The Planning Board deferred its decision last Thursday on whether to grant permission for a large apartment complex less than 100 metres from the Ggantija Temples Hypogeum, the site known as the Xaghra or Brockdorff Stone Circle – PA/07453/24 in Triq Tal-Qacca.

During the meeting, a representative of the Coalition for Gozo called on the Planning Authority (PA) to halt all proceedings, given that the proposed development is of considerable scale and lies within the UNESCO Ggantija Buffer Zone, with roughly half of it falling inside the approved buffer zone of the Xaghra Stone Circle. The plans include basement garages which, according to the cross-section drawings, would necessitate substantial rock excavation.

The Coalition for Gozo said that the proposal also entails the destruction of what appears to be a cluster of “architecturally significant vernacular farmhouse rooms.” Furthermore, the rear elevation of the proposed development would constitute a visual blight, particularly for those approaching Xaghra from Xewkija.

The Coalition pointed out that in its correspondence to the Planning Authority, the Superintendence of Cultural Heritage (SCH) stated that it “finds the proposal objectionable in principle,” further adding:

“Should the Planning Authority further consider this application, the Superintendence is to be consulted again to screen the proposal, since the site, being located within the protected buffer of the UNESCO World Heritage Site of Ggantija, may require further studies, including an impact assessment.”

The Coalition said that the SCH is “well aware that a Heritage Impact Assessment (HIA) is in fact required, and the use of the word may in its communication to the PA is misleading.”

If the Superintendence truly found the proposal “objectionable in principle,” the Coalition insisted that it should have “immediately requested an HIA and suspended the application until the impact of the development on this highly sensitive archaeological area had been properly assessed, in full accordance with UNESCO’s Operational Guidelines for Heritage Impact Assessments.”

It is also abundantly clear that the Kamra tal-Periti Directive 01/23, entitled “The Development within UNESCO Buffer Zones of the Megalithic Temples in Malta,” was “entirely disregarded by the architects concerned.,” the Coalition for Gozo said.Among other points, the Kamra was unequivocal in the directive when it stated:

c) Archaeological Impact Assessment:

Members must carry out an archaeological impact assessment prior to submitting a planning application, to assess the potential impact of the development on the cultural heritage value of the megalithic temples and the buffer zones. The assessment should be included with the planning application.

In the case of the building at Tal-Qacca, the assessment was not undertaken, the Coalition said.

Din l-Art Helwa Ghawdex, Ghawdix and Wirt Ghawdex – the Coalition for Gozo – said that they have been, and will continue to be, “strongly opposed to this development.”

In addition to insisting on an HIA, the Coalition said it objects to the total demolition of what appears to be a fine vernacular cluster of Gozitan rural buildings forming an historically valuable farmhouse complex.

The Coalition also questions why neither the PA Board nor the general public have been provided with a photographic survey of the interior of the vernacular rooms.

The Coalition for Gozo said it has already succeeded in halting another large-scale project, the Gigantija Heights, which had been approved by the PA in November 2023. This was achieved through the invocation of Article 80 of the Development Planning Act, which empowers the PA Board to revoke or amend a permit in cases of fraud, misrepresentation, error, or issues relating to public safety.

“The PA and SCH know that UNESCO safeguards World Heritage Sites by establishing buffer zones around them, within which development is restricted,” stated the Coalition. “In practice, these zones serve as protective shields between the heritage site and its surrounding urban or rural context.”

If this application proceeds in its present form, the Coalition for Gozo said it will have no other option except to once again submit a formal report to UNESCO, as it did in the case of Gigantija Heights, something the Coalition said it would like to avoid, as this is risking yet another international rebuke for Malta from the Director of UNESCO and further negative exposure in the international press.

The Coalition for Gozo concluded by requesting the PA “to suspend this project, commission a full Heritage Impact Assessment and ensure that a proper evaluation of the vernacular structures proposed for demolition is carried out.”

Photos Coalition for Gozo: Back elevation of the apartments: and the vernacular farmhouse rooms set for destruction

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