ASM – GRDA consultation document

Victoria, Gozo - photo by Berthold Werner, CC BY-SA 3.0, via Wikimedia Commons

The Archaeological Society Malta welcomes plans for a green urban upgrade of Victoria and any projects that sensitively improve the urban and rural landscape of Gozo.

Nonetheless, true to its mission, the Society believes that any such initiatives should not be achieved to the detriment to any archaeological or historical sites within the area of development.

This applies to the site proposed for development as the proposed project lies within an Area of Archaeological Importance (Class A) and an Urban Conservation Area.

More specifically, the proposed upgrade lies in the area between the ancient city of Gaulos and its extramural burial site. This is supported by remains along Triq ir-Repubblika, Villa Rundle Gardens and Pjazza San Frangisk as well as others. A preliminary review of the consultation document also reveals an extensive change in the area with underground parking facilities likely to disturb any existing archaeological deposits during the construction phases.

In view of the above, and of the exceptionally high and well-documented archaeological sensitivity and importance of the area in question: –

  • The consideration of any application for this project should be preceded by a thorough Archaeological Impact Assessment; this should be completed BEFORE any decision is taken about whether the project should proceed or not, and what form it should take. For clarity, a thorough Archaeological Impact Assessment is not limited to a desktop exercise, but needs to apply appropriate methods, under the direction of the SCH, such as intensive remote sensing and representative sampling with archaeological sondages, to acquire a sound understanding of the extent and location of areas of higher archaeological sensitivity, the preservation of which needs to be an integral consideration throughout the project design process, from concept to realisation.
  • Timeframes for completion of the project should take into account the likely archaeology related works that need to be carried out, particularly as the works are extensive and the area has the potential for archaeological finds.
  • Any works on site should be monitored at all times by an adequate number of SCH approved archaeology monitors, under the supervision of the Superintendence of Cultural Heritage.
  • Plans should be changed according to finds and where conservation is feasible, incorporated into the final project.