NGOs question Superintendence decision on development near Ġgantija

Updated April 30 with SCH response

A group of Gozitan NGOs has questioned a recent decision by the Superintendence of Cultural Heritage (SCH) to back a controversial planning proposal within the buffer zone of Ġgantija Temple in Gozo.

The Planning Authority had given its blessing to the proposed 22-apartment block of flats and 20 basement garages near the world heritage site in 2023, despite a request from UNESCO for a heritage impact assessment (HIA) before a decision was made.

A subsequent appeal led to the permit being revoked pending an HIA, which was concluded in early February.

The SCH said shortly after that it had no further objections to the plans, following revised drawings – in line with the impact assessment submitted by the developers.

In a statement Tuesday, the Coalition for Gozo – comprising Din l-Art Ħelwa Għawdex, Għawdix and Wirt Għawdex – said the superintendence’s decision was “deeply questionable” following an examination of its reasoning.

The NGOs said that despite the assessment claiming that screening, scoping, and stakeholder consultation were outside its remit, they were “not optional extras”.

“They are the backbone of the UNESCO process. Remove them, and what remains is not a rigorous assessment but a partial one. Yet the Superintendence presents this as methodological strength.”

It also accused the document of “leaning heavily” on UNESCO and the International Council on Monuments and Sites (ICOMOS), which it said was presented as a seal of approval.

“But UNESCO does not approve projects. It does not endorse HIAs. It reviews, comments, and advises. To present that as an endorsement is, at best, imprecise. At worst, it is misleading. Also, no ICOMOS report was presented to back the SCH claims.”

Questioning the superintendence’s handling of the assessment, the Coalition for Gozo noted that the HIA had conceded that the proposed development would “remain dominant in the streetscape” with the facade continuing to appear as a “single, homogeneous mass”.

“These are not minor observations. They are red flags. And yet, despite all this – in what amounts to a breakdown in logic – the conclusion is that the impact is ‘not significant’”, the coalition said.

“One cannot list impacts in detail and then simply declare them insignificant without explaining why. The Superintendence does not resolve this contradiction. It simply accepts it.”

The NGOs also questioned the treatment of the buffer zone, accusing the Superintendence of arguing that the impacts of the development would be less important when experienced from within the buffer zone rather than outside.

It described the scheduling for demolition of a vernacular farmhouse as “alarming”, describing heritage items as being “reduced to a checklist”.

“Approve this, and the next application will follow. And the next. Each will rely on the same logic: no significant impact, no contribution to OUV, no cumulative effect”, the coalition warned.

“By the time the damage becomes undeniable, it will already be done. This is not a matter of technical disagreement but an abject failure of judgement ... In the end, the question is simple: is the Superintendence there to protect our heritage, or to justify its loss?”

Last month saw renewed objections to the proposal.

'Rigorous assessment'

Responding to the developments, the SCH told Times of Malta that the application was subject to “rigorous assessment” by the Superintendence in consultation with the National World Heritage Technical Committee. 

It noted that while “numerous changes were carried out to the proposed development during the processing of the application, including a reduction in massing and volume, a Heritage Impact Assessment was still requested by the Superintendence”. 

The impact assessment coordinators were approved by the SCH in advance, while the compilation and writing of the report were done according to SCH guidelines, it said.  

“We were satisfied with the details and conclusions of this assessment ... The mitigation measure has indeed been implemented in the said drawings to the satisfaction of the local authorities.”