TO WHOM IT MAY CONCERN:
We are compelled to inform of a new road project in Albania, construction is currently underway, that threatens to partially destroy the historic city of Gjirokastra – enlisted as a UNESCO World Heritage site together with the City of Berat in 2005.
On November 10th, 2015 the Albanian Government – namely, the Ministry of Culture and the National Territorial Planning Agency (AKPT) – together with the design agency Atelier Albania launched an international competition titled, “Design of a Bypass Road in the UNESCO Protected City of Gjirokastra.” This project’s key stated objective is to keep vehicle traffic away from the Bazaar, so to pedestrianise the heart of the historic city. This seemingly positive project has a unacceptable caveat: the Ministry and AKPT have de-listed hundreds of cultural monuments for the blueprint of the ‘bypass’.
The negative impact of this project, possibly funded by the World Bank, will be immense. It will mean the demolition of cultural monuments, destruction of the continuity of a cultural landscape of the historic city, visual obstruction of an historic cityscape, negative impact upon the natural landscape and possibly the groundwater, vibration impact upon the geology and surrounding monuments, and significant increased number of tourists to a potentially unsustainable size, especially given the lack of a tourism and management plan. According to the geological seismic studies, the specific area where the bypass is proposed to be constructed is a high-risk area for buildings, and roads. Gjirokastra’s most pressing issue is the restoration of vernacular architecture monuments in danger of collapsing.
Moreover, there are at least six main arguments that demonstrates why the project approved by the Government (September 13th 2016) will be negative for Gjirokastra in particular, and world heritage in general.
It is in breach with the initial guidelines and terms of references provided in the call for the tender by the state authorities. This bypass has to be “located in the surroundings of the Historic Center and the Protected Zone”. Hence, the winning project should have had provide a design solution with the lowest impact on the Historic Center! See in Annex 1 all three proposals submitted for this international competition. The winning project done by Atelier is simply unacceptable as ninety percent of the bypass will be located within the Historic Center of Gjirokastra and the remaining ten percent inside the Buffer Zone. The cost estimate of the winning project was 2.2 million Euros, so why this hefty budget is not protecting the cultural heritage in Gjirokastra?
Link to competition:
http://competitions.planifikimi.gov.al/bypassroad/ If implemented, we will see the loss of archaeological resources, green spaces, landscape continuity, and community. Moreover, the transfer of traffic from the Bazaar to the green area surrounding the castle does not solve the original issue, but instead simply moves the problem to another area, one that once was protected as green and pedestrian-only. The lack of an overview study of transportation system in the historic center of Gjirokastra means that this immediate solution is likely to be unsustainable and might create more damaging developments.
It destroys at least two Category II Cultural Monuments (traditional houses) which were abruptly removed from the list of protected cultural monuments by the Ministry of Culture – the State Court of Gjirokastra has recently issued a verdict to suspend the administrative order of the Ministry of Culture to remove these two traditional houses planned to be demolished by ‘bypass’.
Moreover, it invades into the natural foundations of several other traditional houses/monuments of culture and of the castle, where archaeological excavations have been expected to begin. The two Category II Monuments to be destroyed by the project are the traditional houses of Koço Spiri (Code no. 203026) and Llaqi Papazisi (Code no. 203027). On Sep. 13, 2016, the National Council of Restoration made a decision (no. 223) to remove (de-list) these two traditional houses with the intention to demolish them during the implementation phase of the ‘by-pass’ road project. Their demolition was also foreseen in the presentation Atelier 4 gave at the National Council of Restoration on Sep. 13, 2016. This decision was made in breach of the current Law on Cultural Heritage (Law 9048/updated). Article 25, par. 2, of this Law, which specifies that monuments that are enlisted as Category I or II Monuments of Culture, cannot be removed from the list without the request from the owners. The current owners have never made such request. Moreover, both houses are in good static condition and inhabited. Please see below photos of the two traditional houses which are characteristic to the area with important values to its urban landscape:
It is in breach with the current legislations: the Law on Cultural Heritage, the Albanian Charter of Restoration, and the Regulation of the Historic Center and the Buffer Zones of Gjirokastra. All of the aforementioned legal regulations (See Annex 2) declare the prohibition of new constructions within the Historic Center of Gjirokastra and its Buffer Zone.The decision (no. 223) made by the National Council of Restoration on Sep. 13, 2016, to remove (de-list) these two traditional houses (Category II Monuments of Culture) was made without a prior evaluation and written approval form the Institute of Monuments of Culture (IMK). The Institute of Monuments of Culture submitted an evaluation report on these two traditional houses one month after the decision of the National Council of Restoration to remove the two houses from the list. It must be noted that according to the Law on Cultural Heritage (law 9048/updated), Article 25, par. 3, of the Law specifies that the objects that hold the status of cultural monuments “cannot be destroyed or changed, without the written approval from the Institute of Monuments of Culture”. Also, these two traditional houses (labeled Koço Spiri and Llaqi Papazisi) were declared Category II Monuments of Culture on May 11, 2016, through decision number 135. Hence, these two traditional houses were declared monuments of culture four months before the decision of the National Council of Restoration to de-list them although their static condition and general values did not change at all in this period. Despite this, the Ministry of Culture gave an administrative order (number 369) on Nov. 16, 2016, to remove the two traditional houses from the list of monuments.
The tender process was not transparent and arguably invalid – the winning project announced by the government and ‘Atelier Albania’, was later drastically changed by the National Council of Restoration (NCR). The change doubled the bill of quantities/cost estimate, and by completely changing the solution and shape of the project. The NCR discussed and approved this project on September 13th, 2016; however, the project approved by the NCR is different from the winning proposal of the competition carried out by “Atelier Albania” in cooperation with the Ministry of Culture, changing it by more than 50 percent in both shape and solution. This automatically makes the tender process invalid. The cost estimate for the new bypass approved by the NCR is over 4.1 million Euros (twice the cost of the winning proposal)
At least three geological and seismic studies prove that the specific area covered by the approved ‘bypass’ is on a very dangerous seismic zone with a geological tectonic crack. These three studies are listed below: 1) Sulstarova, E., Kociaj, S., Aliaj Sh., Seismic Regionalization of the PSR of Albania, Academy of Science – Seismological Center, Tirana: 1980. 2) Torresi, F., “Piano di recupero del centro storico di Gjirokastra”, Study in close cooperation with the Albanian Government, 2006.http://www.studiotorresi.it/sito/en/main-works/urban-planning/189-piano-di-recupero-del-centro-storico-di-gjirokastra.htm 4) Cavinato, G., Duni, Ll., Moscatelli, M., Pojani, I., Simionato, M., Cosentino, G., Pagliaroli, A., “Assessment Analysis of Seismologic Risk and Geohazard Vulnerability of First Level in Major Cultural Heritage Sites of Albania”, University of Tirana, Albanian Conference on Disaster Risk Preparedness and Management in Cultural Heritage Sites Berat, May 8, 2012. http://www.slideshare.net/UNESCOVENICE/disaster-risk-preparedness-management-cavinato-ii
It is not in accordance with the urgent priorities and insatisfiable conservation needs of the Historic Center of Gjirokastra, as determined by UNESCO and international NGOs. There is an urgent need for emergency restorations of cultural monuments funding. There are at least 169 cultural monuments of category I and II designated inside the Historic Center of Gjirokastra that are in critical condition, threatened to be completely destroyed. To highlight the extreme situation, in 2011 the UNESCO World Heritage Center warned that Gjirokastra would be placed on the List of World Heritage in Danger if it did not meet certain criteria, including the development of a management plan:(http://whc.unesco.org/en/decisions/4490). None of the criteria for which the World Heritage Center expressed great concern has been met. Among the many great figures to reside in and write about this beautiful city are Ismail Kadare, Lord Byron, Edward Lear, and the female dissident of the communist period, Musine Kokolari, including many others. Machiel Kiel, the well-known historian of Ottoman architecture, has written about Gjirokastra as the best-preserved town from the Ottoman period in the Balkans, not only because of its size, but also because of the magnificence of its architecture. What is more, the city of Gjirokastra inspired a pioneer movement of heritage preservation in Albania that involved the large-scale restoration and protection of vernacular architecture in 1961, three years before the Venice Charter was created. Gjirokastra is truly an exemplary historic city, not only for its historic and architectural value, but also for the culture that it embodies as home to numerous religions and ethnic minorities. Because of its richness in tangible and intangible heritage, Gjirokastra has long been home to the National Folk Festival, which is performed inside the castle. This begs the question of the impact of the bypass on the festival, which surely will mean significant traffic congestion during this period.
We urge you to take action to stop this unlawful and unsustainable road project. Please help us save Gjirokastra, this spectacular, yet very fragile, World Heritage site.
NOTE:
The above material is prepared from a team of national experts, after it was discussed and approved in the meeting organized in the auditorium of the Albanian Academy of Sciences in Tirana on the 9th of February, 2017. The signatures are listed below
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