City of Valletta

a) Lack of definition of a buffer zone

b) Changes in building heights might alter the city’s skyline

c) Major potential development of the new City Gate and the Opera house

d) Development, visitor/tourism pressures

e) Change of use of resident houses for business

October 2015, January 2017: ICOMOS Advisory missions

A state of conservation report was provided by the State Party on 23 March 2023 in response to a request from the World Heritage Centre to enable it to assess the progress made in implementing the recommendations of the 2015 and 2017 ICOMOS Advisory missions and to obtain a comprehensive overview of the potential and cumulative impacts on the property’s Outstanding Universal Value (OUV) of a number of ongoing or planned projects, following growing concerns expressed by Maltese individuals and civil society. The state of conservation report is available at https://whc.unesco.org/en/list/131/documents/. Information presented in this report is as follows:

• A site manager was appointed in January 2023;
• Numerous projects to restore state-owned cultural properties and churches in Valletta are underway;
• An update on large-scale developments in Valletta reported in 2010 includes:

• The hotel project for Lower Fort St Elmo has been halted,
• The excavation of an inter-Harbour Sea Link underneath Valletta has not yet been implemented,
• The rehabilitation of Valletta’s waterfront moat and Triton Square, the establishment of the MUZA National Museum of Fine Arts within Auberge d’ltalie and the proposed interventions and modifications to parts of the Mediterranean Conference Centre (former Sacra Infermeria of the Knights of Malta) have been completed and the St John’s Co-Cathedral Museum project is being implemented under supervision of the Superintendence of Cultural Heritage, all following the advice of the 2017 ICOMOS Advisory mission and subsequent Technical Reviews;

• The regeneration project at Manoel Island is still at the design stage;
• A call for expressions of interest has been launched for the redevelopment of the Evans building into a high-quality tourist accommodation facility. It includes maintaining the building's facades and carrying out archaeological excavations;
• Heritage and/or Environmental Impact Assessments have been requested for the extension of the Grand Hotel Excelsior, the New Breakwater arm off St Elmo point and the redevelopment of Mattia Preti House, and will be undertaken for the Fast Ferry Quay Project. Only the Heritage Impact Assessments (HIAs) that comply with to the Guidance and Toolkit for Impact Assessments in a World Heritage Context are considered by the Superintendence of Cultural Heritage;
• The final draft of the Management Plan was commissioned by the Maltese Government based on a mandate issued by the Superintendent for Cultural Heritage and was due to be finalised in May 2023 for approval by the Cabinet of Ministers and submission to the World Heritage Centre by the end of June 2023. It will include an in-depth analysis of views and vistas, which should assist in the delineation of a buffer zone for the property;
• The solutions envisaged for mass tourism involve spreading the concentration of visitors, promoting Malta as a year-round destination and improving accessibility by introducing ferry services linking the City of Valletta to other areas;
• The State Party undertakes to ensure that the economic and social benefits derived from the tourism industry are integrated into a holistic strategy of historic conservation, social cohesion and environmental sustainability;
• To minimise the negative environmental impact of tourism in Valletta, access points and routes are being diversified to spread the concentration of visitors coming ashore from cruise ships. A ship-to-shore power connection will be established to allow cruise ships to turn off their onboard engines when docked. Measures to reduce vehicular traffic in Valletta include free public transport, access to the city by sea and out-of-town parking. These measures have resulted in the requalification of three of the city’s parking areas in the city as pedestrian piazzas.

A 2017 study on wave disturbance in Valletta harbours is annexed to the report, providing inter alia information on the baseline situation as well as modelling situations and proposals to improve wave disturbance through the construction of a berm and revetment.

From August to December 2022, the World Heritage Centre received and shared with the State Party information from third parties concerning certain projects that may have an impact on the property’s OUV, including the above-mentioned extension of the Grand Hotel Excelsior in the vicinity of the property, the degradation of the roofscape of the property and the construction of a new six-storey concrete façade on the shoreline of the property (Mattia Preti House). On 7 December 2022, the State Party responded by informing that the developers of the Grand Hotel Excelsior would be requested to submit a HIA before any further deliberation on the project, that the application of rooftop additions in Valletta was in the consultation phase to assess its impacts on the property’s OUV; and that the concerns of the World Heritage National Technical Committee regarding the negative impact on the OUV would be taken into account in the Mattia Preti House project. Most recently, on 12 July 2023, the Centre provided third party information to the State Party on two issues, namely the increased commercial development in Valletta’s strategic view corridors and works for the new Museum of St John’s Co-Cathedral, which would impact on the entry of natural light into the Oratory by permanently blocking the window closest to the altar. At the time of writing, no response had yet been received by the World Heritage Centre.

The appointment of a new site manager for the property is welcome, as is restoration work of many state-owned cultural properties and churches, which should help to maintain the OUV of the property.

The brief overview of the status of implementation of large-scale developments in Valletta since 2010, as well as projects within and outside the buffer zone as envisaged in 2010 are noted. It is positive that the State Party has adopted the advice on large-scale projects provided through the two ICOMOS Advisory missions and the various ICOMOS Technical Reviews. ICOMOS concluded that the St John’s Co-Cathedral Museum, as designed at that time, was coherent in its programme and distribution and that the significant improvement it made to the existing museum had advantages that far outweighed its disadvantages.

The 2017 Advisory mission recommendations advised the State Party to complete the property management plan and the ‘Views and Vistas analysis’ to address the issue of tall buildings in the property and its wider setting as a matter of urgency, to conduct HIAs for all future major restorations or new construction within the property and to urgently re-appoint a site manager. The first two recommendations have not yet been completed, while the appointment of a site manager was completed with considerable delay only in 2023. The 2017 Advisory mission also recommended that the State Party should continue to promote high quality new, sympathetic design within the property, rather than permitting façadism and pseudo-historicism.

With particular reference to the proposed regeneration of the Evans Building site, an ICOMOS Technical Review dated August 2022 concluded that there was a strong case for the preservation, conservation and repurposing of the Evans Building, and provided a number of recommendations in this regard. The 2023 state of conservation report submitted by the State Party does not provide information on the follow-up to these recommendations. It is regrettable that the tender for the redevelopment of the Evans Building appears to recognise only the value of the facades and potential archaeological remains and that, according to the website for the proposed redevelopment of Manoel Island in the immediate vicinity of the property, the masterplan was approved before the completion of the ‘Views and Vistas analysis’. Noting that the regeneration project is still in the design phase, the Committee may wish to request the State Party to ensure that the ‘Views and Vistas analysis’ is finalised before the masterplan is approved.

The State Party has carried out HIAs, particularly for projects that were the subject of mission recommendations, although a more systematic and holistic approach would be welcome, particularly for projects within the property. It is also noted that the State Party has requested that Heritage and/or Environmental Impact Assessments be undertaken for some other projects that are under consideration. It is proposed that the Committee recommend that the State Party commission Impact Assessments for all projects that may have an impact on the OUV of the property, paying particular attention to the indirect and cumulative impacts of the many projects proposed in the property and its buffer zone and using the Guidance and Toolkit for Impact Assessments in a World Heritage Context.

Furthermore, it is noted that the State Party makes no reference to height increases in projects within and in the vicinity of the World Heritage property that could have an impact on its skyline. It is therefore recommended that the Committee request the State Party to finalise the ‘Views and Vistas analysis’ from strategic viewpoints to address the issue of height controls inside and outside the property, in accordance with Decision 33 COM 7B.113. It is of concern that limited progress has been made on the establishment of a buffer zone, requested in that same decision in 2009. The Committee may therefore request the State Party to proceed with the finalisation of an adequate buffer zone delineation, based also on the outcomes of the ‘Views and Vistas analysis’, in accordance with the requirements detailed in paragraphs 104 and 105 of the Operational Guidelines, and to submit it to the World Heritage Centre for review in accordance with paragraph 107 of the Operational Guidelines. The final draft of the Management Plan for the property needs to be completed, in line with the 2011 Recommendation on the Historic Urban Landscape and include managing of the future buffer zone and the outcomes of the ‘Views and Vista’s analysis’ and submitted to the World Heritage Centre for review by the Advisory Bodies prior to its formal adoption.

The State Party’s efforts to address mass tourism issues, through tourism management, minimising environmental negative impacts and ensuring that benefits from the tourism industry accrue to the restoration, preservation and sustainability of the property, are welcome and seem to be moving in the right direction. However, considering the negative pressures that mass tourism can exert on the property, it is recommended that the State Party develop a tourism management plan which forms part of the overall management system of the site.