Maltatoday, 24th August 2008, by James Debono –

Malta’s heritage watchdogs, the Superintendence of Fortifications and the Superintendence for Cultural Heritage are up in arms against the obliteration of St Peter’s Battery, a unique World War II relic, to make way for 77 townhouses in the Smart City project.
The heritage guardians are also concerned that another 50 villas, to be constructed near Fort St Rocco, will affect the integrity of the site.
The developers reacted to the objection by slightly modifying their plans for the construction of villas beneath Fort St Rocco and the St Peter’s area. But in his written reaction to the Environmental Impact Study, commissioned by the developers, Superintendent for Fortifications Stephen C. Spiteri did not mince his words in exposing the developers’ complete disregard for the country’s cultural heritage.
“Hardly any attempt whatsoever has been made by the designers of the said project to incorporate any of the historical military features, together with their setting, within the overall design and layout of the proposed Smart City,” wrote Spiteri in his comments on the EIS.

Stephen C Spiteri also claims “none of the concerns he had submitted in writing have been given any weighting.
“Even worse, some of the most salient historical military features to which attention was drawn to as deserving special attention, such as St Peter’s Battery, are now, contrary to our advice, to be unceremoniously swept away,” he protested.
The project’s EIS states that the project will involve the demolition of a heavy anti-aircraft battery and related facilities, two Gun Post, 3 Rifle Butts and a Pillbox.
The Environmentat Impact Statement commissioned by the developers considers “the proposed demolition of the St Peter’s position finding station and Anti-Aircraft Battery in its entirety as well as a Grade 2 farmhouse will result in a major negative impact.”
Effectively “the area will be surgically cleansed of all its military and defensive features,” the Superintendence claims.
An even more sensitive matter is the proposed demolition of St Peter Battery situated in an area where villa development is envisioned.
According to the Superintendence the annihilation of St Peter’s Battery, is considered to constitute a “further impoverishment of Malta’s unique military architectural ensemble.”
Rather than treating these fortifications as historical and cultural assets, “these features have been treated as liabilities and swept away.”
The battery is one of the few WWII gun batteries to have retained “most its features and authenticity” and could easily be restored as a cultural attraction the Superintendence said.

Heritage hassles
The Superintendence also objected to the heights of the proposed buildings in front and to the rear of Fort St Rocco. Built by the Order of Saint John in the 18th century, this fort is not touched by the development. But new apartments, in front and behind, will also interfere with the visual link between the fort and the sea.
“Given that Fort St Rocco is a coastal work of fortification, any development that surrounds it must be sensitive enough not to suffocate and compromise the fort’s commanding position in the landscape.”
The Superintendence warns the authorities not to repeat the mistakes of the past, by allowing development similar to that witnessed at places such as Marsascala, where St Thomas Tower “was suffocated by the Jerma Palace Hotel.”
Malta’s other heritage watchdog, the Superintendence for Cultural Heritage is likewise concerned that Fort St Rocco will be “effectively surrounded and engulfed by the site of the proposed development.”
The project will also have an impact on a number of rural heritage features.
The EIS states “although many of these features will be retained, including all rubble walls within the site, the development of the Scheme alters their setting from that of a rural landscape to a largely urban one.” The impact is considered to be of major significance.
The EIS also warns that works could also damage an entrenchment wall and recommends “sensitive construction methods” to protect it.

Loss of agriculture and trees
The EIS acknowledges the loss of good quality agricultural land in at least two areas within the site, namely: five terraced fields in an area locally known as Ta’ San Rokku and another site bordered by Triq San Leonardu known as Ta’ San Pietru and Ta’ Alessi.
Another major adverse impact is the loss of a number of protected tree species, including Aleppo Pines, Carobs, Mulberries, Olives and Pomegranates. Legal Notice 12 of 2001 protects these species. But the law allows developers to transplant trees whenever this is possible, or to plant new tress elsewhere.
As regards loss of habitat, the major impact will be on the coastal zone since this is one of the major sites where the rare plant Mesembryanthemum crystallinum is found.
The loss of this rare plant would have major ecological significance. The EIS recommends as a mitigation measure the relocation of the plant community.

Waste generation
Excavations for the Smart City project scheme are estimated to generate 651,119 cubic metres of excavation material. This makes Smart City the greatest waste generator in Maltese history.
Smart City will produce more than 44.5% of the inert waste currently produced by Malta in a single year.
The preferred option of the developers is to dump this waste in an offshore dumping site, where disposal of waste is allowed by MEPA.
A jetty has already been constructed to enable trucks to dispose waste arising from the demolition of the industrial estate to a barge, which would then transport the inert material to an offshore dumping site.
Where possible, the excavated material will be reused on site as fill.

Energy cost
The Resources Authority deems the energy demand required for Smart City when it is fully operational to be twice that of Gozo and around 9% of the peak demand of the entire country.
The EIS estimates the project’s total power demand to be 51,466 kVA, requiring the construction of two primary 33kv/11kV substations.
According to MEPA’s own panel, the EIS does not estimate or even consider the impact of this additional power requirement on the national carbon footprint, which is strictly limited by the European Union.
The scheme as proposed does not provide for the generation of energy from alternative sources such as wind and solar power.
According to MEPA’s Natural Heritage Panel, this high-tech project provides a clear opportunity for the exploitation of such alternative sources of energy including solar heating and street-lighting, photovoltaic energy generation and wind turbines.
Reacting to the EIS, the Resources Authority’s Energy Directorate expressed serious concern on the “lack of a serious Energy Management Plan.” Although the developers are committed to achieve the Leader in Energy Efficiency Design (LEED) certification for such a large project, the Authority complains that “no specific measure to comply with energy efficiency measures is mentioned in the EIS”.