At this rate, we may as well just demolish Ggantija altogether

Look: I know I might be coming across as a little naïve, to expect even an iota of ‘consistency’ in decisions taken by the Planning Authority… and even more so, in the PA’s interpretation, and application, of what are ultimately its own policies and guidelines…

… but seriously, though. Is it really that much to ask? Is it really so very ‘unreasonable’, to expect an institution such as the Planning Authority – which exists, among other things, to protect Mata’s natural and cultural heritage from overdevelopment – to actually abide by all the rules and regulations that it has created itself, for that very purpose?

I honestly don’t think so. And yet, I could probably fill this entire newspaper with examples of PA decisions that seem to flatly contradict each other, at every turn: especially, when it comes to how the PA’s own planning guidelines get to be implemented, in practice.

For the purposes of this article, however, I shall limit myself to only two: both of which involve applications for development (either to ‘build’, or to ‘sanction’) in more or less exactly the same area – literally, a stone’s throw away from each other, on the outskirts of Xaghra, Gozo…

… which also means, of course, that they are both just a stone’s throw away from one of our island’s most significant (and irreplaceable) archaeological marvels: the megalithic temples of Ggantija.

As such, the objections to these two developments (and there were many, coming from various quarters… including the international press) were likewise more or less interchangeable.

In both cases, it was argued that the proposed constructions would have an irreversible, negative impact on the integrity of a nearby UNESCO World Heritage Site; that excavations within Ggantija’s buffer-zone could seriously compromise – if not entirely obliterate – the archaeological sensitivity of the site’s wider surroundings (which are believed to still conceal as-yet unearthed discoveries); and that, in any case, both applications were clearly in breach of at least two of country’s most fundamental planning policies…

… namely, 2015’s The Strategic Plan for Environment and Development (SPED); and the Gozo and Comino Local Plans of 2006.

And yet, not only did these two applications result in vastly conflicting decisions – one of them was rejected out of hand; while the other is, as we speak, well on its way to being approved – but the one that was ‘greenlighted’ for approval, turns out to be BY FAR the larger, and the more obtrusive, of the two.

But tell you what: let’s take a closer look at each case; and I’ll leave it up to you to unearth any evidence of ‘consistency’ between them.

The first takes us back to March 2018, when it was reported that: “a sanctioning planning application involving the enlargement of a garage and underlying basement, together with an illegal boundary wall, was turned down by the Planning Commission. The said application concerns a dwelling located within walking distance from the Ggantija megalithic temples in Gozo.”

Now: admittedly, this brings us to a small difference, between this particular application from 2018… and the one for a ‘three-storey, 27-apartment block’ [!], in the same area, that was given a preliminary ‘go-ahead’ just last week.

In the former case, the applicant had already (illegally) built the structures concerned… and was applying to have them retro-actively sanctioned. And to be fair, this does constitute a rather serious aggravation, when it comes to any direct comparison between the two examples.

For even if the more recent case represents an infinitely higher level of threat – not just to Ggantija, by the way; but also to the skyline, character, and core identity of the village of Xaghra itself – than the mere ‘enlargement of a garage’… at least, the applicants themselves have not (as far as I can see, anyway) already ‘broken the law’… like their predecessor so clearly did.

All the same, however: while this may impact the PA’s actual decision-making process, to some degree - in the sense that it makes a ‘rejection’ all-but inevitable, in the former case - it has (or should have) no effect whatsoever on the underlying principles involved in the decision itself.

To put that another way: if ‘Decision A’ was based on ‘Rules X, Y and Z’… and ‘Rules X, Y and Z’ have not changed, in any detail whatsoever, since 2018… then for consistency’s sake, ‘Decision B’, in 2022, should also be based on the same rules and regulations…. effectively, leading to the same conclusion.

But that’s not exactly what happened, is it? Among the many reasons for the PA’s initial rejection of that earlier, 2018 application (which went on to be confirmed by the Appeals Tribunal) was that:

a) “The proposal ran counter to Gozo and Comino Local Plan policies GZ-ARCO-1 and GZ-ARCO-2”

[Note: and ‘GZ-ARCO-1’, in particular, stipulates that: “Until such time that the relevant area or site is scheduled, requests for development permission shall be considered IN THE LIGHT OF THE PROPOSED SCHEDULING”. This translates roughly as: “Even if the area is still designated as ‘within the development zone’… it still has to be treated as ‘scheduled’, regardless.”]

b) “The proposal was in breach of Thematic Objective 8.1 and Thematic Objective 8.7 of the Strategic Plan for Environment and Development, which aim to safeguard and enhance cultural heritage”;

c) “The development had an adverse impact on the rural landscape surrounding the Ggantija Area of Archaeological Importance which includes the Xaghra Stone Circle and the Ghar ta’ Ghejzu”;

d) “[It] ran counter to policy 6.3 of the Rural Policy & Design Guidance 2014 which specifies that structural extensions ‘must respect the rural context and must not compromise the scheduling characteristics of sites of archaeological importance’.”

Now: as far as I can see, every single one of those four objections should apply just as much to any other proposed development, in any other part of what is ultimately the same buffer-zone, of the same UNESCO World Heritage Site.

Yet when it came to assessing a later application – initially, for a ‘FIVE-storey, 31-apartment block’ [!!], complete with ‘underground garage-space for 20 cars’– it’s almost as though not a single one of those policy-guidelines was even still applicable, just a few years later.

So instead of ‘rejecting the application out of hand’ – for the same reasons given above: i.e., because the entire proposal clearly violates every last rule in the PA’s own handbook, on ‘How to Protect Priceless National Monuments’ – the applicants were simply asked to ‘scale down’ their project…

… from ‘five stories’, to ‘three’; and from ‘31 apartments’, to… erm… ‘27’…

… and, well, that’s it really. Never mind that the resulting development still remains around 50 times BIGGER – and more visible – than the one which the same PA had earlier rejected, on the grounds that it ‘compromise[d] the scheduling characteristics of sites of archaeological importance’…

… and never mind that – at three stories in height – this new apartment-block will still tower at least two stories above ALL its urban surroundings (thus firing the ‘starter-pistol’, if you will, for a mad scramble to increase building-heights across the board, in that part of Xaghra)…

… and never mind, too, that the excavation-works that will be required, for all that underground parking, will have a far more devastating impact on the area’s archaeological sensitivity, than any amount of ‘enlarged basements’ (as will the increased urbanisation of the entire neighbourhood: with more people, leading to more traffic, to more pollution, to more demand for even more amenities… all of which, ultimately, points towards ‘more construction and development’ in future...)

But never mind all that; because according to the Superintendence of Cultural Heritage, “after revisions to the plans that saw the proposed development scaled down […] the latest proposal has adequately addressed the concerns previously outlined…”

Huh? What? Really? And if you don’t me asking… HOW, exactly?

Because last I looked, the ‘concerns’ that were ‘previously outlined’ were all rooted in precisely the same rules and regulations – SPED, the Local Plans, Rural Policy & Design Guidance, and all that – which the PA itself has already (rightly) interpreted to mean that…

‘Sorry, folks! There can be NO development, of any kind whatsoever, in the buffer-zone of Ggantija Temples (or any Grade One scheduled monument, for that matter). Because THAT, quite frankly, is what the regulations governing Malta’s environmental and heritage protection actually say. (And guess what? Those regulations exist to protect far more important things, than the commercial profitability of any given ‘development-project’…)”

And besides: if the Planning Authority says ‘yes’ to a ‘three-storey, 21-apartment block’, today… how can it possibly be expected to say ‘no’, when future developers submit applications for a ‘21-storey, 750-apartment block’, tomorow? (Even if on the understanding that – for future approval – they would have to be ‘scaled down’ to, say, only ‘15 storeys’, and ‘450 apartments’, instead?)

No, no, make no mistake: there is more to this than just the ‘integrity of a UNESCO World Heritage site’, you know.

If the Planning Authority does make the colossal mistake of actually approving this aberration – and in all honesty, I fail to see how it can possibly be otherwise: considering that it has now been ‘greenlighted’, by the very people who are supposed to be ‘protecting our heritage – it would mean more than just a death-knell, for Ggantija Temple itself…

… it would be the equivalent of taking every last ‘rule and regulation’, that exists to safeguard even the most priceless aspects of our culture, our heritage and our identity… and just flushing it down the toilet, in one fell swoop.