The Superintendence of Cultural Heritage has taken exception to the suggestion that it is abdicating its duty to safeguard Malta's national heritage.

The entity was replying to a press statement issued by the NGO Flimkien Ghal Ambjent Ahjar, which quoted its coordinator Astrid Vella Vella saying that a "total lack of transparency or adherence to accepted norms point to the SCH's abdication of its responsibility to protect Malta's precious heritage."

In its reply, the Superintendence of Cultural Heritage said it wanted to clarify "recent commentary regarding its work in the Ta' Lablab, Xagħra, Gozo, Tal-Virtu, limits of Rabat, Malta and other areas, as well as concerns raised about its regulatory role.

The Superintendence takes exception to the suggestion that it is abdicating its duty to safeguard Malta's national heritage. Such an assertion is contradicted by the extensive work carried out by the Superintendence, as documented in its publicly available annual reports. Moreover, these comments are an unwarranted affront to the dedicated staff of the entity, who work tirelessly to preserve the nation's cultural heritage, it said.

The Superintendence has always valued and supported voluntary organisations working in the heritage sector, whose input is invaluable. At the same time, it cannot remain silent in the face of what appears to be a campaign of misinformation, which misrepresents the facts and misleads the public. Over the past years, the Superintendence has provided public information on processes at Ta' Lablab in Xagħra, Gozo; however, recent protests have continued to misrepresent the situation. The Ta' Lablab area was included in the 2006 rationalization exercise, and in 2012, the Superintendence submitted a report confirming that the site had been extensively investigated and could be incorporated within the approved development zone.

Consequently, the Planning Control permit was issued. Today, development in the area is proceeding in line with the approved permits and under archaeological monitoring conditions. To date, only a single small burial pit has been identified, which was investigated by professionals and specialists working with the Superintendence. The cultural material associated with this burial is clearly datable to the Ġgantija phase, and any claims suggesting that the remains are 1,000 years older are factually incorrect.

Similarly, the site at tal-Virtu in the limits of Rabat, Malta is undergoing an archaeological evaluation, directed by the Superintendence in line with issued Terms of Reference. This evaluation necessitates the use of mechanical equipment; a medium-sized and a small-sized excavator running on rubber crawlers with toothless buckets to ensure that archaeological features are properly safeguarded.

While some have questioned the use of such machinery, it is standard practice in development-led archaeology, as documented in authoritative sources such as the European Archaeology Council's EAC Guidance 5 - The Benefits of Development-led Archaeology in Europe and Beyond (2024) and the proceedings of the 19th Heritage Symposium, Development-Led Archaeology in Europe: Meeting the Needs of Archaeologists, Developers and the Public (2019), both publicly available online. The evaluation at Tal-Virtu is still at an early stage and the public will be informed of the outcome in due course. The Superintendence can confirm that a tomb found on site had been rifled in the past and found to be devoid of any significant cultural material.

It is important to clarify that the controlled use of heavy machinery in archaeological investigations is legitimate and internationally accepted where development-led, preventive, or rescue archaeology is required. Test trenches are first dug to assess stratigraphy, and sterile layers may then be removed efficiently. Qualified archaeologists monitor all work and may pause excavation immediately upon the identification of cultural heritage, the superintendence said. Research-led and development-led archaeology serve different purposes and the respective methodologies (which in both cases ensures the identification and study of archaeological remains) should not be confused; the Superintendence always prioritises preservation in situ while balancing the practical realities of responsible development within approved zones.

Regarding broader heritage impact assessments (HIAs), the objectors' statement that an HIA is required for every development within World Heritage Site boundaries is inaccurate. The UNESCO/ICOMOS Guidance and Toolkit for Impact Assessments in a World Heritage Context (2022: 8, 18, 25, 32-34) directs that screening must first take place to determine whether an HIA is required. The Superintendence said it undertakes such screening in all cases, and a written recommendation is published for every application on EApps. HIAs are requested only where the potential impact on the Outstanding Universal Value of a World Heritage Site cannot be determined from the information available. It must be also noted that when necessary, the Superintendence consults the National World Heritage Technical Committee on issues related to world heritage. The committee is established under the CAP 445.

A claim has also been made that the Superintendence is indifferent to the situation in Valletta, another UNESCO World Heritage Site. The NGO has not provided any evidence or explanation to support this claim. The Superintendence invites the NGO to engage directly to discuss its concerns and provide specific examples so that they may be addressed constructively.

The issue raised on the disagreement by the Cultural Heritage Advisory Committee for the dismantling of the British barracks at Fort Chambray, it must be pertinent to note that this was during the assessment of the 2012 outline application, which was eventually approved, hence such a comment at this stage is superfluous.

In all its actions, the Superintendence said it remains committed to fulfilling the State's duty to protect and make accessible Malta's cultural heritage, welcoming objective criticism but not wilful misrepresentation.