PA 07902/05– Site at Triq Ghajn Qamar, Xaghra
6th June 2007

Ref. Cultural Heritage Act 2002, (CAP 445)

PA 07902/05– Site at Triq Ghajn Qamar, Xaghra

The attention of the Superintendence of Cultural Heritage has been drawn to the proposed development indicated in caption.

Despite cultural heritage considerations that are known in this area, perusal of the MEPA website does not indicate any consultation with the Superintendence, and the Superintendence has therefore limited information on this proposed development.

The Superintendence is however informed that the application proposes 35 villas with swimming pools. This would be a large scale and impactful development in an area known to be archaeologically sensitive and in the relative vicinity of areas and features protected by planning legislation.

The Superintendence is further informed that no Environmental Impact Assessment (EIA) was undertaken in relation to these proposed works. This is cause for concern, given the extent of the proposed development and the cultural and natural heritage values of the site and its surroundings. The absence of an EIA suggests that the Board is being asked to base decisions on inadequate information and without awareness of the impact of the proposed development.

The Superintendence notes that the site of the development overlooks an Area of Ecological/Scientific Importance and a Special Area of Conservation, as well as a complex of sand dunes of great ecological significance. It is unclear whether the potential impact on the ecology of the area has been identified or taken into consideration, especially since no EIA was undertaken.

Even in the absence of an EIA, the likely visual impact on the landscape is an immediate cause for concern, and such intensive development may not be compatible with the values of the bay, the cliffs and the valley system.

The site also overlooks scheduled cultural heritage features, including the Belancourt Battery and the remains of a pathway, as well as the exceptional archaeological site that is the Roman villa surviving under the sand at the water’s edge.

Cultural heritage features are also known to be present within the site of the proposed works. The so-called “Calypso’s cave” is known to be within the area. This feature has taken on a quasi-iconic identity and is a documented archaeological site, within which neolithic remains have been identified.

While such a find is indicative of the archaeological sensitivity of the site, no systematic study of the area has been undertaken in connection with the proposed development and the cultural heritage significance of the area has not been clearly recognised.

The Superintendence draws attention to the cultural and natural heritage values of the site and its surrounding landscape, and reiterates its concerns that such extensive development may not be compatible with the values of the site or the landscape. The Superintendence strongly urges that these cultural and natural heritage values should be identified and prioitised in the consideration of this proposed development.

Furthermore, the Superintendence notes that decisions should be based on adequate knowledge, and that this application should be only be further considered in the light of an Environmental Impact Assessment.

If this application is to be further processed in the absence of adequate information derived from an Environmental Impact Assessment, the Superintendence believes this application should be refused.

Thank you for your attention.

Mark Anthony Mifsud

f/ Superintendent of Cultural Heritage

cc Permanent Secretary, Ministry for Tourism & Culture, valletta

The Mayor, Local Council, Xaghra


138 Melita Street


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