Liverpool lost its world heritage status in 2021. Dresden’s Elbe Valley had its status revoked in 2009. And now a recent evaluation of Valletta has heritage campaigners worried.

The capital city was named a World Heritage Site by UNESCO in 1980, joining Dubrovnik’s old town and France’s Palace of Versailles.

But in its most recent ‘state of conservation’ report on Valletta, UNESCO highlighted the impact of mass tourism and major plans to develop projects such as the Evans Building and the Grand Hotel Excelsior.

Conservation NGO Flimkien għal Ambjent Aħjar (FAA) said UNESCO was highlighting how Valletta’s heritage significance is being eroded.

It said the report showed how the capital’s status as a World Heritage Site was being “undermined”.

However, according to Ray Bondin, the chairperson of the Maltese National Commission for UNESCO, the report was not as damning as feared.

“There’s no doubt the report was very critical but, at the same time, it did appreciate the actions taken so far by the government,” he said.

“We insist these reports are responded to and I’m sure the government will respond accordingly.”

While Bondin conceded the heritage body was unsettled by the impact of increased commercial activities, he stressed that fears the city is at risk of being removed from the prestigious list are, at present, unfounded.

“The commercialisation of Valletta is quite dramatic and there is a feeling it has gone too far, but this alone isn’t enough. I don’t anticipate Valletta having any problems regarding being delisted.”

What did the report say?

While the report did not say Valletta’s status as a World Heritage Site was at risk, it did point out shortcomings.

UNESCO said it had received no response to its warnings about increased commercial development and said it was concerned that “limited progress” had been made on the establishment of a buffer zone requested in 2009.

It flagged concerns about works to St John’s Co-Cathedral, which it said would impact natural light in the oratory – the area of the cathedral housing Caravaggio’s Saint Jerome Writing painting.

Recommendations dating back to 2017, including a management plan for the city, an analysis of the impact of tall buildings on its skyline and heritage impact assessments in line with UNESCO guidelines had still not been completed, it said.

Meanwhile, a site manager had only been appointed this year “with considerable delay”.

A response to recommendations for works to the historic Evans Building had also not been provided, the report said, describing it as “regrettable that the tender... appears to recognise only the value of the facades and potential archaeological remains”.

The government wants to transform Valletta’s Evans Building into “upmarket tourism accommodation”.

The commercialisation of Valletta is quite dramatic and there is a feeling it has gone too far, but this alone isn’t enough

The culture watchdog also expressed reservations about plans to develop Manoel Island, noting the project’s website claimed the masterplan had been approved before an outstanding ‘views and vistas’ analysis had been submitted. Developers MIDI have applied to build a mix of residential and commercial properties on the island along with restoring heritage buildings.

UNESCO pushed for a skyline impact analysis for both projects, “before any decisions are made that may be difficult to reverse”.

The UN body proposed impact assessments for all projects in Valletta and the surrounding area that could affect the city’s ‘outstanding natural value’ – a designation applied to World Heritage Sites – and requested an updated conservation report from the government by the end of next year.

While the report noted efforts to restore State-owned churches and monuments and welcomed impact assessments completed in several cases, it pushed for improvements recognising “indirect and cumulative” impacts caused by development.

The culture ministry insists that the requested documents have been completed and simply awaiting approval at a national level.

How does the Valletta report compare to delisted sites?

UNESCO has delisted three World Heritage Sites in its history, most recently Liverpool in 2021, which it said had suffered “irreversible loss” from waterfront development and the construction of a new football stadium.

Like Valletta, concerns for Liverpool also focused on the impact caused by tall buildings including a planned multibillion-pound skyscraper.

When comparing Valletta’s recent report to Liverpool’s two years before its removal, however, there are stark differences in the language used.

Ahead of delisting Liverpool, UNESCO had issued reports recalling “repeated serious concerns” and expressing “extreme concern”.

In 2012, UNESCO concluded that should development proceed as planned, Liverpool would be “irreversibly damaged, due to a serious deterioration of its architectural and town planning coherence, a serious loss of historical authenticity, and an important loss of cultural significance.”

It was subsequently added to the organisation’s list of sites in danger.

Germany’s Dresden Elbe Valley was also delisted just five years after joining in 2004, following the construction of a four-lane bridge crossing the Elbe valley at a site considered critical to views of the area.

In a report three years before its removal, UNESCO said plans for the bridge were of “great concern” and would “irreversibly damage” the site and urged the German government to “urgently halt” the project.

It too was added to the list of sites in danger in the same report.