Press Release: PA3758/19

Assoċjazzjoni Wirt il-Kalkara is hereby issuing the following Press Release in relation to PA3758/19, aiming to divulge information and facts regarding the permit issued last Friday.

Facts

1.  Site is located within development zone. Moreover, the site forms part of a protected buffer zone to the existing Cart Ruts as indicated in the list of scheduled property by means of Government Notice (G.N.) 0930 of 2002. The latter G.N also designates the said site as Cart Ruts together with a buffer zone as a Class B Site of Archaeological importance. Class B, UCO 7 states:

Class B: Very Important to be preserved at all costs.  Adequate measures to be taken to preclude any damage from immediate development.

2.  The works consisted in demolishing an existing pre-1967 dwelling, excavate the entire site and construct 10 garages and a substation at basement level, 4 maisonettes at ground floor level, 12 apartments at first, second and third floor levels and 2 apartments at receded floor level.

3.  The initial planning commission board meeting was held on the 09/01/2020, and it was concluded that an archaeological site investigation is to be carried and approved by the Superintendence of Cultural Heritage (SCH).

4.  On the 30^th January 2020, illegal demolition of the pre-1967 dwelling was taking place utilising heavy plant machinery, this without the necessary building regulation documentation and health and safety regulation documentation in place.

5.  On the 5^th of February 2020, the SCH recommended that an archaeological evaluation on the soil-covered areas is carried out, and that the submitted method statement by the applicant’s perit was acceptable from a cultural heritage point of view. In order for the archaeological evaluation to be carried out the SCH requested that: (Document 154a, eAPPS)

1. Prior to the issuing of a development permit on this site, the site is subjected to an archaeological evaluation in terms of the Cultural Heritage Act. This archaeological evaluation will be carried out in keeping with directions and Terms of Reference issued by the Superintendence and will be resourced by the applicant; 
2. The architect/developer is to provide for the approval of the Superintendence of Cultural Heritage the name of an archaeologist who will carry out this evaluation; 
3. This archaeological evaluation is intended to inform eventual planning decisions on protection or on mitigation measures as may be necessary in terms of the Cultural Heritage Act; 
4. The archaeological evaluation will be carried out without prejudice to approval or otherwise of the application.

Moreover, the SCH stated that the architect/applicant are to reminded that all other works, including any dismantling of structures and/or clearing of debris are to be carried out following the issue of the permit.

It must be noted that by the date of the submitted report by the SCH works involving the dismantling/demolition of existing structures was already done utilising heavy plant machinery.

5. On the 27^th May 2020, the SCH noted that: “ the archaeological evaluation has been completed satisfactorily and the methodology has already been approved by the Monitoring Unit.” – vide document 169a (eAPPs)
6. “The evaluation concluded that the cultural heritage feature identified within the site consists of a vaulted cistern which has lost its roofing.” – vide document 169a (eAPPs)
7. The SCH stated that: “given the nature of the site and the justifications presented by the architect/applicant, the proposed works are deemed acceptable from a cultural heritage point of view subject to a heritage gain.” – vide document 169a (eAPPs)
8. The SCH added that “all further ground disturbance works are to be archaeologically monitored and any rock-cutting is to be monitored up until the first 2 metres.” – vide document 169a (eAPPs)
9. A second planning commission board was held on the 03/07/2020, and the application for the works was unanimously approved.

Assoċjazzjoni Wirt il-Kalkara is aggravated and is concerned by the fact that even though the site is located within a development zone, is within a scheduled buffer zone demolition utilising heavy machinery took place without the necessary legal documentations in place.  Moreover, the large machinery could have potentially damaged any signs of cart-ruts and other archaeological findings such as “the vaulted cistern that lost its roofing”.  The recklessness of the developer in respect to the sensitivity of the site could not be passed unnoticed. 

OBJECTION TO PC00028/19

Assoċjazzjoni Wirt il-Kalkara is hereby making public its objection to the above-mentioned proposal on the following grounds:

1. The site covered by the abovementioned application forms part of the countryside and is situated in a rural conservation area as defined in the Kalkara Inset Map.
2. The site forms part of a buffer zone to the existing Cart Ruts as indicated in the list of scheduled property by means of Government Notice (G.N.) 0930 of 2002. The latter G.N also designates the said site as Cart Ruts together with a buffer zone as a Class B Site of Archaeological importance.
3. If this application will be considered for approval, other planning applications on the site will follow, eventually leading to further urban sprawling, potentially damaging the protected Cart Ruts (as the buffer zone would be substantially decreased) and would have an adverse negative impact on the heritage of Malta and the environment.