This Thursday, the Planning Board will decide on an application put forward by Infrastructure Malta for works on the road overlooking the Għeriexem valley to the North of Rabat.
The works being requested include: the widening of the existing road onto the valley in order to upgrade the existing carriageways, the construction of a new promenade and the reconfiguration of on-street parking.
The existing road is certainly in need of improvements, most especially due to its reported structural instability. The upgrading of the road’s carriageways and inclusion of a promenade would also improve accessibility. So why the opposition?
A major concern is the fact that the road lies within an extremely sensitive area of high archaeological value. It is not only within the Rabat and Mdina Area of Archaeological Importance but specifically falls within the Buffer Zone surrounding both the Roman Domus and the Saracenic Cemetery and is in fact only 3 meters away from these Class A archaeological sites. A number of other archaeological structures, as well as ceramic remains, have also been identified within the site’s boundary.
The intensive works proposed would of course necessitate ‘extensive clearing and ground disturbance’ in this area of the highest archaeological sensitivity.
In its consultation on the proposal, the Superintendence of Cultural Heritage [SCH] requested further information which included a Ground Penetrating Radar [GPR] survey of the area in order to locate any possible underground structures, as well as a full investigation of the area, noting that ‘the likelihood of discoveries is extremely high’.
A GPR survey was carried out and some underground structures were in fact noted, however as of March 2020, the applicant still failed to provide a full archaeological investigation. In its correspondence dated 23rd March 2020, the SCH stated that although it did ‘not object to the proposal in principle’, the applicant still had to provide an archaeological evaluation of the area ‘before the approval of any development permit’.
A few days later, the project architect responded by stating that Infrastructure Malta had already issued a tender for all works related to the project, which included the archaeological evaluation. The tender was subject to the permit being issued. The architect declared that the archaeological evaluation would commence once the tender was issued.
This essentially means that since the project tender is tied to the approval of the permit, the archaeological evaluation will be carried out only after the permit has been approved. This is precisely what the SCH had specified should not happen, yet only a month after having set this condition the SCH seemed to accept Infrastructure Malta’s position without batting an eyelid.
Another concern, shared by the Agricultural Advisory Committee and the ERA, is the loss of over 1,900 square meters of agricultural land within the Għeriexem valley. The AAC did not pursue this issue any further, and instead noted that it was not objecting to the project since it is one of national interest. The AAC’s only condition was that the loss of agricultural land would be kept to a minimum and that proportionate compensatory measures ‘which may include restoration of derelict public land or planting of trees’, would be carried out.
Under the Rural Policy and Design Guidance (2014), a project of national interest is not subject to a specific policy but is expected to be ‘assessed on its own merits’, subject to consultation with experts concerned. Therefore, the AAC was not obliged to accept the proposal simply because it is considered to be of national interest. The AAC could have also imposed more specific conditions, instead of allowing Infrastructure Malta to essentially decide for itself which compensatory measure it would implement.
In February 2020, Infrastructure Malta proposed that the upgrading of the extension to the Ta’ Qali National Park be considered the compensatory measure being implemented to make up for the loss of agricultural land.
The inclusion of this land as part of the Ta’ Qali National Park had already been announced in May 2019, and re-announced by Infrastructure Malta Minister Ian Borg, in September of the same year. It should also be noted that this land, repeatedly marketed as a new extension to the Ta’ Qali National Park, was always designated for such a use in the Local Plans. Either way, such a completely unrelated project that had long been in the pipeline should not be considered a ‘compensatory measure’ that can make up for the loss of agricultural land in the Għeriexem Valley.
Another major concern is the impact of the road-widening on a number of rare and important species found in the valley, as well as the loss of what ERA described as the ‘largest fig tree’ in Malta. ERA had requested that these issues be addressed. The proposal was amended slightly to ‘mitigate’ the impact, however, from the information available it seems that the fig tree would still be removed. Compensatory tree planting was proposed to address this impact, but how could a couple of saplings possibly make up for the loss of this exceptional fig tree?
The real issue with this proposal is not the upgrading of the road itself but the inadequacy of the mitigation measures and the consulting agencies’ willingness to seemingly cave in to Infrastructure Malta’s demands, despite their conditions not having been met. It is worrying that such projects of ‘national interest’ are allowed to bulldoze through the planning process with any checks along the way serving as nothing more than a box-ticking exercise. In effect, it simply illustrates the frailty of our planning system and the absurdity of how it functions.
Tara Cassar is an architect focusing on planning policies and environmental issues related to land-use, active with a number of local eNGOs.
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