Anyone travelling up Federation Drive recently, halfway between the hospital and St. Aroment, will have noticed a massive concrete structure being erected on a corner lot. One will also have noticed the type of residential housing already existing in this area with lawns, trees, hedges and other green spaces as per Central Housing & Planning Authority (CHPA) standards over 60 years ago. Post the devastation of Hurricane Maria in 2017, it is shocking that an apartment project of that magnitude, has been approved by The Physical Planning Division. The 3 storeys, absorb almost the entire property of 7668sq. ft. This is a low-density area, as assigned by Planning and elevated apartments are not part of the housing amenity.

In the document: Physical Planning and Development Authority - Section 1.3 under Residential Standards, one of the points under the section 1.3.1 RESIDENTIAL DEVELOPMENTS section b, states: "The use of standards governing residential density is to control the amount of residential development so that the resulting level of development can be: Respectful of the rights of residents to enjoy adequate light, ventilation, views, and privacy".

The ambience of peace, quiet and privacy of mostly senior citizens in this low density area, has been shattered. A blind eye appears to have been cast by the Planning Division. This area as per Planning regulations, is mainly for One family homes, NOT multilevel apartments. However, precedents have been set by Planning. To quote a local environmentalist: 'Mature communities have developed characters that Planning must be sensitive to, as their decisions can literally undermine a social fabric that took years to achieve'.

Again we refer to the Planning document statement:" Respectful of the rights of residents." i.e. not only showing regard for new land owners.

It is understood about a month ago, the project was given a 'warning letter' apparently due to construction breaches, yet work continued with Physical Planning Division's knowledge and even increased into the night. Prior to and currently, work has been 7 days a week.

After review by a professional with Planning standards expertise, it is observed that the building:

• Does not meet planning setback requirements for this development on Federation Drive and Windsor Gap.

• The building exceeds the recommended Floor Area Ratio (FAR) for the Pottersville Development Scheme – FAR is directly relevant to density as the more floor space to land you have the denser an area becomes. These properties were bought as One family, homes and have been so for the last 60-plus years from the 1950's.

• The building exceeds the lot occupancy for this Development Scheme

• The proposed allowance for parking is impractical and does not meet Planning's standards. It will not accommodate the plans' approved number of vehicles.

• The building ridgeline exceeds the area standard and is too close to the road. As a result, it also blocks the view of the neighbours.

Questions: Was Planning inspecting the project? Why were those breaches allowed to occur? Why did work continue – into the night when it was allegedly stopped by the relevant authority? This is not just about a community of senior citizens, who have been restrained through this ordeal. Planning's credibility has been eroded over the years and Dominica needs to have faith in this entity. As a developing country prone to severe weather events, proper urban planning, green space laws and policy are key to weather mitigation and to the genuine development of the country's Nature Island concept. There appears to be no effective attempt at zoning in Dominica. We must practice good building standards, not just talk about it. This concrete anomaly in the wrong zone and is not the standard we aspire to.

A home is normally the largest investment made by citizens globally and especially during this Covid-19 pandemic, ordinary people have the right, the expectation, to enjoy and to even rediscover, the comfort of their homes and outdoor spaces without intrusion.

Some background: Over a year ago, the residents wrote to the Physical Planning Division (PPD)with concerns when they became aware that there was a plan for a residential apartment building for that location. It should be noted that the plans had been drawn and designed not by an architect, but by an employee of said PPD. Never mind the obvious conflict of interest of the Division vetting plans drawn by an employee, a culture that is endemic in the PPD.

Fast forward: the plans were approved in early 2019 and the residents' concerns were ignored. The residents continued to request a copy of the plans with continued refusals by Planning Division. Legal assistance was sought and a copy of the plans was provided for a fee.

Earlier on, Planning personnel had surveyed home owners in the area, on the possibility of agreeing to an office on the same location, for the Dominica Olympic Committee (DOC). Neither institution provided a proposed structural design to allow residents to make an informed decision. As this is not a commercial area, the community consensus had to be no. Recent information indicated that despite the community consensus, Planning had decided to give DOC permission to build an office without advising residents. Again, Planning had ignored and disrespected the rights of the residents, despite the feedback. At the time the parties were unaware that the land had been sold to 2 Chinese nationals.

A FOR SALE sign was then placed on the land. The residents who were in the process of repairing severely hurricane damaged homes, were relieved and thought that the potential concrete intrusion was over.

A source indicated that the lot was put back on the market because, the owners realized that due to the scale of the building, it would not fit well on the land. The land is wider to the east and narrows to the west i.e. the Gap below. Apparently, this issue was not considered by the Planning draftsman or the technical committee. Due to the inflated price, the owners were unable to sell.

Present day: Work on the apartment project commenced in July 2020. Due to its size, the building had to be angled to fit the lot. Construction continues 7 days a week from 6:30 a.m. and it is clear that the community's residential amenity standards are being severely violated by this invasive structure. Nevertheless, work has continued unabated with Planning's blessings. The residents have again written to Planning outlining the breaches, requesting consultation, and that the building does not continue to the third storey. The land itself sits high, approximately 8-10 ft above the road. Even with excavation, add three stories to this and the height increases significantly, bringing the building above the properties in a higher elevation, and not within the usual building standards for this area. The 2 upper floors, with a capacity for multiple families, is a clear deviation from the intended single family homes in this low-density area. Reliable information indicates that a 5-vehicle parking space is now inaccessible, due to construction breaches.

Some of the damage is already done. The landscape is now marred by this massive concrete structure. Should this apartment building project continue to another storey, the residential community landscape will be completely, negatively changed forever. If it does, to paraphrase the Dominican Prime Minister after Hurricane Maria, "Their Eden will indeed be broken." Planning is under the PM's portfolio and he appears to be a keen supporter of green space integrated with residential living. This project does not reflect that aspect. We all know our home is our oasis, our 'Eden.' For too long, planning anomalies have been allowed to appear as the norm in residential areas across Dominica. This building project will affect light for residents. Privacy has already been invaded; workers at a height which would be a roof in this area, peer into residents' bedrooms daily and air flow is already being impacted. Land values may also be affected negatively, as the building will appear off putting to someone wanting to purchase a home in an area with a certain residential ambience.

The residents feel they have been restrained and silent for too long feeling betrayed by the 'system'. A legal battle, which could set a Planning precedent, might be very extended and local pockets are not as well lined as the owners who also own and renovated a house into several apartments, a few minutes away. There is a marked increase of labour on the project, indicating that the owners want to add the final storey urgently. It is imperative that the top storey is not allowed to be constructed.

Goodwill, while one of the oldest, is one of the better planned Dominican residential developments, designed to help provide housing mainly for a previous generation of civil servants. It still remains one of the sought after residential locations. The pioneer Planners of the Pottersville Housing Scheme many hard working and visionary Dominicans no longer with us, planned Goodwill carefully and with thought for the environment. Every detail was planned: areas for playing fields, churches, shops, schools, down to a house number metal plate for each residence, many of which exist today on house fronts, despite the ravages of hurricanes over the decades. It was not meant for this type of 'housing', as the average lots are not as large as e.g. Morne Daniel, where this building would have been more appropriate.

Certainly, there are silent victims today, resigned to living in the shadows of the lofty elevations that the Planning hierarchy has decreed Goodwill and other urban areas should be forced to accept. Goodwill is the largest residential development on the island, yet a senior Planning official once questioned: "Who buys property in Goodwill, to build a family home?" With a new, highly qualified leader, the public was hoping for a fresh approach to applying Planning standards. Alas!

The community's senior residents just want to live in their homes peacefully and enjoy their gardens, yards and retirement with family in quiet comfort and tranquility. "We are just ordinary citizens who worked hard for decades to build our homes, and some of us are still repairing after Hurricane Maria. It does not matter who owns the land." A resident said to me. "Whether it was Joe Bleau, Mother Teresa, or Barack Obama, Planning rules and standards should still apply." Another resident lamented. "This is not change for the better. Planning thinks this is Roseau and has no regard for senior citizens. I am no longer getting privacy in my bedroom. I have to keep my curtains closed all day. No breeze." A pensive resident added. "While we have lost quite a bit of faith in the system, we believe and are optimistic that reason and law will prevail and the Planning Division will do the right thing and not allow that top floor to proceed." The clock is ticking.

John & Jane Planner – Concerned Citizens