Objection 101/15
Possible lack of an Economic Sustainability Report
The association questions whether the procedure sufficiently includes the economic justification for the long-term maintenance of the proposed new public space.
Read full analysis →Objection 202/15
Questioning of the legal basis cited
The association argues that some legal references invoked in the procedure may not apply to the Valencian territory and requests that the legal basis be clarified.
Read full analysis →Objection 303/15
Request for the Heritage department's report
Given the area's relationship with the historic centre, the association asks that the report of the regional Heritage department be expressly incorporated into the file.
Read full analysis →Objection 404/15
Procedure proportionate to the scope of the change
The association questions whether the chosen procedural channel matches the actual scope of the proposed modification, and asks that a procedure with stronger guarantees be considered.
Read full analysis →Objection 505/15
Coherence of the protected-area boundary
The association questions the coherence between the new graphic boundary and the historic urban fabric, and asks that the protected-area line be justified using objective technical and heritage criteria.
Read full analysis →Objection 606/15
Proportionality between environmental justification and added volume
The association considers that the environmental justification based on preserving existing trees is not proportionate to the increase in buildable volume that the modification would allow.
Read full analysis →Objection 707/15
Safeguards for hydraulic heritage (historic irrigation channel)
The association warns of the possible presence, in the underground of the area, of elements of the historic irrigation system, and asks the file to provide for studies and archaeological supervision.
Read full analysis →Objection 808/15
Possible impact on sunlight and ventilation
The association expresses concern about the effect the new volume could have on sunlight, ventilation and habitability conditions of the consolidated neighbouring dwellings.
Read full analysis →Objection 909/15
Coherence with prior technical criteria
The association notes that recent reports and administrative acts maintained certain height parameters for the area, and asks for reinforced technical reasoning for any substantive change of criterion.
Read full analysis →Objection 1010/15
Full access to the file
The association, as an interested party, has requested full access to the maps, plans and versions of the file, and considers that this access must be guaranteed in full to enable an effective technical defence.
Read full analysis →Objection 1111/15
Comptroller's report on future burdens
The association requests that the municipal Comptroller's report on the economic burdens arising from the proposed new public facility be expressly included.
Read full analysis →Objection 1212/15
Scope of the environmental assessment
Given the heritage and urban impact of the area, the association considers that it should be assessed whether the chosen environmental procedure is the appropriate one, or whether a broader procedure is warranted.
Read full analysis →Objection 1313/15
Compliance of penthouses with the ACA ordinance
The association argues that the current ordinance for the ACA zone makes the inclusion of penthouses conditional on a specific volumetric instrument, and requests that compliance be evidenced.
Read full analysis →Objection 1414/15
Equal treatment in urban-planning burdens
The association asks that urban-planning and heritage burdens be applied under homogeneous criteria to all owners in the area, without unjustified singularities.
Read full analysis →Objection 1515/15
Compliance with the old-town regeneration mandate
The association recalls that current planning foresees the regeneration and pedestrianisation of the historic centre, and asks that any specific modifications be coherent with that mandate.
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