correspond with reality, the spokesperson replied that it is the responsibility of the person or en- tity requesting the photomontage to ensure that the photomontage submitted is a correct interpre- tation of the approved drawings submitted and approved. From a compliance and enforce- ment standpoint, the PA can only ensure that the development fol- lows the approved drawings and documents listed in the develop- ment permission, while noting that photomontages are not typically included as approved documents. What the guidelines state: The PA's guidelines, approved in 2015, have established stand- ards for visualizations of proposed buildings and other structures, which are requested during the assessment of planning applica- tions. While all planning applications requiring an Environmental Plan- ning Statement (EPS) and an En- vironmental Impact Statement (EIS) must adhere to the require- ments outlined in these guide- lines, a "proportional approach", depending on the size and con- text, is recommended for other applications. For projects requiring an Envi- ronment Impact Statement, a set of photographs of the complet- ed project, taken from the same viewpoint locations and under the same photographic condi- tions, must be submitted. These guidelines advocate the use of a high-quality digital SLR camera with a full-frame sensor and a 50mm fixed focal length camera lens. The use of a 28mm fixed focal length camera lens is only per- mitted in specific circumstances. Visual impact assessments neces- sitate 75mm single-frame images recalibrated from the 50mm im- ages to ensure proper assessment by a broader audience. Visualizations should include all relevant viewpoint information, camera and photographic data, reading distance, and all other in- formation used in the preparation of the visualizations." Examples of good practice The guidelines have clearly 'Eye-candy' photomontages Photomontages showing how a development will look like to any person standing at the same point as the image is taken can be useful for planners and decision-making boards. But are guidelines for visual assessments approved by the Planning Authority in 2015 being followed? A MaltaToday probe reveals this is not always the case and that no one is responsible for vetting the quality of these images Use of Google Earth image: Old people's home in Swieqi High-rise Villa Rosa development