New Nadur cemetery - the facts -
Perit Edward Scerri
Sunday, June 24, 2007

I have been entrusted by the Rev. Archpriest of Nadur to present the facts on the development of a new cemetery at Triq Ghajn Qasab, Nadur, following your publication of a press release on this subject by Dr Harry Vassallo, chairperson of Alternattiva Demokratika.

It is not true that the full development application for this project was approved in the same week as the private redevelopment of the Ulysses Lodge at Ir-Ramla l-Hamra. Application PA2407/04 for the new cemetery was approved on November 6, 2006. It took MEPA seven months to issue the printed version of the permit which was sent on June 5.

Part of this time was entailed in preparing a bank guarantee, which, among other conditions, ensures the transplanting of young olive trees which third parties planted within the site after the outline permit was approved. In any case, it is very unfair to link a private project with a public utility project.

The public should be aware that the construction of a new cemetery in Nadur is not an avoidable luxury but a long-needed and expected necessity. The present cemetery is very small, covering two or three normal plots and is located within an area that was opened up for residential development around three decades ago. The result is that this cemetery literally abuts residences, unlike any other cemetery in Gozo. A very small plot at the back of the cemetery owned by the parish could not be developed as an extension of the cemetery because this was not acceptable by public health standards, given the abutment of the cemetery by the residences.

Dr Vassallo's statement gives the impression that no other alternative sites were considered prior to the presentation of the application on the approved site. This is far from true. One such site was at Triq ta' Xhajma, currently used by motocross enthusiasts, and which is government owned.

However, during the presubmission consultation MEPA first asked us to seek the approval of the WSC who then had the responsibility of the natural aquifer instead of MRA. The WSC did not issue its approval for that particular site since it bordered a government borehole. No further studies were carried out on that site.

Furthermore, the parish could not resort to sites that were privately owned but only to sites that were administered by the Lands Department or the Joint Office. The site at Triq Ghajn Qasab was in fact administered by the Joint Office. Dr Vassallo must acknowledge that a cemetery has to be located outside the development zone. There even exists a public health regulation that it has to be located 250 yards from habitable areas. Dr Vassallo failed to propose which other alternative sites he considers as appropriate for the location of a cemetery in Nadur, given these constraints.

Other past statements by AD that the cemetery will have 2,000 buried persons at the same time are truly fictitious. The approved cemetery caters for around 600 graves, each with three layers. Public health regulations do not allow the opening of a grave within two years from the burial of a person within that particular grave.

It is therefore impossible that graves be occupied by 600 decomposing bodies at the same time, let alone 2,000. In any case, the way the cemetery will be constructed, as already specified in the course of the processing of the application, will ensure that the graves are sealed exactly like a water reservoir and the possibility of contamination does not exist.

The number of graves included in the plans of the project was reached after making a comparison between the number of graves in other village cemeteries vis--vis the individual village populations.

Nadur is the largest village of Gozo, larger than Xewkija and Xaghra with respect to population. When taking the proportion of the population of the village with respect to the villages of Qala and Sannat, the size of the cemetery of Nadur should be around 800. With respect to the cemetery approved for Xaghra, it should be around 847. Considering the existing graves in Nadur, which amount to 147, the new cemetery of around 600 graves is proportionately even less than the grave accommodation in other villages.

Furthermore, we have reduced the number of graves following various requests of the DCC for more landscaping, more spacious landings and circulation spaces, even if our original plans catered for all this. Out of these 600, 150 must legally obligatorily be reserved as common graves. Therefore only around 450 remain available. Considering that the parish already has a list of around 300 applications for burial plots and considering that:

more demand may arise from nearby parishes;

some graves within the existing cemetery may eventually be transferred to the new cemetery since the site of the existing cemetery literally abuts apartments and houses;

more requests from the Nadur population will arise once the project starts;

a projection of future requests within the coming 10 years must be allowed for, then the number of graves in the new cemetery is more than justified.

Regarding the fact that no EIA was prepared, it must be noted that a look at EIA legislation does not oblige the preparation of an EIA for such a project. Furthermore, clause 1.1 of the EIA legislation (General Category of Project) specifies that an EIA would still be required if the development involves five hectares of land or the ground cover of the building or installation exceeds one hectare.

Our whole site covers approximately 0.65 of a hectare. If the proposed development did fall under one of the EIA legislation categories, MEPA would surely have asked for the preparation of an EIA. However, on approval of the outline permit, MEPA did ask for a number of reports, which covered the following aspects, effects on hydrology and hydrological features, effects on agriculture, visual effects, landscaping scheme.

One of the reports prepared was a hydrology and hydrogeology baseline survey prepared by reputable geologist Saviour Scerri. The report concludes that "the proposed development is unlikely to have any adverse impact on these resources", given obviously the implementation of certain construction measures that we ourselves had proposed. The Nadur parish is not in any way ignoring the preoccupations of the farmers who till land in the vicinity. The implementation of the measures of this report as well as other self-imposed measures that have been issued as part of the permit conditions ensures that the development will not in any way affect the water aquifer.

Regarding the size of the proposed chapel, may we point out that the size of the chapel was reduced further substantially prior to the approval of the permit. The circular basic forms of the chapel and its minimum use of glazing ensure that it blends well with the surroundings. Furthermore, the chapel will not affect the skyline because the land at the back of the cemetery rises substantially.

No mention was made of the effort invested in avoiding the conventional grid layout of local cemeteries and in including an enormous number of trees and plants, which approaches the 1,000 figure. The levels of the cemetery follow those of the street and for this reason seven different terraced sections were created. The walls separating the cemetery from the fields will consist entirely of rubble walls.

The fact that the site for the cemetery was not included in the Gozo Local Plan does not mean that the site cannot be developed as a cemetery. Outline permit PA2887/02 for the project was already approved before the final version of the Gozo Local Plan was issued. Furthermore, there are other examples where public utility developments were not shown in the draft or final Gozo Local Plan but the Local Plan Unit still gave favourable views. One such development was a new large playing field at the back of the H.O.S. residences at ta' Seguna, Sannat. Permit PA1717/03 for this development was issued on February 20.

Finally, may I point out that the implementation of a project such as a cemetery by a church parish will result in saving taxpayers thousands of liri. A cemetery should ideally be developed by the government since it is a necessary public utility, and the government would still sell the graves at a cost. However, the Nadur parish understands the preoccupation of the Nadur residents who have been pressing the parish to solve the problem of grave shortage at least for the past 20 years.

The Nadur parish does not intend to make lucrative profits out of this project, as has been implied. It would be happy simply to cover the mammoth cost of such a project. The parish knows that there have been many cases where Nadur families have had to resort to unhappy decisions, which had to be taken because of the extreme shortage of graves in Nadur, with its 4,000 strong population. The parish knows that the vast majority of the Nadur, residents appreciate the effort of the parish in providing them with a decent burial site.

Population: 3,669
Grave plots: 781
(DCC approved extension of 601 graves in 2005)

Population: 3,971
Grave plots: 147
(within cemetery in residential area)

Population: 1,315
Grave plots: 280

Population: 1,489
Grave plots: 260
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24 Jun 2007 by