The Gozo Regional Council, comprised of 14 mayors from Gozo and representing all the localities, has sent a letter to the Superintendence of Cultural Heritage to object to the proposed development at Ggantija Heights, Triq il-Parsott, Xaghra.

The Planning Authority last November approved an application that will see 22 apartments and 20 garages built on the edge of the Xagħra Development Zone, ignoring a request by UNESCO.

The Gozo Regional Council, in a letter sent in December but made public on Friday, said the development “threatens this extremely important world heritage site, as well as the status of the other sites. Given the importance of the site, this application should have been carefully considered with a heritage impact assessment as recommended by UNESCO and any other checks that are there to help us give a learned response and safeguard our heritage and culture.”

The council also noted that there are six other applications or new developments within the same buffer zone. UNESCO had also called for a cumulative impact assessment of the area, an assessment that has not occurred. Cumulative impact is defined by something that “results from the environmental impacts of a project [development] combining with the same environmental impacts of other past, existing and reasonably foreseeable future projects or activities, including those that may be enabled by the project.” On a one-by-one basis these stand-alone projects would not have impacted or affected its surrounding but their collective development are a different story.

To this end, the council called for a cumulative impact assessment.

The council said that the development is planned to take place less than 200 meters from the site itself are the Ġgantija Temples, one of the oldest free-standing buildings in the world and a UNESCO World Heritage Site, which are situated within an area of significant archaeological significance. Government Notice 853/10, which was released on August 17, 2010, includes this buffer zone (please refer to the document attached).

“A buffer zone, or at least the area that the proposed development is within, which can clearly be seen and has been declared null by the Planning Authority. Any application for development should have been considered with the understanding that it will unavoidably negatively affect one of our most treasured archaeological treasures and its UNESCO site designation,” the council observed.

It said that the 22-apartment block will negatively affect the view from and towards Ġgantija and subsequently could permanently impact the context and experience of this historic landmark. As these temples are listed together on the UNESCO World Heritage List, the risk is that any delisting could result in delisting all the other temples found in Malta, the council added.

The council pointed out that as per the Cultural Heritage Act, the Superintendence of Cultural Heritage is bound;

·        to exercise surveillance over the protection, excavation, monitoring, exploration, conservation, restoration, maintenance, exhibition and accessibility, import, export and movement of cultural property;

·        to promote and conduct research in the field of cultural heritage and to conduct excavations and other investigations which may be required so that objects or aspects of cultural heritage be discovered, cared for and appreciated;

·        to ensure that adequate documentation is kept and archived in relation to excavation, exploration and search for antiquities, the conservation of cultural property and discoveries resulting from environment impact assessments;

·        to promote and ensure the best policies, standards and practices in the conservation and presentation of artefacts, collections, museums, buildings, monuments and sites and to maintain all necessary databases and information derived from or required to organise, plan, co-ordinate, and monitor restoration and conservation projects;

·        to advise and coordinate with the Planning Authority action in safeguarding cultural heritage when considering applications for planning permission relating to development affecting objects, sites, buildings or landscapes which form part of the cultural heritage as well as to advise other pertinent bodies on all matters of cultural heritage;

The council said that geophysical surveys carried out revealed “a large number of anomalies”, which may also include other megaliths in the olive grove to the north of the temple, in the vicinity of the development plot, where an exploratory trench had also been opened. This means that the proposed development works may bury and cause damage to undiscovered archaeological remains and obstruct future archaeological research.

UNESCO’s rules and governing principles that are designed to protect World Heritage Sites are being ignored, the council added.

Two letters were sent by the Director of UNESCO’s World Heritage Centre Lazare Eloundou.  In both letters he had expressed the guiding principles that these impact assessments should be conducted, in his first “for potential impact” referring to the block in question and later that a heritage impact assessment is a “pre-requisite for development projects and activities that are planned for implementation within or around a World Heritage property” and “that such assessments should serve to identify potential negative impacts on the Outstanding Universal Value of the property and to recommend mitigation measures against degradation or other negative impacts on the cultural heritage within the property or its wider setting.”

This means that both a cumulative assessment and a heritage impact assessment for one particular application (PA/00570/21) has been called for and ignored. If we continue to ignore these calls and its regulations UNESCO is well within their rights to revoke our title and status on these sites, the council said.

From what can be noted through reports, the council said the Superintendence of Cultural Heritage has green lighted this without an assessment report being conducted on what damage this building may have on Ġgantija, a Grade 1 Monument and UNESCO site. Not only are we endangering the site itself, but also its status as protocol and Malta’s responsibilities under the World Heritage Convention are not being followed in this regard. 

 

"To this end we are calling for a re-assessment of this approved application and for all required studies in and of the area including the stand-alone heritage assessment and the cumulative impact assessment to be conducted and vetted accordingly. Once the results are in hand, and only then next steps should be taken accordingly, ensuring the protection of our heritage and history," the council said.

Full letter may be found here